Letter from Peter Bunch to Nancy

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ZIMMER & BUNCH LLC
Attorneys at Law
680 Umpqua Bank Plaza
Gary J. Zimmer One S.W. Columbia Street
Peter Bunch Portland, Oregon 97258-2007
Angela M. Bentz
Carey M. Haladay Telephone: 503-295-6191
Sarah H. Bond Facsimile: 503-294-0108
Attorneys email: peter@zimmer-law.com
Website: www.zimmer-law.com
K:\PB\SHAFFER, PARK\NICKLES 01.DOC
April XX, 2010
Nancy Nickles
2118 19th St., Apt #15
West Linn, OR 97068
Re: Custody and Parenting Time Issues with Park Shaffer
Dear Ms. Nickles:
Please be advised that I represent Park Shaffer. I have reviewed the judgment
of dissolution of marriage. It is my understanding that you and Mr. Shaffer now reside in
Clackamas County. In the event that there are future legal proceedings between the
two of you, Mr. Shaffer believes it makes sense to change the venue of any legal
proceedings to Clackamas County. Accordingly, I enclose for your review a stipulated
order transferring venue of your case to Clackamas County.
If the form and substance of this order are acceptable, please sign where
indicated before a notary public. Please then send the order to me in the enclosed, selfaddressed,
stamped envelope. I have also enclosed a copy for your records.
Please understand that this document impacts legal rights. You should have an
attorney of your choice review the document. If you do not have an attorney, the
telephone number of the Oregon State Bar attorney referral service is 503.684.3763.
It is my further understanding that, pursuant to the terms of your judgment of
dissolution of marriage, you and Mr. Shaffer are to have equal parenting time with your
two children. Noah, however, has not been participating in the court-ordered parenting
time. Mr. Shaffer believes that the status quo is not in Noah's bests interests.
Accordingly, he is requesting that you immediately meet with him, and Noah's
psychologist, Dr. Terry Jenkins, to establish a predictable and prompt reunification plan
to effectuate the court-ordered parenting time between Noah and his father, as well as
Noah and his brother.
Noah plainly needs the love and support of both parents. He is not of an age at
which he has the discretion to decide at which house he will reside. You are also at risk
of being in contempt of court if you do not facilitate, and encourage, Noah's parenting
time with his father.
Z I M M E R & B U N C H L L C
ATTORNEYS AT LAW
Nancy Nickles
RE: Custody and Parenting Time Issues with Park Shaffer
April XX, 2010
Page 2
K:\PB\SHAFFER, PARK\NICKLES 01.DOC
Mr. Shaffer will be contacting you regarding working together with Dr. Jenkins to
resolve these issues. Please understand that he has authorized me to take appropriate
legal action unless you promptly work with Mr. Shaffer to address the serious problems
with the current parenting time arrangement and its impact on Noah.
If you retain a lawyer, please provide a copy of this correspondence to him or
her. I will direct all future correspondence to your lawyer.
Mr. Shaffer wants to reiterate that it is in the children's best interests to resolve all
issues amicably. He is committed to doing so.
Very truly yours,
ZIMMER & BUNCH LLC
Peter Bunch
PB/am