Message-ID: <9743955.1075852778984.JavaMail.evans@thyme> Date: Tue, 23 Oct 2001 08:04:42 -0700 (PDT) From: postmaster@enron.com To: joe.stepenovitch@enron.com Subject: Delivery Status Notification (Relay) Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: postmaster@ENRON.com X-To: Stepenovitch, Joe X-cc: X-bcc: X-Folder: \JSTEPENO (Non-Privileged)\Deleted Items X-Origin: Stepenovitch-J X-FileName: JSTEPENO (Non-Privileged).pst This is an automatically generated Delivery Status Notification. Your message has been successfully relayed to the following recipients, but the requested delivery status notifications may not be generated by the destination. linda.stepenovitch@bankofamerica.com --------- Inline attachment follows --------- From: To: linda.stepenovitch@bankofamerica.com Date: Tuesday, October 23, 2001 3:02:13 GMT Subject: I hope this answers your questions. -me > -----Original Message----- > From: Jonda Stowell @ENRON > Sent: Tuesday, October 23, 2001 9:40 AM > To: Stepenovitch, Joe > Cc: Donn Fullenweider > Subject: RE: Stepenovitch > > Dear Joe: > > In order to prepare your case for trial, several things are necessary, > as > follows: > > 1. Depositions must be taken of you and Tonya. > > 2. We must send discovery to Tonya and we must have sufficient time > pursuant to the Texas Rules of Civil Procedure for it to be answered > prior > to trial. > > 3. The Court will require mediation before we can go to trial. > > 4. The Court will appoint a mental health examiner and possible an > attorney > ad litem to represent Payton's best interests. > > This is now a case where custody and possession are an issue and these > steps > MUST be taken before we can proceed to trial. Initially, after > paternity > was established and you first visited with Payton, your desire was > that all > possession periods would be worked out by agreement and neither you > nor > Tonya wanted any more court proceedings. However, since then, Tonya > has > bucked your every request for visitation and put limitations of one > kind or > another on it, turning the case into a custody case. Without > discovery to > Tonya (similar to the discovery we answered for you) and Tonya's > deposition > and a mental health evaluation, we are not prepared for trial and the > Court > would not be ready to hear the case and entertain what was in Payton's > best > interest. Therefore, Mr. Fullenweider did not opposed Stewart > Gagnon's > motion for continuance, and would have, in fact, have filed one > himself in > keeping with your best interest (and Payton's) in mind. > > As I explained, we are working on a Request for Temporary Orders, > which I > expect will be set on 11/14/01, along with the hearing on mental > evaluations. At that time, I expect the court to set your possession > periods with Payton, including holidays. Until then, we must work on > scheduling your possession periods by agreement. > > To confirm your November 3rd visitation period, you have chosen to > have > Payton from 12:00 noon to 7:00 p.m. in Vero Beach on the 3rd and will > forego > November 4th. Where will you pick up and drop off Payton? > > Jonda > > > > > > -----Original Message----- > From: Joe.Stepenovitch@enron.com [mailto:Joe.Stepenovitch@enron.com] > Sent: Tuesday, October 23, 2001 9:05 AM > To: jls@fullenweider.com > Subject: RE: Stepenovitch > > > Good Morning Jonda, > > I received the papers from you yesterday about the continuance. I was > under the impression that it was the court moving the date. It looks > like > to me its Tonya and her Lawyer. They have been doing pushing this > case > back from the start and I'm sure they are doing this for a reason (to > say > to the jury: that a bond has been created and its not in the best > interest > of the child to go with his father after being with his mother for so > long) > At this point if we go to trial Payton will be 1 year old and I will > have > only seen him about 12 times. I don't think I will win that battle! > > As for the November 12th court date will we have something in writing > by > the judge so I can start having my rights! I feel like her and her > lawyer > can tell us what to do and we must follow there rules. Will this > change or > do I have to go through this until the April court date? That can't > be how > is system works. I should have the right to pick my own son up > whenever I > want and no court or lawyer or even his mother should have anything to > say > about that. I don't understand why everything is against me? > > Finally, for the weekend of Nov 1st I will take my son for the whole > day > (in Vero) on Saturday and forego Sunday. > > -Joe > > -----Original Message----- > From: Jonda Stowell @ENRON > Sent: Friday, October 19, 2001 3:33 PM > To: Stepenovitch, Joe > Subject: Stepenovitch > > > Dear Joe: > > I just received a phone call from Miryam Mitchell. She said if > you > would like to take Payton to Vero Beach on Saturday, November 3rd, > you > may have him from 12:00 to 7:00, if you are willing to forego > visitation on Sunday and let Tonya have him all day on Sunday. > > If you'd prefer this, let me know. It is your call. > > Jonda L. Stowell > Legal Assistant > The Fullenweider Firm > 4265 San Felipe, Suite 1400 > Houston, TX 77027 > (713) 624-4100 Telephone > (713) 624-4141 Facsimile > e-mail: jls@fullenweider.com > > > > > ********************************************************************** > This e-mail is the property of Enron Corp. and/or its relevant > affiliate and > may contain confidential and privileged material for the sole use of > the > intended recipient (s). Any review, use, distribution or disclosure by > others is strictly prohibited. If you are not the intended recipient > (or > authorized to receive for the recipient), please contact the sender or > reply > to Enron Corp. at enron.messaging.administration@enron.com and delete > all > copies of the message. This e-mail (and any attachments hereto) are > not > intended to be an offer (or an acceptance) and do not create or > evidence a > binding and enforceable contract between Enron Corp. (or any of its > affiliates) and the intended recipient or any other party, and may not > be > relied on by anyone as the basis of a contract by estoppel or > otherwise. > Thank you. > **********************************************************************