United Stales Department of' State

Washington,D.C. 20520
UNITED STATES CENTRAL AUTHORITY
HAGUE CONVENTION ON THE C M L ASPECTS OF
INTERNATIONAL CHILD ABDUCTION
Office of Children's Issues
U.S.Department of State
Washington, D.C. 20520
TEL: (202) 736-9130

April 2,2009

Roy L. Moms, Esq.

11725 Greenland Drive
Potomac, MD 20854

Re: KTNG-PFEIFFER. Ariana-Leilani Marearita Alexandra

Dear Mr. Morris:

Pursuant to your request, enclosed, please find a Hague Convention application package. The
application was filed by the child's mother, Dr. Ariel King and forwarded to our office by the
Central Authority of Germany. I understand Dr. King has retained you directly to file her Hague
application in court.

PLEASE NOTE: Address information in the Hague application is provided for the purpose
of service of process for legal proceedings only and should not be released to anyone except
for that purpose. Release of address information to the left-behind parent is prohibited.

At your request, we will provide, a letter to the presiding judge explaining the obligations of the
United State's court under the Hague Convention.

It would be most appreciative if you would keep me apprised of the case status (ie. when the case
is filed; when the Hague hearing is scheduled, etc.) so that I can keep the German Central
Authority informed. If you have any questions, please feel free to contact me at 202-663-1343 or
by e-mail at moffitci@,state.eov.

~bductionsUnit Case Officer

 BUNDESAMT FUR JUSTIZ
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POSTAL ADDRESS SUnctesafntfUrJiiSiL; SaOS4 BONN GERMANY

AIRMAIL STREEl ADDRESS Adenauerallee 99 - 103,53113 Bonn

US. Department of State POETALADDRESS 53034 BONN, GERMANY
Office of Children's Issues, SA-29 CONTACT Angelika Laueri
2100 Pennsylvania Ave NW, 4th Floor 01UISION 11 3
WASHINGTON, DC 20037 PHONE 4 9 (0)22399 410 - 54 17
United States of America FAX 4 9 (0)22899 410 - 54 01
E MAIL Int.soqereohlgbfj.bund de
SRIC- A - 66/09
- partly in advance bv Fax: 001 202 736 HIE NO
BANKACCOUNT Account No 380 01 006
9133 or 001 202 736 9132 - Bundesbank Fll. Koln (bank code no. 370 000 00)
DATE Bonn, 10 March 2009lGie

SUBJECT Hague Convention on the civil aspects of International child abduction of 25 October 1980

CONCERNING Child: Ar~anna-LeilanaKing-Pfeiffer, born 7 May 2003

ENCLOSURES - Application
-- Authorisation
Request

- Legal Background on US Custody System

- Contact addresses
- Dossier including (only by mail):
- Photos of mother and child
- Certificate of Marriage
- Copy of child's passport of the child
- Certification of vital records
- Copy of Passport of the father
- Permanent Resident card of the father
- Copy of the passport of the mother
- List of court Orders

Dear Sir or Madam:

Enclosed please find a new application under the Hague Convention on behalf of the mother,
s Ariel Rosita King, for organising the effective exercise of rights of access with the
~ r Dr.
above mentioned child.

The case is registered in our office under case number:

INTERNET w.bund~alusiisanrt-6a
PAGE 2 OF Z

Please be so kind to cite this number in subsequent correspondence,

Please acknowledge receipt of the application, exhaust all possibilities available in order to
locate the child as soon as possible and please inform the competent social services about
the allegation concerning the child's sexual abuse.

Please keep me informed about any progress in due course

If you need further information or documents please do not hesitate to contact me.

'Your assistance in this return matter is greatly appreciated here.

Yours sincerely
For the Central Authority
Lauen

.. ...
 BUNUI-toWI I-UK JUSl lL

-. ,

BIRGIT KRUSMANN
Rechtsanwaltin
FachanWaltin fur Familienrecht HaydnstraRe 10,80336 Munchen

vorab per e-mail

Zentrale BehSrde
Frau Bachfeld
Adenaueralie 99 103 -
53094 Bonn

- HURRIES MUCH !!!I

IHR ZCICHEN

Request for arrangements for organizing or securing the effective exercise of access
concerning the child
Ariana-Leilana King-Pfeiffer, born at 07.0S.2003 in Houston Texas the USA,
4836 reservoir Road 3, Washington DC 200007,
and also because of child well-being endangerment

I indicate to the special authority under main  606 Abs I ZPO that I am the lawyer who
represents the child's mother: Ariel Rosita King, resident: Arnoldstrasse 34, Bayreuth D-
95445. who is American citizen.

The child's mother has substantial doubts around the well-being of her five-year daughter
Ariana-Leilani, who is living with the child father, since the justified suspicion of a sexual
abuse exists by the child's father. Besides since May 2008 the daughter has
Neutropinia, with the abililty t o fight infection is clearly reduced, yet surprisingly the
Father refuses to provide the child however the necessary full medical assessment
and treatment The child's father for eight months has prevented contact of the child's
mother with her daughter. Likewise he refused contact to the grandmother and the
remaining relatives as well as former friends to have any contact with the child,

The five-year child, Ariana-Leilana therefore needs assistance as fast as possible, in

order to protect her mental and physical well-being.

-
Proof: photos of child and mother in copy, ehibit.
- A la-d -

In--- - -. - .. mil":
.. Conoeratinn .
GERMAN LE3AL SERllICES. Carol n Scn-u-Burpss, 3C6 SQLm WalAer Sireel C0.i-mbia. SC 292D5, 2%
?el 0')' e03 254 8153 e-r^aiI. cscOmrmar- m a ssriice3 corn memdl' f.'v.v^ernan e c a . % r w ; e D
 Rachtsanwaitin Birgit Kmrnann HKV final application engllsch 10.02

1. Access

Mother and child had a closed and faithful realationship. The child's father for
eight months has prevented contact of the child's mother with her daughter,
based on a illegal and false decision of a judge in virginia, who did no
consider the child's interest in any way. Likewise the childfather refused
contact t o the grandmother and the remaining relatives as well as former
friends t o have any contact with the child.

Proposed arrangements for access:

- Five days each week with overnights every second weekend or if not possible
one week with overnihht each month
- Half of the school-holidays with overnight
-- telephone contact every evening
current informations about her health and from doctors and school~teachers

2. Circumstances

The child's mother, Dr. Ariel King, represented by me, had a marriage license issued.14.
02.2000 in Phoenix Arizona with Dr. Michael Pfeiffer,. Out of the marriage the parties had a
child Ariana- Leilana, born 07.05.2003. Ariana Leilana has both the German and the
American nationality. The child father is German citizen, who due to the marriage has a visa
for the USA that turned out later to be invalid as it was obtained fraudulently. Dr. Pfeiffer is a
neurologist who is employed in a group practice in Virginia.

The child's mother, Dr. Ariel King studied public health, policy and management obtaining a
doctorate degree and two master degrees at various international universities. She created
the Ariel Foundation international, an international relief organization, which Is active in Africa
in the year 2002. She is a chairman of the Foundation. In addition, she created a company
Ariel Consulting International, Inc., which advises African governments in public-private
partnerships.

The child's mother is internationally active and has several domiciles, that include a house in
in Maryland, in 11725 Greenlane Drive, Potomac, MD, 20854, a home which she and her
daughter lived to toegher until June 2008.

-
Proof:
- copies of: marriage certifikatton, Birth certificate. German Passport and
American passport (Expired May 2008) of the child Ariana Leilana, German
passport and American visa child father, Dr. Micheal Pfeiffer and repeated
residence permit of the child's mother Dr. Ariel King, brochure of the Ariel
Foundation international, and Ariel Consulting international inc. and university
degerees
-A2a-5h-

Since the birth of Ariana-Leilana, the child's mother was dedicated exclusively to her
daughter, the household, and the child's fathers carrer while she gave up her occupation.
After the child's father in the Spring 2007 accepted a position to practice to in Florida and
1 B / B3/2609 10: 43 0049228994105401
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RechtsanwaitinBirglt Krusmann H K ~final
I application englisch 10.02 -Sate 3 -

bought a family house there, the child's father decided some weeks before he left that
suddenly he did not to take over the medical practice in Florida. The past family dwelling unit
was already dissolved. The child's father abandoned the family shortly on 17.06.2007,
without leaving financial means for their accommodation and necessary living costs at their
disposal. He vacated the child's mother from all the accounts, and emptied the child's bank
account, and closed all the credit cards. The child's mother found emergency accomodation
with the daughter temporarily with acquaintances for several weeks.

Then child's mother found temporary accomodation in Virginia. Later, within three months
when sufficient financial means were available, the child and her mother rented in Maryland
for herelf and her daughter. The daughter lived since the separation of child parents in June
2007 in the household of the child's mother and had regular visits with the child's father.

Later, than the child's mother hired a German Au Pair, Melina Orphanopolous, with her help,
she was able to work and when sufficient financial 'means were available, the child's mother
rented a house in Maryland, 11725 Greenlane Drive, Potomac, MD. for herself and her
daughter. The daughter, Ariana-Leilani since the separation of the child parents in June 2007
has lived in the household with her mother and had regularly visits with her father. The child
since 2006 has attended the German School in Potomac Maryland, once weekly a Hebrew
school, took swimming, ballet, gymnastic and piano instruction and beganviolin instruction.
The mother promoted her well-being in various way and was attendive to her emotional,
mental, psychological and physical development. Since 17.06.2008 the child now lives in the
household of the child's father because of an untenable decision due to an incompetent court
in Virginia, which the father obtained a custody switch when the child's mother had to care
for her own mother when she became critically ill and she had to care for her in the intensive
care unit of a hospitalthe. Since that 16.06.2008 the child's mother and also the many
remaining relatives and acquaintance that she has known all her life do not have any contact
with the child.

In detail:

Between the parties since 17.06.2007 there have been different custody procedures and
separation procedures are that were pending in different Federal States of the USA.

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Proof: list of ameiican court cases in copy as plant

On 20 07 2007 the child's father in Washington made an application for pending the divorce.
full custody of their daughter and maintenance, the complaints was rejected, since the court
was not responsible in Washington, DC., because the father had not lived there for a full 6-
months.

On 9.08.2007 the father then made another appolciation for full custody in Virgina. The
child's mother with the initial decision 05.09.2007 had the exclusive parental custody of her
daughter, Ariana-Leilani, while the child's father had regular visits, i.e. each Wednesday
evening with overnight accomodation and one overnight weekend.

-
Proof: Custody decision of 05.09.2007 from Virginia copy attached
- AT-
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Rechtsanwallln Blrglt KrUsmann H K final
~ application ertallsch 10.02 -Seite4-

On 15.10,2007 the chiid's mother in Maryland filed for custody, maintenance and divorce, the
child's father filed to have the application dismissed. In March 2008 the child's mothers
request was rejected, since the Maryland court mistakenly erred that was not responsible.

As the child's mother file for Divorce in Washington DC Court on 18.04.2008 the child's
father through a written answer by his lawyer stated on 30.05.2008 that the marriage was not
valid in the USA, since the mother and father did not have amarriage ceremony in Arizona
with her Arizona Marriage Lisence. From some documents it became evident that the child
father knew of this circumstance and had already admit that the marriage ceremony in
Houston Texas did not meet the requirement of the Arizona iisence, therefore, there is no
valid legal marriange. Understandably the rather conservatively thinking child's mother was
very shocked andfelt betrayed by this fact.

-
Proof: Writ of the lawyer from May 2008 in copy as plant
-A8-

On 08.02 2008 the child's father requested from the incornpeten Virginia court full cutody for
himself. When the child's mother at the end January 2008 had to attend to her seriously ill
mother in an Atlanta hospital intensive care unit, Anana-Leiiani, and the German Au Pair,
Melina all went to Atlanta. The mother arranged for the fath
er to visit the chiid while in Atlanta, however he said he was too busy. Yet, the father
contacted by phone the surgeon who treated the mother saying that he wanted to help the
child's grandmother. Instead he gave false information to the court that the granmother was
not really sick and the mother was lying about the severity of her illness.

Custody was transferee! temporarily to .the father before an incompetent court in Virginia until
the mother returned from Atlanta. The child's mother returned from Atlanta with the child
father after he obtained on 08.02.2008 a temporal limited transmission of the exclusive
parental concern in Virginia before an actually incompetent court.

The request was justified with the fact that the mother's lawyer filed the verification was filed
two days late that verified that the mother had met the conditions to have custody
automatically reversed back to her.

Proof: Temporary order Virginia 21.02.2008 in copy as plant

Only in June 2008 the child's mother, due t o the strongly changed behavior of the
child, sought help because the child would bite herself, cry, scream, and refuse
overnight visits. Under desperate stress the dhild would bite herself, had injuries on
her body, and spoke in English and German t o several people about seeing 'Mr.
Piggys' Penis and saying that she was scared to sleep in the big bed with her father.
The father insisted o n overnights and would go to the child's large bed (2 person). At
first it did not become clear that her daughter is being sexually abused, but with her
daughter's behaviour and verbalizaiton with confirmation from professionals that her
daughter was being obviously sexually abused by her own father, Dr. Michael Pfeiffer.
The child's mother consulted a child play therapist before knowing the reasons fort he
changed behavior.