STATE OF INDIANA ) IN THE ELKHART SUPERIOR COURT NO. 5
) SS:
ELKHART COUNTY ) CAUSE NO. 20D050010DR640
IN RE THE MARRIAGE OF: )
)
ALISON GRATZOL, )
PETITIONER )
)
V. )
)
AMIR H. SANJARI, )
RESPONDENT ) EMERGENCY PERMANENT
INJUNCTION
EMERGENCY PERMANENT INJUNCTION FOR:
EMERGENCY INJUNCTIVE RELIEF
AND
CONTEMPT
AND
COMPENSATION
COMES NOW, the Respondent/Father, Amir H. Sanjari, and being duly sworn upon his
oath say:
1. That, he is respondent in the above-entitled cause of action,
2. That, on January 25, 2002, a Court hearing had been set to consider the return of
Respondent/Father’s joint (legal & physical) custody,
3. That, the Petitioner/Mother had refused to let the Respondent/Father to see the
minor children on the previous evening, however, she allowed it the following
day after the Court hearing! The purpose of which was that the
Respondent/Father would not find out about the elder minor child’s self-
mutilation (while in the custody of the Petitioner/Mother) before the said Court
hearing.
Later, evidence (such as photos) of the self-mutilations were obtained by the
Respondent/Father,
4. That, Petitioner/Mother (husband) was (were) held in contempt by the Court for
interference with the Respondent/Father’s visitation,
5. That, the Respondent/Father
“…a- has been granted visitation rights [Court Order of February 04,
2002] with the child[ren]…” in accordance with the Indiana
Parenting Time Guidelines, and
“…b- regularly pays support ordered by a court for the child[ren],”
6. That, the Petitioner/Mother, inflicting Parental Alienation Syndrome (PAS) upon
the minor children against the Respondent/Father, has failed, on a number of
occasions (Court informed) and in violation of Indiana Parenting Time
Guidelines and IC 31-17-4-4 (Family) as well as the IC 35-42-3-4 (Criminal), to
present the minor child(ren) for Respondent/Father’s visitations,
7. That, the Petitioner/Mother through manipulation of events and the minor
children, interferes with the telephonic contact,
8. That, a reent episode (she has become progressively emboldened in violating
Court Orders) of such violations took place when the Petitioner/Mother failed to
present the elder minor child, after the latter’s latest self-mutilation (while in the
custody of the Petitioner/Mother), for visitation with the Respondent/Father
during the Spring Break on April 05, 2003, and again on April 11, 2003, for
monthly weekend visitation. The child’s absence due to the Petitioner/Mother’s
violation lasted seven (7) days or more (IC 35-42-3-4).
These violations are more important and significant and are compounded by, yet
again (please see above), her attempt to cover up the extent of injury due to the
child’s self-mutilation,
9. The Respondent/Father has not seen his elder daughter since the (second
weekend in) March 2003 visitation. The next scheduled visitation is the weekend
of May 09, 2003.
The Respondent/Father seeks permanent injunction against the Petitioner/Mother and
requests the following.
A. EMERGENCY Injunctive Relief
1. The Respondent/Father seeks permanent injunction to enforce parenting time
under IC 31-17-4-4 to include both visitation and telephonic contact,
2. The Respondent/Father further seeks permanent injunction to prevent the
Petitioner/Mother from further future interference in visitation and
telephonic contact,
B. Contempt
1. The above, at the very least, represent Petitioner/Mother’s multiple violation of
Indiana Parenting Time Guidelines and IC 31-17-4-4 as well as the IC 35-42-3-4.
Respondent/Father seeks permanent injunction against the Petitioner/Mother, and
requests that the Court hold the Petitioner/Mother accountable and in contempt
based upon the above Codes and summon her to show cause as to her actions in
interfering with the paternal visitation (including telephonic), and her violation of
the Court Order and IN Parenting Guide Lines and above Codes.
The Respondent/Father seeks, and will continue to seek, maximum punishment
(permitted under the above Codes) of the Petitioner/Mother for such violations
under both Family Codes (IN Parenting Guidelines & IC 31-17-4-4) as well as
Criminal Code 35-42-3-4.
C. Compensation For Expenses
1. That, the Respondent/Father further seeks reasonable relief and compensation
($500) from the Petitioner/Mother, for the cost of having to file this Injunction
and any and all related expenses in dealing with this matter (including lost time,
travel, etc…) caused by the Petitioner/Mother, as well as punitive damages
against her. This is not the first time that Petitioner/Mother and/or her husband
have interfered with the Respondent/Father’s visitation.
WHEREFORE, the Respondent/Father, Amir H. Sanjari, requests the Court,
- issue a permanent injunction to enforce parenting time,
- hold the Petitioner/Mother accountable and in contempt and apply to her maximum
punishment for these violations under both Family and Criminal Codes,
- award the Respondent/Father all the appropriate and relevant expenses and costs
incurred in dealing with this matter, as well as awarding punitive damages to the
Respondent/Father and against the Petitioner/Mother.
I affirm under the pains and penalties for perjury that the above and foregoing
representations are true.
______________________________
Amir H. Sanjari, Respondent (Pro Se)
206 Berkley Manor Drive
Cranberry
Pennsylvania 16066
Ph: (724) 741 0678
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the above and foregoing
document was served upon the following:
Max K. Walker, Jr., Attorney at Law
131 East Franklin Street, Suite 12, Elkhart, IN 46516
By Fax and/or United States Mail postage prepaid on this _02nd_day of _May_, 2003