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 )

APPLICATION FOR EMERGENCY TELECONFERENCE TO DECIDE UPON:

- PHYSICAL EXAMINATION OF THE MINOR CHILDREN

- IN-CAMERA PSYCHOLOGICAL EVALUATION OF THE MINOR
CHILDREN, ENSURING CONFIDENTIALITY OF THEIR STATEMENTS

- TEMPORARY VISITATION ARRANGEMENT

- CHANGE OF LOCATION FOR THE CASE HISTORY, DOCUMENTS,
EVIDENCE

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 August 27, 2001, this court awarded the Petitioner/Mother, Alison Gratzol, sole legal and physical custody of the parties’ minor children, A, and M.

3.  That, on February 4, 2002, the Respondent/Father was granted “visitation with the children beginning the second Friday of each month commencing at 6:00 p.m. or other times as agreed by the parents and ending Sunday evening at 8:00 p.m. unless otherwise agreed by the parents. In addition, he shall have visitation on holidays pursuant to the Indiana Parenting Time Guidelines with copies of such to be provided to each parent by their respective counsel”.

4.  That since the filing of custody (September 11, 2002) by the Respondent/Father, the Petitioner/Mother and her husband, John Gratzol, have intensified their effort to coerce the younger minor child, M.
Indications shown by M are similar to those exhibited by the older child, A, prior to the latter starting to self-mutilate.

5.  That, the minor children are exposed to psychological and physical danger during their continued stay with the Petitioner/Mother.

6.  That, the Respondent/Father has been deprived of his agreed visitation in October (18 & 25) 2002, as a result of the Petitioner/Mother’s deception and manipulation of the minor children, and refusal to facilitate the Respondent/Father’s exercising of his visitation rights as per Court order and prior agreements with the children and the Petitioner/Mother.

7.  That, the Court has asked Dr. Anthony Berardi to carry out a psychological evaluation of the minor children and other interested parties in this case to commence in the week of November 17, 2002.

8.  That, the continued residence of the children with the Petitioner/Mother has resulted in further manipulation of the children, and their alienation from the Respondent/Father. Hence, biasing and tainting the proposed psychological evaluation.

9.  That, the Respondent/Father requests that an emergency teleconference be held before the psychological evaluation process commences so that the Court could hear and decide upon the following requests made by the Respondent/Father:
a- that, the psychological evaluation of the minor children be held In-Camera
and that the children be given assurances, as proposed by Dr. Berardi, that
their statements to him would not be divulged to the parties, hence, re-
assuring the minor children about any potential intimidation or repercussion
they may be fearful of. This is in view of the fact that they are in the
physical custody of the Petitioner/Mother. (Please see October 21,
2002, November 04, 2002 petitions).
The Respondent/Father understands that Dr. Berardi agrees that this would be
more conducive to the minor children’s comfort and openness in
communicating with him.

b- that, the Court order the minor children to undergo physical examination
including blood tests for the presence of substances / drugs the minor
children may have been exposed to.
And that, these examinations be carried out by independent qualified
physicians and professionals other than those at the Bristol Street
Pediatrics Clinic in Elkhart (where the minor children are enrolled as
patients). These should specifically exclude any participation or influence by
Dr. Mable Blunk of the same clinic.
A recommended, by Dr. Berardi, physician with experience in this area is Dr.
Thomas Soisson, MD, whom the Respondent/Father asks the Court to appoint
to carry out such examinations.

c- that, the loss of the Respondent/Father’s (October 2002) visitation times
(November, 04, 2002 petition) be addressed, and dealt with.


d- that, all evidence, documents, information and material of any and all type
and kind pertaining to this case be handled by, and maintained and
safeguarded in the physical care of Marshall Circuit Court under the
jurisdiction of Honorable Judge Michael Cook.

WHEREFORE, the Respondent/Father, Amir H. Sanjari, prays that, this Court set an
emergency teleconference in a timely manner before the psychological evaluation process
commences to hear and order:

-that the psychological evaluation of the minor children be carried out In-Camera
in order that the said children be assured that their statements would not attract
any adverse repercussions or punishment as they are currently in the
physical custody of the Petitioner/Mother.
-the physical examination (including blood test for drugs and similar foreign
substances) of the minor children by independent physicians / professionals
outside Elkhart. And that such examiners should not include any members of the
Bristol Street Pediatrics Clinic in Elkhart, in particular Dr. Mable Blunk.
The Respondent/Father asks that Dr.Thomas Soisson, MD, as recommended by
Dr. Berardi, to carry out such examinations of the children.


-the Petitioner/Mother to facilitate additional individual (one weekend each)
visitation times for M and A with the Respondent/Father which he
was deprived of in October 2002.
- that the physical location of all documents, evidence, petitions, information,
material of any and all type and kind pertaining to this case be moved to, and
they be dealt with and handled by, and maintained and safeguarded by Marshall
Circuit Court in Plymouth, Mashall County, IN under the jurisdiction of
Honorable Judge Michael Cook.


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 United States Mail postage prepaid on this _7th_day of _November_, 2002