SUPREME
COURT OF THE STATE OF NEW YORK
COUNTY OF
ONONDAGA
____________________________________
NOTICE
OF MOTION Index
No. M-705-95 RJI
No. 33-95-3267
Adrianne
Murtari,
Plaintiff
-- against --
John
Murtari,
Defendant
____________________________________
Motion
by: Defendant.
October
10th, 1995 at 10:00 AM at the Onondaga County Courthouse, Syracuse, New
York.
Date, Time
and Place of
hearing:
1)
Affidavit 2)
Affidavit for Custody 3)
Affidavit for Support 4)
Letters of Reference and
all the pleadings and proceedings heretofore had.
Supporting
Papers:
Relief
Demanded:
A.
An
order vacating the Note of Issue in the above-entitled action on the grounds
that it is not ready for trial and prohibiting plaintiff from future discovery
without leave of the Court.
B.
An
order replacing Mr. Joseph Lupia Jr, Esq., with another law guardian.
C.
An
order prohibiting the report of Mr. Joseph Lupia from being entered into
evidence at trial without his oral testimony.
D.
An
order allowing the defendant to conduct an independent psychological evaluation
of the plaintiff.
E.
An
order prohibiting the report of Dr. Lois Black from being entered into evidence
at trial without her oral testimony.
F.
An
order making defendant custodial parent, with an equal sharing by both parents
of physical time with Domenic; OR, An order scheduling an immediate hearing
into the issue of pretrial custody of our son, Domenic.
G.
An
order granting either parent access to Domenic while he is at daycare.
H.
An
order granting either parent first “right of refusal”, before placing our son
in third party care on a regular basis.
I.
An
order baring the Plaintiff from the marital residence unless the defendant
approves of entry and is present.
Such
other and further relief as the court deems proper.
Dated: 11 March 1996
John
Murtari, pro se
2404
Sourwood Drive
Phoenix,
NY 13135
(315)
695-4422