Generated on Jan 15, 2025, 12:05:03 PMgemini-1.5-flash
Letter 1: Petition for Contempt of Court - Child Visitation Violation
File # 597402, Docket # F-08413-16/20E, CSMS # BX96657N1
To the Honorable Judge [Judge's Name],
This letter constitutes a formal petition for contempt of court against Cristina Lezcano, mother of my children, Isabella (15) and Isaiah (11), regarding consistent and egregious violations of our existing child visitation order. The order, dated [Insert Date of Order], outlines a shared custody arrangement including specific pick-up and drop-off responsibilities. Ms. Lezcano has flagrantly disregarded this agreement for an extended period, severely impacting my relationship with my children.
Specifically, Ms. Lezcano has repeatedly refused to adhere to the agreed-upon pick-up and drop-off schedule for over five years. This pattern of non-compliance is not occasional; it is a consistent pattern of behavior designed to limit my time with my children. This is further evidenced by:
Missed School Days: Isabella and Isaiah have accumulated numerous unexcused absences from school over the past several years, often attributed to vaguely defined "illnesses." I have not been notified of these absences, raising concerns about Ms. Lezcano's prioritization of my children's education.
Endangerment of Children: Ms. Lezcano's actions have placed my children in danger. She previously stated in court that the police were called to her residence multiple times due to her fiancé's behavior. Despite his arrest for domestic violence, she subsequently allowed him to move into her new apartment, providing him with the address and exposing the children to further stress.
Phone Call Monitoring: On September 20, 2023, Ms. Lezcano was caught monitoring my phone calls with the children. My request to cease this invasive behavior was met with anger. (Text messages documenting this incident are attached as Exhibit A).
Last-Minute Visitation Changes: On July 20, 2023, Ms. Lezcano informed me at the last minute that Isabella would not be attending my scheduled weekend visitation. (Text messages are attached as Exhibit B). This is a recurring pattern of last-minute cancellations and changes, causing significant disruption and emotional distress for both me and my children. Numerous other instances of late pick-ups, missed pick-ups, and significant delays exceeding 30 minutes are also documented (Exhibit C).
Financial Non-Disclosure: Ms. Lezcano has failed to report increases in her earnings, impacting the fairness and accuracy of the current child support order.
These repeated violations are not only a breach of the court order but also inflict significant emotional harm on my children and me. Ms. Lezcano's actions demonstrate a deliberate attempt to undermine my parental rights and severely restrict my relationship with my children.
Therefore, I respectfully request the court to:
Issue an order to show cause to Ms. Lezcano, compelling her to explain her consistent non-compliance with the visitation schedule.
Impose appropriate sanctions against Ms. Lezcano for her contempt of court.
Modify the existing visitation order to include stricter enforcement mechanisms to prevent future violations.
Investigate the circumstances surrounding Ms. Lezcano's ex-fiancé and ensure the safety and well-being of my children.
Implement a system to monitor communication between Ms. Lezcano and myself to mitigate further conflict.
Provide guidance on US Government passport possession policies for international travel with my children.
Dismiss the arrears of approximately $2,290.18, acknowledging the $100 cash payments that were not properly recorded despite Ms. Lezcano's confirmation of receipt.
Enforce the pick-up and drop-off schedule on alternate weekends as originally stipulated.
Cancel child care expenses and refund all payments made while family members resided with Ms. Lezcano, given that Isaiah has had consistent childcare provided by family members since he was nine years old.
Maintain the children's enrollment on Ms. Lezcano's health insurance plan.
Establish a third-party mediator for medical decision-making due to ongoing disagreements between Ms. Lezcano and myself.
Lift any unnecessary restrictions on my visitation with my children.
Request a recent paystub from Ms. Lezcano to verify her current wage.
I have attached copies of the existing court order, text messages documenting recent communication attempts, and other relevant evidence to support my claims. I am available to provide further information or testimony as needed.
Sincerely,
Isaac Pilier 516-574-1876
Letter 2: Petition for Child Support Modification
File # 597402, Docket # F-08413-16/20E, CSMS # BX96657N1
To the Honorable Judge [Judge's Name],
I, Isaac Pilier, respectfully request a modification to the existing child support order in case number [Case Number]. The current order mandates a bi-weekly payment of $[Current Child Support Amount]. Due to a significant change in my circumstances, I am requesting a modification to reflect my current financial capabilities.
Significant Change in Circumstances:
On October 16, 2023, I was unexpectedly laid off from my previous employment. This resulted in a substantial reduction in income. While I secured new employment on December 16, 2023, my current annual salary of $75,000 is significantly less than my previous income. My net bi-weekly income after taxes is $2,177.80. The current child support obligation, including arrears and childcare costs, totals $1,227 bi-weekly. This leaves me with only $950.80 bi-weekly, or $1,901.60 monthly, to cover my living expenses.
My monthly expenses include:
These expenses alone exceed my remaining income after child support, leaving insufficient funds for food, utilities, and other essential needs. Furthermore, my medical insurance premiums of $400 per month will commence in March 2024, further straining my budget. The current child support obligation of over 50% of my net income is unsustainable. The $55 weekly childcare expense for my 11-year-old son, Isaiah, is also unwarranted, as he has received consistent childcare from family members for several years, eliminating the need for external care.
Attached Documentation:
I have attached the following documents as supporting evidence:
Proposed Modification:
Considering my reduced income and increased expenses, I respectfully request a modification to the child support order, reducing the amount to a figure that accurately reflects my current financial capacity while still ensuring the well-being of my children. I propose a bi-weekly payment of $[Proposed Amount], pending a review of Ms. Lezcano's income and expenses. I also request a review of the childcare expenses, given that Isaiah's care is provided by family members.
Thank you for your time and consideration.
Sincerely,
Isaac Pilier 516-574-1876