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 ) VERIFIED MOTION FOR MODIFICATION OF PARENTING TIME

VERIFIED MOTION FOR MODIFICATION OF PARENTING TIME

COMES NOW, the Respondent/Father, Amir H. Sanjari, pro se, and files his motion for modification to increase his parenting time with his two minor children in accordance with the Indiana Parenting Time Guidelines, and in support states:

1.  That, he is Respondent in the above-entitled cause of action,

2.  That, while Respondent/Father resided in Pittsburgh, PA, he had parenting time, with both of his minor children, as set forth in the Indiana Parenting Time Guidelines and by the Court’s orders (e.g. those of 02.04.2002 and mediation agreement of 12.10.2003- file-stamped 12.31.2003- attached here), of one weekend per month visitation as well as telephonic contact. The transportation of the children to/from Elkhart / Pittsburgh were split among the two parents,

3.  That, Respondent/Father regularly pays support ordered by the court for the children and is current on his child support payment,

4.  That, Respondent/Father has recently relocated to Grand Rapids, Michigan, (120 miles to Elkhart, IN, c.f. 355 miles Pittsburgh to Elkhart), in order to be closer to his children,

5.  That, it is requested that, in addition to unrestricted telephone contact, the visitation order be modified to provide the Respondent with parenting time, at the very least, on alternate weekends, and other times in accordance with the IN Parenting Time Guidelines.
It is further requested that the transportation of the children to/from Elkhart / Grand Rapids be equally split (half-way point at exit 44, MI 131 route) between the two parents.

WHEREFORE, the Respondent/Father, Amir H. Sanjari, pro se, requests the Court that

- his parenting time, in accordance with the Indiana Parenting Time Guidelines, with his children be modified to include, at the minimum, alternate weekends, and unrestricted telephone contact,
- the transportation of the children to/from Elkhart / Grand Rapids be equally shared by the parents,
- exit 44 on MI 131 route, half-way from Elkhart, be assigned as the point of exchange of the children,
- this modification be ordered expeditiously and not await the custody case hearing, which may potentially be delayed again.


I affirm under the pains and penalties for perjury that the above and foregoing representations are true.

______

Dr. Amir H. Sanjari, Respondent (Pro Se)

3299 Park Ridge Lane

Grand Rapids, Michigan 49525

Ph: (616) 365 2676

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 _16th_day of _April_, 2004.