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DOCKET NO. MMX-FA-12-401 8627-S TANYA TAUPIER VS. EDWARD TAUPIER SUPERIOR COURT J,D. OF MIDDLESEX AT MIDDLETOWN JUNE 20, 2018 PLAINTIFFラS MOTION FOR MODIFICATION JUDGMENT Pursuant to Comecticut General Statutes §46b-56 plainti算Tanya Taupier, reSPeCtfully requests that the c parenting time with㍉md access to, the parties’minor child In support thereof; the plaintiff represents as follow l. On August 28, 2015,血e mamage of the par Memorandum of Decision following trial orinkus, J.). 2. Pursuant to the court’s judgment, Paragraph 4, w弛1∴the chiidren includes every other weekend and school yean During the s皿mer mOnths,血e defchdant’s includes every other week (begiming or ending on Sund parent,s parenting time, the party who does not hav 国漢書国

TANYA TAUPIER J,D. OF MIDDLESEX VS. AT MIDDLETOWN … · docket no. mmx-fa-12-401 8627-s tanya taupier vs. edward taupier superior court j,d. of middlesex at middletown june 20, 2018

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Page 1: TANYA TAUPIER J,D. OF MIDDLESEX VS. AT MIDDLETOWN … · docket no. mmx-fa-12-401 8627-s tanya taupier vs. edward taupier superior court j,d. of middlesex at middletown june 20, 2018

DOCKET NO. MMX-FA-12-401 8627-S

TANYA TAUPIER

VS.

EDWARD TAUPIER

SUPERIOR COURT

J,D. OF MIDDLESEX

AT MIDDLETOWN

JUNE 20, 2018

PLAINTIFFラS MOTION FOR MODIFICATION OF PARENTING TIME・ POST

JUDGMENT

Pursuant to Comecticut General Statutes §46b-56 and the Court’s inherent authohty, the

plainti算Tanya Taupier, reSPeCtfully requests that the court modify the defendant, Edward Taupier’s,

parenting time with㍉md access to, the parties’minor children, Gabriel (age 12) and Sara (age l l)・

In support thereof; the plaintiff represents as follows:

l. On August 28, 2015,血e mamage of the parties was dissoIved pursuant to a

Memorandum of Decision following trial orinkus, J.).

2. Pursuant to the court’s judgment, Paragraph 4, the defendant’s regular parenting time

w弛1∴the chiidren includes every other weekend and Tuesday and Thursday evermgs, during the

school yean During the s皿mer mOnths,血e defchdant’s regular parenting time with the children

includes every other week (begiming or ending on Sunday at 7 p.m.) Additionally, during the other

parent,s parenting time, the party who does not have parenting time on that day is entitled to

国漢書国

Page 2: TANYA TAUPIER J,D. OF MIDDLESEX VS. AT MIDDLETOWN … · docket no. mmx-fa-12-401 8627-s tanya taupier vs. edward taupier superior court j,d. of middlesex at middletown june 20, 2018

telephone contact with the children between 7:30 p.m. and 8 p.m・ (For the court’s specific orders, See

Memorandum of Decision, dated August 28, 201 5, attaChed hereto as Exhibit A)・

3. On January 17, 2017, the court (Albis, J.) approved and made an order ofthe court, the

Agreement of the parties’(#225.00), Wherein both parties agreed that they and their minor children

(currently ages 12 and =) would submit to a psychoIogical evaluation.

4. On February 24, 2017, the court (Dormarski, J.) entered an order that:

Pursuant to the agreement of the parties made an order of

the court on January 17, 2017, Whereby the parties and the minor

children are to submit to a psychoIogical evaluation, and upon the

inability of the parties to agree upon the selection of an evaluator,

it is hereby ORDERED:

PsychoIogical evaluations of the plaint距Tanya Taupier,

the defendant Edward Taupier, and the parties’minor children

Gabriel and Sara, Shall be conducted by Dr. Bruce Freedman of

BIoomfield, Comecticut.

5. On July 7, 201 7, Dr. Freedman completed his psychoIogical evaluation, but could not

make recommendations as to changes to custody or visitation, because血e defendant did not

Participate in the process.

6. On August ll, 2017, the defendant, Who had been free on an appellate bond in

COmeCtion with his conviction on various charges, including threatening in the first degree, WaS

arrested on an additional ten charges (five felony and five misdemeanors). The defendant has been

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Page 3: TANYA TAUPIER J,D. OF MIDDLESEX VS. AT MIDDLETOWN … · docket no. mmx-fa-12-401 8627-s tanya taupier vs. edward taupier superior court j,d. of middlesex at middletown june 20, 2018

incarcerated since his arrest on that date, and is currently expected to be released on or about January

lO,2019.

7. The current parenting schedule is no Ionger in the minor children,s best interests’nOr

is it in their best interests to have any telephone contact with the defendant during his period of

lnCarCerati on.

WHEREFORE, the plaint肝respec血Ily requests that the co血modify its Judgment

of dissolution and suspend the defendant,s access to the minor children, including through telephone

contact, until further order of the court or agreement of the parties’in wrltmg; Order the defendant,

upon his release from incarceration, tO Participate in a psychoIogical evaluation with Dr. Freedman;

and order such other and further relief as the court deems proper.

The Plaintiff;

Tanya Taupier

By:

Ame C. Dranginis

Pullman & Comley, LLC

90 State House Square

Hartford, CT O6103-3702

Juris No. 47892

Telephone 860 424 4300

Facsimile 860 424 4370

Her Attomeys

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Page 4: TANYA TAUPIER J,D. OF MIDDLESEX VS. AT MIDDLETOWN … · docket no. mmx-fa-12-401 8627-s tanya taupier vs. edward taupier superior court j,d. of middlesex at middletown june 20, 2018

DOCKET NO. MMX-FA-12-401 8627-S

TANYA TAUPIER

VS.

EDWARD TAUPIER

SUPERIOR COURT

J.D. OF MIDDLESEX

AT MIDDLETOWN

JUNE 20, 2018

PLAINTIFF)S MOTION FOR CONTEMPT RE: PSYCHOLOGICAL EVALUATION‘ POST

JUD GMENT

Pursuant to Comecticut General Statutes §46b-87 and the Court’s inherent au血ority, the

plaintiff; Tanya Taupier, reSPeCtfully requests that the court hold the defendant, Edward Taupier, in

contempt for his willful violation of the court’s orders as to a psychoIogical evaluntion. The plaintiff

further requests that the court enter additional orders to enforce its prior orders, eVen in the event a

COntemPt finding is not made.

In support thereof;血e plaintiff represents as fo11ows:

1. On August 28, 2015, the mamage of the parties was dissoIved pursuant to a

Memorandun of Decision following trial ainkus, J.).

2. On January 17, 2017, the court (Albis, J.) approved and made an order ofthe court, the

Agreement of the parties’(#225.00), Wherein both parties agreed that they and their minor c皿dren

(currently ages 12 and l l) would submit to a psychological evaluation.

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Page 5: TANYA TAUPIER J,D. OF MIDDLESEX VS. AT MIDDLETOWN … · docket no. mmx-fa-12-401 8627-s tanya taupier vs. edward taupier superior court j,d. of middlesex at middletown june 20, 2018

3. On February 24, 2017, the court (Dormarski, J.) entered an order that:

Pursuant to the agreement of the parties made an order of

the court on January 17, 2017, Whereby the pa正es and the minor

Children are to submit to a psychoIogical evaluation, and upon the

inability of the parties to agree upon the selection of an evaluator,

it is hereby ORDERED:

Psychological evaluations of the plaintiff Tanya Taupier,

the defendant Edward Taupier, and the parties’minor children

Gabriel and Sara, Shall be conducted by Dr. Bruce Freedman of

BIoom宜eld, Comecticut.

4. On July 7, 201 7, Dr. Freedman completed his psychoIogical evaluation, but could not

make recommendations because the defendant did not participate in the process.

5. Notwithstanding the court’s clear and unambiguous orders, the defendant has willfully

failed to comply with the sane and has refused to participate in血e psychoIogical evaluation with Dr.

Freedmanl.

WHEREFORE, the plaintiff respectfu11y requests that the court find the defendant in

COntemPt for his failure to pa正cipate in the psychological evaluation by Dr. Freedman; Order the

defendant to pay the plaintiffs costs in preparmg and prosecuting this motion, including but not

limited to attomey fees; SuSPend the defendant’s access to the children (including by telephone for so

1 A皿ough the defendant is currently incarcerated, he was not incarcerated during the period in

Which Dr. Freedman conducted his evaluation and issued his report.

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Page 6: TANYA TAUPIER J,D. OF MIDDLESEX VS. AT MIDDLETOWN … · docket no. mmx-fa-12-401 8627-s tanya taupier vs. edward taupier superior court j,d. of middlesex at middletown june 20, 2018

long as the defendant remains incarcerated) unless and until he participates in the psychoIogical

evaluation; and such other and餌her relief as the court deems proper.

The Plaintiff;

Tanya Taupier

By:

Ame C. Dranginis

Pullman & Comley, LLC

90 State House Square

Hartford, CT O6103-3702

Juris No. 47892

Telephone 860 424 4300

Facsimile 860 424 4370

Her Attomeys

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