<p> STATE OF INDIANA ) IN THE ELKHART SUPERIOR COURT NO. 5 ) SS: ELKHART COUNTY ) CAUSE NO. 20D050010DR640</p><p>IN RE THE MARRIAGE OF: ) ) ALISON GRATZOL, ) PETITIONER ) ) V. ) ) AMIR H. SANJARI, ) RESPONDENT )</p><p>EMERGENCY EXCLUSION OF LOU ANN TODD’S TESTIMONY; AND CONTEMPT OF LOU ANN TODD FOR REFUSAL TO PROVIDE SUBPOENAED DOCUMENTS; AND COURT ORDER TO HER TO PROVIDE SUBPOENAED DOCUMENTS; AND COMPENSATION FOR EXPENSES</p><p>COMES NOW, the Respondent/Father, Amir H. Sanjari, and being duly sworn upon his oath say:</p><p>1. That, he is respondent in the above-entitled cause of action.</p><p>2. That, he is the father of the parties’ minor children, A, and M.</p><p>3. That, the minor child, A, had started self-mutilation “cutting” herself while in the physical custody of the Petitioner/Mother.</p><p>4. That, while in the Petitioner/Mother’s physical custody, the children were coerced and manipulated to visit Ms. Lou Ann Todd, a social worker. </p><p>5. That, Ms. Todd’s biased and destructive role, and other issues, are in question.</p><p>6. That, Ms. Todd was deposed and (Discovery) subpoenaed, through the Elkhart Superior Court No. 5, by the Respondent/Father to appear and bring relevant documents. 7. That, Ms. Todd sent a letter (with copy enclosed to Judge Cook) to the Respondent/Father refusing to obey the subpoena while giving fallacious “reasons”.</p><p>8. That, the Respondent/Father is entitled to the documents and records in accordance with Indiana Code 16-39-2-9 (please see the letter, enclosed here, faxed by the Respondent/Father to Ms. Todd in response to her refusal).</p><p>9. That, Ms. Todd did not respond to the Respondent/Father’s communication and did not meet the deadline.</p><p>Exclusion</p><p>10. That, the Respondent/Father respectfully requests that, due to her highly questionable and inappropriate role, and circumstances of the minor children being manipulated into visiting her, Ms. Todd’s potential testimony and all her submissions be excluded from consideration in this case. </p><p>Contempt of Lou Ann Todd</p><p>11. That, the Respondent/Father respectfully seeks the Court contempt of Ms. Todd for her refusal to obey the subpoena and provision of documents.</p><p>Order to Comply with Subpoena</p><p>12. That, the Respondent/Father respectfully requests that the Court order Ms. Todd to comply with all the provisions of the subpoena and deposition and provide the requested documents at the deposition hearing set for January 24, 2003, as pre- arranged.</p><p>Award of Costs</p><p>13. That, the Respondent/Father respectfully requests that the Court award compensation for any and all expenses incurred by the Respondent/Father as a result of Ms. Todd’s refusal to obey the served subpoena, including this action. </p><p>WHEREFORE, the Respondent/Father, Amir H. Sanjari, prays that, this Court, as an emergency consideration due to the short time involved (deposition hearing on January 24, 2003, 09:30 a.m.), - exclude any and all testimony and submission by Lou Ann Todd due to her highly questionable role in this case.</p><p>- hold Ms. Todd in contempt of Court for her refusal to comply with the court served subpoena and deposition upon her.</p><p>- order Ms. Todd to comply with the subpoena and deposition order and provide all requested documents and records to the Respondent/Father at the deposition. </p><p>- award to the Respondent/Father all expenses resulting from Ms. Todd’s refusal to comply with the subpoena order. </p><p>- decide upon these issues as soon as possible due to the short time involved.</p><p>I affirm under the pains and penalties for perjury that the above and foregoing representations are true.</p><p>______Amir H. Sanjari, Respondent (Pro Se) 206 Berkley Manor Drive Cranberry Pennsylvania 16066 Ph: (724) 741 0678</p><p>CERTIFICATE OF SERVICE</p><p>The undersigned hereby certifies that a true and correct copy of the above and foregoing document was served upon the following:</p><p>Max K. Walker, Jr. Attorney at Law 131 East Franklin Street, Suite 12 Elkhart, IN 46516</p><p>By United States Mail postage prepaid on this _22nd_day of _January_, 2003</p>