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NO. N23N-CR-12-0132781-S STATE OF CONNECTICUT VS.

TAMARA SYTCH

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SUPERIOR COURT GEOGRAPHIC AREA 23 December 4, 2012

MOTION TO MODIFY PROTECTIVE ORDERS The defendant, Tamara Sytch, through her undersigned counsel, respectfully requests this court modify all existing No Contact Protective Orders to Partial Protective Orders for the purpose of allowing the defendant, Tamara Sytch, to speak, and interact, with Damien Selvaggio, the party classified as the victim under Connecticut Law. In support of this request the defendant, Tamara Sytch, through her undersigned counsel, represents as follows: 1) At this time a full no contact order is in place, preventing either party from having contact

with each other. 2) At this time, the defendant Tamara Sytch, and the party classified as the victim, Damien

Selvaggio, believe the order should be modified, and request, said action be taken, with the purpose 1

of the modification to allow the parties to speak over the phone and via electronic mail. In further support of the Motion the defendant, Tamara Sytch, through her undersigned counsel represents the following additional facts. 3) At this point the defendant, Tamara Sytch, has completed the detoxification portion of her

treatment at the Caron Foundation, and has been inpatient for a period of close to 50 days. Alcohol or drugs will play no role in any interaction between the defendant, Tamara Sytch, and Mr. Selvagio which were at the center of, and the main cause of past events which led to court involvement. In short the major contributing factor, which led to the defendants arrests, is no longer present. 4) Both parties have not spoken since approximately October 18, 2012, allowing for ample time

for the emotional elements of this case to subside and allowing both parties to interact like rational adults. 5) Tamara Sytch is currently housed at Concept 90, in Harrisburg Pennsylvania, and any

contact will be via telephone or electronic mail. As a result, there exists no risk there will be another domestic dispute like those that have already taken place and make up the subject matter of her pending charges. This is an extremely regimented facility and any behavior deemed unacceptable would lead to the loss of phone and inter-net privileges. 6) In addition, the purpose of the defendant participating in treatment is to allow her to address 2

certain issues and avoid finding herself in similar situations in the future. At this time the failure of the parties to speak with each other has created a situation of uncertainty and questions for both parties, which tends to undermine the defendants current treatment goals. In essence, it is easier to concentrate on moving forward without questions lingering from the past. Allowing the parties to speak would essentially allow for the possibility of closure and the ability for both to move forward. 7) In the undersigneds understanding these facilities are concerned with following court orders

and are only concerned with compliance of said orders. The undersigneds understanding is if the court will allow contact, they take no issue with such a decision nor have an opinion. 8) Finally, Mr. Selvaggio has contacted the undersigned on numerous occasions offering

information that has been helpful to the undersigned in formulating and understanding a treatment plan for the defendant. He has been polite, has thanked me for my becoming involved in the case and can be described as an asset to the defense. To be clear, he has been an asset to the defense in many ways providing a great deal of insight related to certain situations that has proven extremely valuable. At this point the undersigned believes Mr. Selvaggio has a great deal of insight to offer the defendants treatment providers and this will only serve to benefit the defendant and her treatment goals.

WHEREFORE, the defendant, Tamara Sytch, respectfully requests that the Motion for Modification of Protective Order, be granted and modified from a Full Contact Order to a Partial Protective Order, for the reasons stated therein and for such other grounds as may be asserted at a full hearing on the merits thereof.

THE DEFENDANT TAMARA SYTCH,

BY _______________________________________ Rob Serafinowicz (423695) The Law Offices of Rob Serafinowicz, LLC 52 Holmes Avenue Waterbury, CT 06702 Telephone Number: (203) 755-0267 Fax: (203) 528-4302 RS9907@gmail.com Her Attorney

ORDER The foregoing motion having been heard, it is hereby ORDERED: GRANTED / DENIED

THE COURT

BY__________________________, J.

CERTIFICATION This is to certify that service has been made upon the following counsel pursuant to the Connecticut Rules of Practice: Office of the States Attorney Geographic Area 22 121 Elm Street New Haven, CT 06510

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Rob Serafinowicz, Esquire