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Petitioner has been subjected to relentless, brutal and escalating physical, verbal and emotional abuse at the hands

of Respondent that have made the Petitioner fear for his physical and psychological safety and for their infant daughter, Alexandra, to the point where he does not feel safe in his own home. Respondent intentionally does this because of her refusal to work, refusal to agree to a divorce, the issue of custody in the divorce, to alienate the infant child and to obtain permanent residency as Respondent is an illegal alien. 1. Most recently on January 13th, 2013, Respondent was verbally abusive to Petitioner in front of their child saying that he will be leaving forever. 2. On January 11th, 2013 Respondent refused to cooperate in bringing the infant for her scheduled 18 month medical checkup despite having been reminded in an email the day before. 3. On many occasions including in January 2013, Respondent has ran out of food and supplies for the infant child and an analysis of her spending reveals the majority of support money is going for her own personal use on Ebay purchases rather than on food, toys, books and clothing. 4. On December 15th, 2012. Respondent hit Petitioner hard on the top of his head while feeding their infant daughter with her hand and grabbed his cell phone during the altercation. The phone was retrieved and police were called and a police report was filed. 5. On December 2nd, 2012 Respondent shoved Petitioner with force while he was holding their infant child and falsely accused Petitioner of driving while under the influence of drugs with the infant child in the backseat. A police report was filed. 6. On November 24th, 2012 Respondent slapped Petitioner hard in the head while Petitioner was driving with their infant child in the back seat for no reason. A police report was filed. 7. On Thanksgiving, November 22nd, 2012 Petitioner was preparing to take their infant child out to a friends house for Thanksgiving. As Petitioner carried the child, Respondent grabbed Petitioners jacket forcefully, he pulled away and Respondent forcefully kicked Petitioner in the rear right upper part of his leg. A police report was filed. 8. On October 28th, 2012, late at night, Respondent refused to allow Petitioner to feed their hungry infant child and grabbed the infant away from Petitioner. Petitioner insisted on feeding her and she calmed down. A police report was filed. 9. On October 26, 2012. Petitioner was trying to take their infant child to a music class Respondent following Petitioner in public, and yelled obscenities in front of their infant child and for neighbors to hear. Respondent blocked Petitioner and slammed his body twice into the car, once as he held their infant child and caused his neck and side to be in pain. Respondent was verbally abusive and blocked Respondents vision while driving by waving her middle finger in front of his eyes. A police report was filed and Petitioner saw a doctor. 10. On several occasions, including on October 26, Respondent, who has a sexually transmitted disease, made unwanted sexual advances towards Petitioner and, upon his refusal, made unwanted physical contact on the body of Petitioner grabbing Respondents genitals. Petitioner often argued with the Respondent who met men in cars while dressed provocatively and arranged meetings on the internet for sexual encounters claiming that this was a good way to get a job. Yet Respondent irrationally blames Petitioner for transmitting a disease he does not have and falsely claims that Petitioner has a girlfriend and another wife.

11. In July and other times, Respondent over the objection of Petitioner has taken the infant to the home of people who, upon information and belief, are swingers and invited these people to visit her alone in the marital residence and bizarrely blames Petitioner for her choice of these friends. Petitioner has asked Respondent to become active in a local church, charity or parental center to make different friends and she refused. Respondent has refused to cooperate with a baptism of the child against the wishes of Petitioner and against the best interests of the child. 12. On July 18, 2012 Respondent blocked the home security camera and the system is later disabled for no legitimate reason endangering the occupants including the infant child. 13. On July 6, 2012 Respondent grabbed food from Petitioner while feeding their infant child and made him fall on back for no legitimate reason. 14. On July 4th, 2012, Respondent, for no reason, rammed Petitioners car 4 times with a shopping cart causing damage to Petitioners vehicle. This was on their childs first birthday. Later that day Respondent grabbed money from petitioner that was given as a gift to the infant daughter. 15. June 30, 2012 Respondent blocked Petitioner from leaving house with infant daughter, and threatened to call police for no legitimate reason. 16. On June 24, 2012 Respondent grabbed a book from Petitioner while reading to infant daughter for no legitimate reason 17. On June 23, 2012 Respondent grabbed food from Petitioner while feeding infant daughter for no legitimate reason. 18. Respondent forces the infant to watch television for several hours a day instead of reading and interacting with her and participate in social activities. Respondent spends her entire day on the internet and stalks the Petitioner on line, and she has left the infant in the crib in dirty diapers. Respondent refuses to use the high chair to feed the infant. Respondent infrequently bathes her and makes sexual abuse accusations when Petitioner does so. The infant child is behind in social development of other children as a result of the physical, social and mental damage being inflicted by Respondents neglect. 19. On April 21, 2012, Petitioner told Respondent that he wanted an amicable divorce because of irreconcilable differences. Respondent told other people she did not want a divorce. On April 28, 2012 Respondent made false child abuse/neglect allegations against Petitioner. The CPS investigation concluded that these allegations were unfounded. Petitioner filed for divorce on May 18th, 2012. Respondent threatened to make him lose his job, house, law license and friends. Respondent sent out false and defamatory emails and messages to Petitioners friends, family, coworkers and colleagues. Respondent threatened to defame Petitioner in the community and did so. Respondent committed perjury in each allegation in her reply to Petitioners divorce complaint including a claim that Petitioner did not buy a car seat for the infant which would be illegal. Respondent frequently threatens to escalate and do worse things and does so. In May, Petitioner had to undergo gallbladder surgery which was Doctor said was caused by this stress, sees a psychiatrist and is often forced to stay in hotels, with friends or in his car to avoid further violence. Respondent harasses and alarms Petitioner on a regular basis and serves no legitimate purpose and is intended to create fear and, in fact, has caused fear for Petitioner and his daughter. Petitioner respectfully pleads to this court for the relief requested. Thank you.

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