SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF ONONDAGA

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AFFFIDAVIT FOR MODIFICATION OF ORDER

Index No. M-705-95

 
 


ADRIANNE MURTARI,

                        Plaintiff,             

                                               

      - against -                                    

     

 

JOHN MURTARI,

                        Defendant.

 

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State of New York       )

County of Onondaga      ) ss:

JOHN MURTARI, being duly sworn, deposes and states:

 

1.                I am the defendant in this action, and I make this affidavit in support of a decision requesting the modification of a previous order.

2.                Dr. Black was appointed, by agreement of both parties, to perform a psychological assessment, in an order dated Sep 19, 1995.

3.                I had my first interview with Dr. Black on September 23, 1995 and had some concerns regarding her questioning of me and her responses to the information I was providing.

4.                I felt that a recording would provide the best vehicle for keeping my answers unambiguous and available for peer review. I wrote this to Dr. Black in a letter dated Oct 26, 1995 (attached).

5.                In a phone conversation a few days later Dr. Black rejected taping on the basis of violating my confidentiality.  When I told her that was not a problem for me -- she told me she objected to being recorded and doubted any other psychologist would perform testing under such conditions. I asked her to please not proceed until I could examine the matter further. She expressed concern and irritation over the delay.

6.                After speaking with two other individuals I became satisfied that any sessions needed to be recorded.  Shortly thereafter I had another phone conversation with Dr. Black regarding the matter. This lasted 20-30 minutes and was “heated” at times. Dr. Black kept reminding me she was under compulsion of the Court to complete the testing and that I was blocking that process and could be labeled as uncooperative if my behavior continued. 

7.                In this conversation I again told Dr. Black I needed to speak with the other attorney in an attempt to resolve this and potentially have the intervention of the Court.  She did not want to wait.

8.                I called the New York State Psychological Association referral number and asked for a “divorce/custody assessment” referral.  I was given the name of a Dr. Lazarro, here in Syracuse.

9.                I spoke with Dr. Lazarro over the phone and he described his method for conducting these examinations:  He performs in-depth testing of the individual and has a separate Child Psychologist perform an evaluation of the parent/child relationship.  They prepare their findings independently and then meet to discuss the results.  He told me this technique was now being used in large metropolitan areas to ensure fairness by using “two sets of eyes”.  He told me recording of the sessions with both himself and the Child Psychologist’s would not be a problem.  I did not discuss any of the specifics of the matter with him.

10.            I was preparing a letter for Dr. Black when I received her letter dated Nov 2, 1995 (attached), in which she offers to have the final session recorded.   Given the events which had transpired I could not accept this and sent her a letter dated Nov 5, 1995 (attached) -- in this letter I did tell her another Psychologist would allow recording of sessions.

11.            I was also concerned that she stated she had completed her personal interviews of me -- and we just needed to review her findings.  I am trying to understand what actual testing was conducted.  In our first session we only discussed the marriage and my feelings about what had happened.  There were no questions about my personal background or habits or my relationships with others.

12.            My wife, Adrianne, was admitted to Crouse Irving Hospital for a period of three days 26-28 September, following severe headaches, body ache, and vomiting.  She was diagnosed with Viral Meningitis, which could have been brought on by a weakening of the immune system caused by psychological stress.  This underlines the need for a comprehensive and in-depth psychological evaluation.

13.            Dr. Blacks letter of Nov 7, 1995, is misleading.  She omits  the objections she had voiced in two phone conversations regarding the recording of her questions (which truly seemed to be the motivation for her concern).

 

                                                _________________________

                                                JOHN MURTARI

Sworn to before me this

13th day of November, 1995.

______________________________

Notary Public