2404 Sourwood Drive

                                                                                                            Phoenix, NY  13135

                                                                                                            4 October, 1995

 

Murtari v. Murtari

Index No: 95M705

RJI No: 33-95-3267

 
The Honorable Charles T. Major

Supreme Court Justice

Onondaga County Courthouse, Room 401

401 Montgomery Street

Syracuse, NY  13202

 

Dear Judge Major:

 

I have taken the time to prepare a care plan for our son, Domenic, in preparation for discussion of my motion for temporary joint physical custody.  I hope it can be something that will be good for our son (to avoid a lot of back and forth travel) and both of us. Adrianne is living in apartments south of the S.U. Campus; our house is in Phoenix -- over a half hour drive.  I would like to avoid us making this trip with our son everyday -- especially as the weather gets colder. The plan would be:

 

·        We alternate weekends with Domenic, from 5 PM Friday to 5 PM Sunday. 

·        From Monday at 8 AM to Wednesday at 1 PM (53 hrs) he is with his father.

·        From Wednesday at 1 PM to Friday at 5 PM (52 hrs) he is with his mother.  

·        The time from Sunday at 5 PM to Monday at 8PM would alternate depending on whose weekend it was. 

 

This would give Domenic some important stability; he would definitely be able to enjoy the neighborhood and children where we live.  I would also have liked to alternate the weekday schedule -- but with Adrianne working Monday-Thursday this might be the best fit? Adrianne is free to decide how she wants to handle care for Domenic Thursday morning. I would certainly be able to help.

 

To help my work schedule in my home office -- I have arranged for my mother to be here on the weekdays when I have Domenic.  We also have his regular sitter or my cousin (who has two small children and lives less than ten minutes away).  For my part, I want the order to clearly state that his mother is welcome for dinner or play at the home on any day.

 

My phone: 315-695-4422.

                                                                                                Respectfully yours,

 

 

                                                                                                John Murtari

CC:  Ms.  Maureen Walsh, Esq.     

CC:  Mr. Joseph Lupia, Esq.