• Embed Doc
  • Copy Link
  • Readcast
  • Collections
  • CommentGo Back
Download
 
;I
I'
I
11
k~
LEVI:"
&
MARGOLIN
{SPACE
BELOW FOa
F1U~G
STA~lP
ONL':
2,1
I!
311
411
5
Attorn.y.-Ior
Petitioner.
DEBORAH
A.S.
VAN
SICKLE
6
7
81
91
10\
I
111
I
121
13
SUPERIOR
COURT
OFTHE
STATE
OF
CALIFORNIA
FOR
THE
COUNTY
OF
LOS
ANGELES
In
RQ
the
Marriage
of:
)
)
CASE NO.
BD003554
Petitioner:
DEBORAH
A.S.
VAN
SICKLE)
and
DECLARATION
OF
DEBORAH
A.S.
VAN
SIC:
14
Respondent:
BARRY
L.
VAN
SICKLE
)))
)
IN
SUPPORT
OF
REQUES'FOR
TEMPORARY
AND
PERMANENT
RESTRAININI
ORDERS,
SUPPORT,
ATTORNEYS'
FEES
AND
COST
1516
17
-----------------------------)
18
I,
Deborah
A.S.
Van
Sickle, declare
and
state
and,
if
called
101
as
a
witness
would
competently
testify
to
the
following
facts
20
1
1
within
my
personal
knowledge.
211
2211
1.
I
am
the
Petitioner
in
this
action.
I
currently reside
!
23.
with
my
13
month
old
daughter,
Heather,
at
1617
steinhart
Ave.,
24[,
RedondO
Beach,
California.
On
March
25,
1990,
the
Respondent
I
251
(hereinafter referred
to
as
"Barry")
left
the
family
home
after
2al
a
physical
attack
upon
me,
which
necessitated calling
the
police
I .
27
1,
for
which
a
report
was
filed
at
the
Redondo
Beach
police.
A
true
28
1
and
correct
copy
of
Which
is
attached hereto
as Exhibit
"1".
vonalcklo\docl.dvo
1
 
z
1
Barry
has
not
resided
at
the
former
family
home
since.
Barry,
I
2!
believe,
has
spent
two
nights
since
March
25,1990,
at
the
family
31
home
sleeping in
a
downstairs
bedroom.
41
2.
I
request
the
Court
issue
a
"Stay
Away
Order"
requiring
5
Barry
fo
stay
at
least
25
yards
away
from
my
home
except
for
6
purposes
of
picking
up
our
daughter
for
visitation.
3.
During
the
course of our
4
year
marriage,
Barry
has
8
physically assaulted
me
at
least
11
times.
As a
result
of
the
9\,
last
incident
on
March
25, 1990,
I
have
currently
been
in
101!
counselling
one
day
a week
at
1736
Family
Crisis
Center,
the
II
IIi
South
Bay
Center
for
Battered
Women.
Barry
is
39
years
of
age
I
12
this
July.
He
is
approximately
6
foot
1
inch
in
height
and
13
1
141
151
161
:
weighs between
230
and
240
pounds.
He
is
a
former
college
football
player.
I
am
approximately
5
foot
6
inches
and
between
118
and
122
pounds.
After the
most
recent
physical
assault
on
me
in
March
of
1990,
Barry agreed
to
leave
the
family
home. I
fiied
17:
for
divorce
in
June
of
1990.
Barry's
agreement
not
to
enter
the
18\:
family
home
except
by
agreement
or for
visitation
and
to
allow
me
191
1
to
use
it
as
my
residence
was
confirmed
in
writing
by
his
201
counsel.
Attached
hereto as
Exhibit
"2"
is
a
true
and
correct
21i,
copy
of
his
lawyer's
letter
to
my
lawyer
with
this
assurance.
2211
4.
On
March
25,
1990,
after
an
approximately
20
minute
23
11
argumentwhich
commenced
in
our
bedroom,
and
continued
down
intc
241'
the
garage,
Barry
pushed
me
back
into the front
entryway
of
om
25
1
home.
Barry
had
become
increasingly
visibly
angry.
I hac
261
previously
put
my
daughter
down
on
the
floor
upstairs
for
feal
27\
that
Ba~ry
would
physically
assault
me
which
couldcause
injur)
281
to
our
daughter. In
September
of
1989,
he
attacked
me
while
1
i
vansieUe\decl.dvs
2
 
z
1
was
holding
my
daughter.
on
March
25,
1990,
Barry grabbed
me
2
around
my
thighs,
lifted
me
approximately
three feet
up
into the
3
air
and
slammed
me
down
against
a
tile
floor
which
was
covered
by
4
an
area
rug.
I
struck
my
head
and
was
dazed.
I
got
up
and
ran
to
a
tBiephone
to
call
"911".
5
)
Barry
ran
after
me
and
pulled
the
6
telephone
out.
I
then
ran
upstairs
to
the
bedroom
telephone.
I
1
71
was
able
to
call
"911"
and
complete
a
call
before
Barry
ripped
8
the
telephone
I
was
usingout
of the
wall.
He
then
ripped
the
9
I
kitchen
telephoneoutof
the
wall as
well.
The
police
did
!
arrive.
They
stayed
until
Barry
completed
packing
his
car.
10
I
~
11
Barry,
who
is
a
trial
lawyer,
had been
preparing
to
leave
for
an
•
.
.
0
....;
i
a
5
< "
a
!
~
;:
12-
out of
town
trial.
5.
After
this
incident,
Barry
agreed
that
we
should
live
J
CO!
_
5
~
~
13
~<ig~
.
,.
~
~
i
~
~
14.
separate
and
apart.
He
moved
out.
"l
z
!:
~
15
I
6.
From
March
25, 1990,
through
thecurrent
date,
I
have
>
!
~~
I
~
~~
16
I
ived
in
the
family
home
with our
daughter,
Heather.Barry
has
~
1711
resided primarily
with
his
unCle,
Joseph
Cummins,
the
Senior
18
:
Partner
in
the
firm
in
which
Barry
is
a
partner,
cummins
and
191
White.
20i
7.
Shortly
after
filing
my
Petition
for
Dissolution,
my
211
attorney
has
been
attempting
to
negotiate
temporary
restraining
22:
orders
in
this
matter.
During
this
process,
as
indicated
above,
23
Barry's
counsel
has
represented
that
Barry
would
make
no
effort
24
to
reoccupy
our
home.
I,
thus,
have
taken
no
action
to
keep
hi~
25'
away
from
my
home
pending
these
negotiations
or
to
request
its
26
e)Cclusi
va
use
and
occupancy,
hoping
to
save
these
costs
if
an
27
agreement
was
forthcoming.
28
8.
On
wednesday
evening,June
27,
1990,
I
made
vano'ckle\decl.dv.
3
of 00

Leave a Comment

You must be to leave a comment.
Submit
Characters: ...
You must be to leave a comment.
Submit
Characters: ...