Gildersleeve CPO Mod Request- Draft

Good morning your honor,

Mr. Gildersleeve is respectfully asking that the court modify his Crimiminal Protective Order.

(It is my client’s opinion that) the facts of the case do not support a CPO.

From the beginning of the case, on Decmeber 3rd 2021 there was a No Negative Contact Order
issued (Exhibit A, 12/03/2021 Docket)

Then on April 21st, 2022 the court changed the no negative contact order to a Criminal
Protective Order at the victim’s request. (Exhibit B, 04/21/2022 Docket)

The order was changed by the court soley at the victim’s request under the grounds that it could
be modified at a later date per Judge Belsky.

There have been no negative incidents since that date and in fact the restraining order filed by
the victim in family court was dismissed per stipulation. I have included a copy of the stipulation
for the court’s review (Exhibit C, Stipulation) and a current case status from the 3rd (Third) floor
family business office (Exhibit D, Get case status from courhouse)

Mr. Gildersleeve does not want to have any contact with the victim in this case, Ms. Taich, other
than to effectively co parent their 1 year old daughter, “Charlize.”

Mr. Gildersleeve has taken full responsibility for the actions in this case and although traumatic
and not to be taken lightly, this incident was caused by alcohol which Mr. Gildersleeve now
recognize and Mr. Gildersleeve has been taking steps to ensure that this sort of behavior never
happen again.

Mr. Gildersleeve immediately started counseling and therapy 2/25/21, has completed
- 53 individual therapy sessions for domestic violence treatment,
- anger management training,
- anxiety modification techniques,
- improving communication skills,
- parenting issues,
- and also completed a psychoeducational reprogramming and sensitivity training to
promote gender equalitarian behaviors.

I have also included letters from Dr. James Utic describing Mr. Gildersleeves treatment and
progress from his therapy sessions. (Exhibit E, Letters from mitigaiton packet)
The criminal protective order in this case is negatively affecting my client’s ability to spend more
time with his daughter and we are respectfully requesting that the CPO be removed or at least
modified back to a no negative contact order so he can spend more time with his daughter.