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Filing# 52663937 E-Filed 02/17/2017 03:11:29 PM

IN THE CIRCUIT COURT OF THE 11TH


JUDICIAL CIRCUIT IN AND FOR MIAMI­
DADE COUNTY, FLORIDA

FAMILY DIVISION

CASE NO.:
*
IN RE:

AARON JASON ROLLINS, *-:

'*
Petitioner-Father,

and *

RANI CLARA SANDERSON, *

Respondent-Mother.
*

VERIFIED PETITION FOR


DETERMINATION OF PATERNITY AND RELATED RELIEF

For his petition, captioned above, the Petitioner states:

-1, ACTION FOR DETERMINATION OF PATERNITY: This is an action

for determination of paternity, pursuant to Chapter 742, Florida Statutes. The

Respondent is pregnant, and claims that the Petitioner is the Father. The Petitioner is

desirous of determining whether he is the biological father, and requests the Court to

order DNA testing.

2. SUBJECT MATTER JURISO_ICTION: The Court has jurisdiction over

the parties and subject matter of this action, because:

2.1 The Petitioner is a permanent resident of Florida.

2.2 The child was conceived in Florida.

KUTNER AND ASSOCIATES


FAMILY LA"W ;-\.TTORNEYS
JJTH FLOOR, COURTHOUSE TOWEl't, 44 WEST FLAGLER -l,TREET, MIAMJ 1 FLORIDA 33130•180B • TELEPHONE (305) 377-9411
[Roi/Ins v. Sanderson]

3. PERSONAL JURISDICTION AND THE LONG ARM-STATUTE: The

Court has personal jurisdiction over the Respondent, because:

3.1 The parties engaged in sexual intercourse 1 in Florida, to which the

child may have been conceived. Section 48.193(1)(a)(8), Florida Statutes,

specifically provides:

(1)(a) A person, whether or not a citizen or resident of this


state, who personally or through an agent does any of the
acts enumerated in this subjection thereby submits himself
or herself and, if he or she is a natural person, his or her
personal representative to the jurisdiction of the courts of this
state for any cause of action arising from any of the following
acts:
***
8. With respect to a proceeding for paternity, engaging In
the act of sexual intercourse within this state with
respect to which a child may have been conceived.
(Emphasis added).

3.2 If it is determined, through DNA testing, that the Petitioner is the

biological father of the child, this Court has personal jurisdiction over both parties,

pursuant to Section 88.2011, Florida Statutes, to establish appropriate support for the

child in accordance with Florida law:

(1) In a proceeding to establish ... a support order or to


determine parentage of a child, a tribunal of this state may
exercise personal jurisdiction over a nonresident individual
or the individual ... if: (f) The individual engaged in sexual
intercourse in this state and the child may have been
conceived by that act of intercourse.

1 The parties had sexual intercourse in the State of Florida, several times during the month
of June, 2016.

-2-

KUTNER AND .ASSOCIATES


l'AMILY LAW ATTORN:EYS
11TH FLOOR, COURTHOUSE TOWER, 44 WEST FLAGLER STREE:T, MIAMI, F"LORIDA 33130•1B08 • TELE:PHONE (30S) 377•9411
[Rollins v. Sanderson]

4. RESIDENCY: The Petitioner has been a resident of the State of

Florida for more than six months prior to the filing of this petition. Upon information and

belief, the Respondent has been living in California for approximately one month. The

Petitioner is unaware of the Respondent's domicile, as she frequently moves from state

to state. Upon information and belief, the Respondent keeps all of her valuable

belongings in a storage facility in Nevada, so she is not tied to a certain location. Her

cellular phone has a Hawaii area code.

5. UNBORN CHILD: The child is unborn.

6. IMPROPER PATERNITY ACTION PENDING IN CALIFORNIA: On

February 9, 2017, the Respondent filed a Petition to Establish Parental Relationship in

the Superior Court of California, County of Los Angeles, Case No. BF058574 (Exhibit

"1"). Judge Carl H. Moor is presiding. The Petitioner was served the same day. The

California action is wholly improper. This matter should be adjudicated in Florida,

because:

6.1 Aside from the Respondent's forum shopping, there is absolutely

no connection to California.

6.2 The child is unborn.

6.3 For almost the entirety of her pregnancy, the Respondent was

residing in the states of Hawaii and Colorado.

6.4 Upon information and belief, the Respondent has no family, no

job, and no close ties to California.

-3-

KUTNER AND ASSOCIATES


FAMILY LA"W ATTORNEYS
I fTff FLOOR, COUP!THOUSE TOWER, 44 WE:ST FLAGLER STREET, MIAMI, P'LORIDA 3313O· IBOS • TELE:'3HONE (3OS) 377 •9411
[Rollins v. Sanderson]

6.5 The Petitioner is domiciled in Florida. He has been a permanent

resident of Florida for close to three years.

6.6 The parties had intercourse in Florida in June, 2017, nine months

prior to the expected due date of the child in March, 2017.

6.7 Key witnesses with knowledge of the parties' sexual activity, in

June, 2016, reside in Miami, Florida.

6.8 During the preliminary stages of her pregnancy, the parties

agreed that the Respondent would obtain an abortion. She demanded2 the sum of

$10,000, which the Petitioner paid. The Respondent's demands were negotiated by a

Florida attorney. The Respondent returned $5,000 to the Petitioner.

7. ATTORNEYS' FEES, SUIT MONIES, AND COSTS: The Petitioner

has obligated himself to pay a reasonable fee to the undersigned firm for its services in

connection with these proceedings. In the event that the Respondent takes

unreasonable positions and/or causes unnecessary litigation or attorneys' fees to be

incurred, the Respondent should be responsible for the Petitioner's reasonable

attorneys' fees and costs, pursuant to Section 61.16, Florida Statutes, and the factors

set forth in Rosen v. Rosen, 696 So. 2d 697 (Fla. 1997) and its progeny.

WHEREFORE, it is requested that this Court grant relief consistent with

this petition.

l Reference is made to pages 2 and 3, of the declaration in the California action.

-4-

KU']NERAND ASSOC:IA'.11�'.S
FA.l\,1ILY LAVv ATTORNEYS
11TH FLOOR, COURTHOUSE TOWER, 44 WEST FLAGLER STREET, p,IIAMI, J'LORJDA 33130-ISOB • TELl!:PHONE (305) 377-9411
[Rollins v. Sanderson]

STATE OF FLORIDA )
>
SS:
COUNTY OF MIAMI-DADE )

BEFORE ME, the undersigned authority, personally appeared AARON

JASON ROLLINS, who is personally known to me and who, after being duly sworn,

deposes and states that the contents of the foregoing Verified Petition for Determination

of Paternity and Related Relief are true and correct. /""' ../ t
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AARON, JASON ROLLINS

WITNESS my hand and official seal at Miami, Miami-Dade County, Florida

this 17th day of February, 2017.


MAURICE JAV KUTNER
� Notdli)' Pidlllc • Stat& of Ffortda Notary Pub''
•; CCfflmlHIDii # ff 195291 ·
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KUTNER AND ASSOCIATES
11th Floor - Courthouse Tower
44 West Flagler Street
Miami, Florida 33130-1808
Phone: {305) 377-9411
Fax: (305) 377-4758

By7'C_
MAURICE � KvtNER
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Florida Bar No.: 44775
MJKutner@KutnerFamily�com

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-5-

KUTNER AND AsSOCIATES


FAMILY Li\..W ATTORNEYS
11™ i"LOOR, COURTHOUSE TOWER, 44 WEST FLAGLER STREET, MIAMI, FLORIDA 33130• 1801!1 • TELEPHONE (305) 377-9411
FL.200 -
ATTORNEY OR f!Af<TY WITHOUT ATTORNEY (Name, 8/ma IJar numoor, and addross): FOR COURT USE OM. Y '

J'lark Vincent Kaplan (58836)


Danielle E. Grabois {283702)
Law Offices of Schuchman & Kaplan
1875 Century Park East, 880
Los Angeles, CA 90067
TELEPHONE NO. (Opt;ooai): 31 0 - 4 7 3 -0 7 9 8 FAX NO, (Op/Jona/): 310-4 7 3-Q 62 5 CONEi.BJ!,�QCJeY
E-MAIL ADDRESS (Op/Iona/}: 0 l:!U Cl ••
Su�rlor Court c,'t Ctitilfornla
ATTORNEYP'DRtM,meJ: Rani Clara Sanderson a.lnty Cf Lo.e Ang�ea
SUPERIOR COURT OF CAUFORNrA, COUNTY OF Los .P>...ngeles
STRi.ET ADDRESS: 111 N . Hill Street �· fII rJ:QJ01t
MAILING ADDRESS: SAME AS ABOVE
crrvANoz1PcooE: Los An9eles 90012
Stanley Mask SI�rri A. 0Arttr, E:XfJCUfl\fff Ottl0if/01erk
_ By: Peter Ontiveros, o�
eRANcHNAME:
PETmONER Rani Clara Sanderson
RESPONDENT: Aaron Rollins

Fosa5 ,A""'
PETITION TO ESTABLISH PARENTAL RELATIONSHIP CASENUM1J
[iJ Child Support W
Child Custody
0 Visitation W
Other (specifvl: Prenatal Exoenses

1. Petitioner is
a. [xJ the mother.
D
�� i� ��jned to Judg�&...,,i .. J21l·

b. the father.
c. D the child or the child's personal representative (specify �,;:,f €.lppointment):
d. D other (specify):
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2. The children are


a. Child's name �c,f_b_ trt_h Age Sex

b. W a child who is not yet born.


3. The court has jurisdiction over the respondent because the respondent
a. W
resides in this state.
b. [iJ had sexual intercourse in this state, which resulted In conception of the children listed in item 2.
c. D
other (specffyJ:

4. The action is brought in this county because (you must check one or mon3to file in this county):
a.
[iJ the child resides or is found in the county.
b. D
a parent is deceased and proceedings for administration of the estate have been or could be started in this county.
5. Petitioner claims (check all that apply):
a. D
respondent is the child's mother.
b. [i] respondent is the child's father.
c. D
parentage has been established by Voluntary Declaration of Paternity (attach copy).
d. [iJ respondent who is child's parent has failed to support the child.
e. [i] (name):Rani Clara Sanderson has furnished or is furnishing the following reasonable expenses
of pregnancy and birth for which the respondent as parent of the child is obligated:
Amount Payable to For (specify):
Petitioner TBD

f.
L.
...J public assistance is being provided to the child. EJGUSJT �
g. [x7 other (specify): See the attached declaration of Rani Clara Sanderson.
6. A completed Declaration Under Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA)) (form FL-105) is attached.
Pag_e1 of2

sOk
Form Approved tor Optional Use PETITION TO ESTABLISH PARENTAL RELATIONSHIP Family Code. § 7630
JL<licial Cot.llCil of California
FL-200 [Rev. J¥wa(y 1, 2003) (Unlfonn Parentage)
�.PJus
PETITIONER: Rani Clara Sanderson C!!'i,$E N�IM�!,:R:
r-
RESPONDENT: Aaron Rollins
Petitioner requests the court to m,ike the determinations indicated below..
7. PARENT-CHILD RELATIONSHIP
a. [iJ Respondent b. W
Petitioner
c. D Other (specify): is the parent of the children listed in item 2.

8. CHILD CUSTODY AND VISITATION Petitioner Res ent Joint Other


c=J
a. Legal custody of children to CJ D
b. Physical custody of children to
c. Visitation of children:
w CJ D D
(1) ONone
(2) [i] Reasonable visitation.
(3) D
Petitioner [i] Respondent should have the right to visit the children as follows:
See the attached declaration of Rani Clara Sanderson.

(4) D Visitation wit, the following restrictions (specify):

d. Facts in support of the requested custody and visitation orders are (specify):
w Contained in the attached declaration.
e. DI request mediation to work out a parenting plan.

9. REASONABLE EXPENSES OF PREGNANCY AND BIRTH:


Reasonable expenses of pregnancy Petitioner Re " ent Joint
j� i
���-� D D
as follows: $6,749 & TBD*; See the attached declaration of Rani Clara Sanderson.

*The full amount has not yet been determined and will not be until the birth of the child.
10. FEES AND COSTS OF LITIGATION Petitioner Respondent Joint
a. Attorney fees to be paid by D D
b. Expert fees, guardian ad fitem fees, and other costs
of the action or pretrial proceedings to be paid by r-""J [iJ C�i
11. NAME CHANGE
DChildren's names be changed, according to Family Code section 7638, as follows (specify):

12. CHILD SUPPORT


The court may make orders for support of the children and issue an earnings assignment without further notice to either party.

13. I have read the restraining order on the back of the Summons (FL-210) and I understand it applies to me when this Petition is filed.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: February 9 , 2 0 l 7 ,,..,.-
,,..,. ----,

.Rfil!i. �lara Sanderson ,.,._..-- J-.--_::;;


�- ,--:;;
(TYPE OR PRllr NAME)

A blank Response to Petition to Establish Parental Relationship (form FL-220) must be served on the Respondent with this Petition .

NOTICE: If you have a child from this relationship, the court is required to order child support based upon the income of
both parents. Support normally continues until the child is 18. You should supply the court with infonnation about your
finances. Otherwise, the child support order will be based upon information supplled by the other parent.
Any party required to pay child support must pay interest on overdue amounts at the "legal" rate, which Is currently
10 percent.
FL-200 (P.av. JanuaP/ 1, :?.003] PETITION TO ESTABLISH PARENTAL RELATIONSHIP Pag,, 2ol2

(Unifonn Parentage)
1
2 DECLARATION Oli� RANI CLARA SANDERSON

3 1. I, Ra:J.i Clara Sanderson, submit this Declaration in support of my Petition for

4 Paternity Action. All of the facts stated below are true and correct and are of my own personal
1
5 knowledge, and I could and would competently testify under oath as to each of the matters herein
6
stated if called as a witness.
7
8 INTRODUCTION
9 2. I met Respondent, Aaron Rollins, in 2007 through mutual friends. We dated in 2008
10
"and again,. and most recently, we began dating in April of 2016.
11
3. Respondent and I went on a trip on June 21, 2016 when we decided to take our

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12
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� ,., relationship to the next level and become romantic. On this vacation, he told me I'd "make such a
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141 good mom," and discussed how I should move in with him and he'd build me a large closet. He
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0 :!I "' 0. 15 told me he was building a nanny's quarters because ideally he wanted kids within a year or so
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16 because he was getting 9ld and needed to settle down. He told me specifically he "needs to settle
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down now, [he's] 43 .... [he] needs stability." When we returned back to California on June 28th,
1s II
.. Respondent and I had unprotected sex.
19
4. As we were not taking precautions against getting pregnant, and Respondent is a
20
physician, I asked him to prescribe me birth control; he did. (It is my belief and understanding that
21
I
22 birth control does not act immediately, but takes about two (2) weeks to get into your system.) I
23 began taking the pill on June 28, 2016, when we returned to California, and had unprotected sex
1
24 during that time.
25
5. ! was to go on a cross country horseback riding trip, which caused a strain in our
26
relationship. Once I found out I was pregnant, the trip was cancelled.
27
6. According to my doctor, research of baby blogs, and reviewing my calendar, we
28 1
DECLARATION
11 conceived our baby on or around June 29 or 30th.
1
2 7. I missed my menstrual period, so I took an over the counter pregnancy test on July 27,

3 112016, while Respondent was away on a business trip. It crune back positive. I went immediately to
4 the doctor the next day to confirm the test, with a more accurate blood test. The blood test results
5 came back on July 30th confirming I was pregnant.
6
8. As I had not had intercourse with anyone else, I informed Respondent immediately by
7
phone upon finding out I was pregnant, as he was out of the country. His response was "oh ... this
8
is not good timing" and "we don't have the foundation for this." He wanted to date me for six (6)
9
1o months before making the decision to go forward with this pregnancy (although we have known
11 � each other for eight (8) years). He also stated ''It's great to know you can get pregnant this easily,

12 II so if we want to try to have one in the future." He wanted me to have an abortion, even though he
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� .:::: ..,... l3 "knew my stance on that.


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9. I have not heard from Respondent in about seven (7) months. On November 29, 2016, I
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gi c,;�� .. emailed him to 1ry to open communication. Attached hereto as Exhibit "A" is a 1rue and correct
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17 n copy of my email to him. On Christmas eve I sent him. another email, this time with a sonogram
18 II picture attached, informing him we are having a daughter and asked again to have open
19 communication. See Exhibit "B" for a true and correct copy of this email. I never received a
1
20 reply to either emai .
l
21
PRENATAL EXPENSES
22
10. Respondent wanted me to have an abortion, even though I had discussed with
23
him before I was pregnant that if I got pregnant, at my age, I would not have an abortion. However,
24

25 I considered it for him. Respondent gifted me $10,000 to pay for the abortion and related costs. O
26 had no insurance the first twenty weeks of my pregnancy).
27 11. I received the funds via cash through his boat captain, "Ron." Respondent sent his
28 2
DECLARA'UON
full time yacht boat captain to Califomi� from Florida, to give me this money. ·Ron tried to.take.me
1
2 to the doctor for the abortion, not wanting my friends to be involved, and I believe to confirm I would
3 go through with the abortion. He told me "you don't need friends; you have me." I felt he was
4 I pressuring me.
5 12. However, after hearing the baby's heartbeat, I could not go through with the abortion.
6
13. I returned the remaining funds (that I did not spend on the pregnancy and
7
accommodations to obtain the abortion ($5,000)) to Respondent at dinner a few weeks later. He
8
did not want to accept the money, but in the end he did, as I left it on the table and walked away.
9
10 Respondent has not covered any other costs of this pregnancy.
11 I 14. I temporarily moved to Colorado while pregnant (and after Respondent wanted me

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12 to have an abortion), as I had a low rental place to stay and a place across the street to store my

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horse (that I had planned on riding across the country before I found out I was pregnant).
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� i {� I 15. On August 11, 2016 Respondent informed me that he did not want to talk to me
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� anymore and I should speak to his lawyer. See Exhibit "C" for a true and correct copy of the email
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j 17 � from Respondent stating same.
18 16. My prenata1 expenses from the time I found out I was pregnant to present include, but

1911 are not limited to:


20 a. My General Practioner, Dr. Ron Benbassat's office visit for a blood test to
21
determine if I were pregnant: payment of approximately $45 (he gave me a deal
22
as I had limited funds)
23
b. OBGYN, Dr. Rebecca Brown for an abortion consultation and ultra sound,
24
25 payment of approximately $500

26 c. $200 to fly out a friend who could help care for me during my morning sickness,

27 and to drive me to Colorado


28
DECLARATION
• :d: '. Paying-for an AirBnB and other accommodations from July 2016 witil: ··:,_ :L: -.,,.
1
2 September for approximately $800

3 e. Rent for the first two months in Colorado of approximately $700 a month for 2
4 months, totaling $1,400
5
f Rent for the third month I stayed in Colorado; �pproxim�t�ly.$690
6
g. Genetic Testing by Sequenom for approximately $695 (testing was done due to
7
my age and taking birth control pills when I did not know I was pregnant, plus
8
9 the unknown of Respondent's backgrowid, as I was not in contact with him)

10 h. Medicines for nausea; approximately $150


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1
11 i. Prenatal vitamins; approximately $200
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12 � j. Groceries from August to current were approximately $1,400
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k. Airfare to fly home so I could save money and have my parent's help me with
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:i:: i:'t:! baby expenses, as well as be seen by doctors under the Hawaiian health care
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el_.,,u ,! system, which saw me for minimal costs; approximately $500
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17 I. Gas driving from Colorado to Los Angeles; approximately $250.

18 m. Totaling $6,740.

19 17. Future expenses will include, but are not limited to the hospital stay and delivery costs.
20 I intend to live in California, and give birth to the baby in California.
21
RESPONDENTllASlllE �'UN])S 'I'O CONTRlBUTi� FOR TJlE.PRENATALEXPENSES
22
18. Respondent is a plastic surgeon to the stars. See Exhibit "D" for a true and correct copy
23
of Respondent's website that describes him as
24 1
25 "Dr. Aaron Rollins is the liposuction doctor to the stars, as well as,

26 the founder of Elite Body Sculpture in Beverly Hills, Houston,


27 Sacramento and New York. Dr. Rollins is considered a specialist in
28 4
DECLARATION
body ·sculpting and has performed thousands of laser liposuction
1
2 procedures. Due to this, he has been featt.rred on numerous media

3 outlets including Good Morning America, Extra, Good Day LA


4 as well as being featured in Europe on RTL and Nova TV."
5
19. Further, while we were together, Respondent stated that his regular and
6
customary charge for each hour and a half procedure is $14,000 and he would perform multiple
7
. procedures per day.
8.
20. Respondent told me that he routinely would make approximately $100,000 in cash for a
9
1 o n few days of work performing liposuctions.
11 21. Respondent has stated to me that he earns over a million dollars a month;
12 n And he had the expectation of earning over $2 million a month in the near future.
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� C\ QI:) 22. Respondent owns multiple locations of his clinic. On our trip in June, he was on the
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0:; ;f� phone with his business manager, and I heard him discuss the possibility of selling his
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companv/invention
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< 17 23. When we traveled; it was first class. On our vacation, we stayed on his private yacht.

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1s With all his money, he has refused to help me v-n.th any prenatal expenses.
19 I DON.PT HAVE lJIB..PlINDS
20 24. I was uninsmed during the first twenty (20) weeks ofmy pregnancy. I thereafter
21 •
obtained Medi-Cal. This covered emergency situations only, which meant for regular checkups I
22
had to pay out of pocket.
23
25. I am currently living off loans to cover my day to day expenses. I have $3,000 left in
24
25 I my bank account as of February 6, 2017, but am in extreme credit card debt (owing more than
26 11 $3,000).
27 26. I used to work in my career repairing vehicles as a restoration specialist. However, the
28
DECLARATION
chemicals it entails working with has stopped.me. from working there, and I have not had a job or
1
I
2 made an incom�: since June of 2016. (I took off for the vacation and to prepare for my trip in June
3 II and could not return because I was pregnant).
4 27. I cannot afford to maintain payments for our un-bom baby such as doctor visits,
5 11 vitamins, the hospital for when I go into labor and other related expenses.
6
CUSTODY/V'ISITATION
7
28. Our baby is due in March 18, 2017. I plan to breastfeed. Further, Respondent has not
8
spoken to me since mid-August, 2016. Therefore, I am respectfully requesting full physical and
9
1o1 legal custody so I can care for our baby without the difficulty of trying to communicate with
11 I Respondent who refuses to communicate with me.

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12. 29. I am requesting Respondent have reasonable visitation, but no overnights, with a step up
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pIan fior future vts1tat1on.
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ATTORNEY'S FEES ANDCOSTS
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t,l UM 30. I cannot afford the same caliber attorney as Respondent can (as can be seen above).
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16
17 11 I am entitled to the same representation as he is; and had to get a loan to be able to retain counsel.
18 I Therefore, as Respondent can afford it; I am entitled to the same type of representation, and it was
19 I necessary to hire counsel to get help; I am respectfully requesting the Court have Respondent pay
20 for my attorney's fees and costs.
21
I II
22
23
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25 II
26 II
27 //

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DECLARATION
1
2 CONCLUSION

:i
3 31. Therefore, as Respondent has failed to pay for prenatal expenses, and he has the

means to do so, and I do not, I respectful! y request the Court order Respondent to pay for such

expenses, as well as attorney's fees and costs.


6
7 I declare under penalty of perjury pursuant to the laws of the State of California, that the

8 I foregoing is true and correct.


9
10
Executed on this ? day of February, 2017 at Los Angeles, California
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2ll/2017 Sanderson -Rollins Fwd: Hello

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Begin forwarded message:

From: Rani <raniriot@gmail.com>


Date: November 29, 2016 at 16:06:46 PST
To: Aaron Rollins <aaroniro!lins@yahoo.cQm >
Subject Hello

Seasons Greetings,

It's been almost 4 months. -I just wanted to send a note saying I am open to communicating
with you.

... Rani Sanderson �-

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217!2017 Sanderson- Rollins Fwd: Merry Christmas

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Begin forwarded message:

From: Rani <raniriot@gmail.com>


Date: December 24, 2016 at 17:59:57 PST
To: Aaron Rollins <:aaronjrollins@yahoo.com>
Subject Meny Christmas

This is our daughter. You may not consider her a gift, but I do. I just thought maybe if you
were with your family on Xmas you might be struck by the mood to let them know. I would
like that.

She's vivacious with every great sign of health imaginable. I have done all scans and tests ,
genetic and otherwise, to make sure she is doing the best that she can.

https://Ol.ilook.officacom/rmatrx�ection.as,lX 112
2!7!'2017 Sanderson- RolOns Fwd: Merry CITlstmas

- Rani S

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https://ootJook.office.com/owafprojection.asp:< 212
2lll2017 Sanderson Rollins Fwd: thread

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Begin forwarded message:

From: Aaron Rollins <aaroniroUins@yahoo.com>


Date: August 11, 2016 at 18:56:10 PDT
To: Rani <raniriot@gmajl.com>

Dear Rani,

It is clear to me that the two of us have different perspectives on this.situation. I recognize


that the situation you are ih is very difficult for you and that you are struggling 'to determine
what the right decision is for you. My confusion and disappointment is in_ the fact that I
believed that we had come to an agreement to terminate the pregnancy and that is clearly
why I arranged to give you the funds to do so. To me, it now feels like a betrayal of trust
which I struggle with. Although I wish that I could make this decision for you and resolve the
situation, it is not my place or right to do so and therefore I believe that the best thing that 1
can do for both of us is to back off a·nd allow you the space to determine what is best for
you.

I also believe I have an obligation to reiterate to you that the two of us do not have a future
together. I think it is important that you understand this reality, whether or not it impacts
your decision to have the child. At this time, so that we can keep things civil between us, I
ask that you do not contact me directly again. If either you or Ray wish to convey any
information to me, please go through my attorney, Brett Berman. Brett's number is (310)
788-3837.

Best,
·• Aaron

Sent from my iPhone

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Beverly Hills, Sacramento & Now York


Dr. Aaron Rollins is the liposuction (/airbrush-laser-liposculpture/) doctor to the stars, as well as, the founder of Elite Body
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and has performed thousands of laser liposuction procedures. Due to this, he has been featured on numerous media
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He is a life-long art lover who studied sculpture and to fulfill his dream of combining art and science, he eventually attended medical school.

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211flD17 Aaron Rollins, MD I Elite Body Sculpture

Dr. Rollins went to medical sch9ol at the McG_i_l_l �niyersity Fa��lty of Medicine in Montreal, Canada
after completing his undergraduate studies at McGill University. -He-has received· many. awards for.his
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Distinction" honor at McGill University. He is affiliated-with the American College of Surgeons, American
Board of Laser Surgery, American Academy of Cosmetic Surgery and the American Society of
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"Patient comfort is my main focus," states Dr. Rollins "because we focus exclusively on laser liposuction
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Curriculum Vitae
AFFILIATIONS
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World Academy of Cosmetic Surgery
American College of Surgeons - Affiliate Member
UNDERGRADUATE
McGill University (Montreal, Canada}- BA Psychology
MEDICAL SCHOOL
McGill University Faculty of Medicine (Montreal, Canada) - Doctor of Medicine
RESIDENCY
UCSF (San Francisco, CA} - General Surgery Internship
University of Miami (Miami, FL) - General Surgery
HONORS AND AWARDS
I.D.E.A. Bronze Medal for medical inventions
McGill University "Great Distinction"
Golden Key Nationai Honor
Compassionate Doctor Certification

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NAME; ADDRESS, AND TELEl"NONE :NUMBER OF·ATTORI\IEY OR PARn':W!THOUT·ATI'Ol'lNE�: , fffAl"E BAR NUMBER.; •·• 1,,., Resen.'f.ld..fQf�f.JifS/aiJ,lp-
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Mark Vincent Kaplan
·uanielle E. Grabois (SBN 283702). .-·'--;-'--- -56-83-6--. __.._____ ,,__
Law Offices of Schuchman & Kaplan
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CONFORMED COPY
OOIGIIIIAL FILED
1875 Century Park East, 880 superior Court of Californie.
Los Angeles; CA 90067 County of L01!i Anpi&IGi!,
310-473-0798
ATTORNEY FOR (Name): Rani Clara Sander son FEB 0·9 2017
SUPERIOR COURT OF CALIFORNIA1 COUNTY OF LOS ANGELES .,...'"rn ft carter, Executive Officer/Cler�
couRTHOtJSEAOORESS; 111 N. Hill Stre
et By: Peter Offl:W@!'�, �9il�l1
Los Anqeles 90012
PETmONERIPLAlNTIFF; Rani Clara Sanderson

RESPONDENT/DEFENDANT: .Aaron Rollins

FAMILY LAW CASE COVER SHEET


BFosa;.,-,,,,
.
'-'A.'>L I\IUll'l�!:tt; �
CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO DISTRICT

Case Filing Instructions


This cover sheet is required so that the court can assign your case to the correct court district for filing and hearing. It
satisfies the requirement for a certificate authorizing filing in the district, as set forth in Los Angeles Superior Court
Rules 2(d) and 14.2. It must be completed and submitted to the court along with the original Complaint or Petition in
ALL Family cases filed in any district of the Los Angeles County Superior Court. This form is not required in
Abandonment & Emancipation cases, which are to be filed at Children's Court.

1. Fill in the requested information.


a) Enter address of Petitioner
ADDRESS: CITY: STATE 2JPCCl!lE

CONFIDENTIAL
b} Enter address of Respondent. DO NOT COMPLETE THIS ITEM IF THIS IS A MINOR'S CONTRACT CASE
ADDRESS: CITY; STATE ZIP CODE
!

MINOR CHILDREN INVOLVED? ["'i] YES HOW MANY? 1 (UNBORNl ONO


** DUE DATE IS MARCH 18, 2017
II. Select the correct district:

a. Under Column 1 below, check the one type of action which best describes the nature of this case.
b. In Column 2 below, circle the reason for your choice of district that applies to the type of action you have checked.

Applicable Reason for Choosing District (See Column 2 below)


1. May be filed ln Central District. 3. Child resides within the district
2. District where one or more of the parties reside. 4. District where Petitioner resides.

jii TYPE OF ACTION (Cllsck onLy oo,ej (Coo1lnlli,d} ,, APPLICABLE REASONS 1see ab�l
D A5520 Dissolution of Marriage 1. 2
D A5525 Summary Dissolution of Marriage 1. 2
C.:::] A5521 Dissolution of-Domestic Partnership 1. 2
--------
, 1 A5530 Nullity of Void or Voidabie Marriage i. 2
D A5531 Nullity of Void or Voidable Domestic 1. 2
Partnership

FAM 020 FAMILY LAW CASE COVER SHEET Page 1 of 2


(Rev 11/11) CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO DISTRICT LASC RULE 5.2
1A-F020
Sl'®:1fµtr�·:·1,ra:h1 • Clara Sa!ld?ii'isibn- Vs,. -Aaro,i. ·Rc511:tns�!i:::ili;.U1h.:.rmb�

••j..·-~··-��-�i,.���,;-;.;a!rill,i.-,;-,;;: • -�-
•. �-0�· � ,�-. •r .��.;.. :.._,____

D A5510 Legal Separation I 1. 2


-
[ =1 A5511 Legal Separation of Domestic Partnership I 1. 2
D A6126 Petition for Custody and Support of Minor I 1. 2. 3
[--------!
A6131 Child Support Services Department {CSSD) I 1.
Parentage/Support
1-------1
A6139 Foreign Support Order I 1. 2. 3

CJ A6136 Foreign Custody Order I 1. 2. 3


[------1
A6138 Uniform Interstate Family Support Act (UIFSA) I 1. 2. 3
Responding Petition
D A6122 Domestic Violence Restraining Order (Civil I (Any Court Jurisdiction - DV's only)
Harassment - use Civil Cover Sheet)

D A6600 Habeas Corpus Petition - Child Custody I 1. 3

lrlJ A6080 Petition to Establish Parentage I Paternity {Non• � 2.�


governmental)
D A6111 Approval of Minor's Contract (6751 Family Code) I1
D A6130 Other Family Complaint or Petition (Specify): I 1. 2. 3
D A6101 Agency Adoption I 1. 4
D A6102 Independent Adoption I 1. 4
D A6104 Stepparent Adoption I 1. 4
0A6103 Adult Adoption 1 4

D A6106 Sole Custody Petition 11.. 4

Ill. Enter address of minor child if known. (DO NOT COMPLETE UNLESS YOU HAVE CIRCLED ITEM 3 AS AN APPLICABLE REASON
ADDRESS: Do not complete if thl• cau falla under Family Code §1751 CITY: STATE ZIP CODE

UNBORN/CONFIDENTIAL **DUE DA.TE IS MARCH 18, 2017


IV. Enter the information below and sign the certificate.
Certificate / Declaration of Assignment: The undersigned hereby certifies and declares that the above entitled matter is properly filed for
assignment to the Central District of the Los Angles Superior Court underJyde of Civil Procedure §392 et seq., 2300 et
seq. of the Family Code, and Rule 2{b), {c), and (d} of this court for reason checked abof/1 certify and declare under penalty of perjury
under the laws of the State of California that the foregoing is true and correct.

Date: Februa_.r.y 9,; 2,Q1}


(SIGNATURE OF A
Danielle

FAM 020 FAMILY LAW CASE COVER SHEET Page 2 of 2


(Rev 11/11) CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO DISTRICT LASC RULE 5.2
FL-105/GC-120
ATTORNEY OR PARTY WffHOIJT ATTORNEY (N;,me, StBID Bar number. and addresSJ: . ·•·. :·· , ,., ,._ ·' ·; '1"08.COURT,USE'ONLY ..
Mark Vincent Kaplan· (58836)
Danielle E. Grab6is (283702)
•k

Law Offices of Schuchman & Kaplan


1875 Century Park East, 880
Los Angeles, CA 90067
TELEPHONE NO.: 310-4 7 3-07 98 FAX NO. (Optional): ·310-4 7 3-Q 625
E-MAIL ADDRESS (OplionBI):
ATTORNEYFOR_(t,l_smt1J:Rani Clara Sanderson
SUPERIOR COURT OF CALIFORNIA, COUNTY OF
STREET ADDRESS: 111 N. Hill Street
Los Angeles
mJ iJ.Q 1017
MAILING ADDRESS: SAME AS ABOVE
c1rvAN021PcooE:Los Angeles 90012 •-·�-�
�It
eRANcHNAME:
Stanley Mask
(This section appiifl omt ID family law cases.)
a.r:-..�.�
PETITIONER: Rani Clara Sanderson

RESPONDENT:Aaron Rollins
OTHER PARTY:
(This section apples only to {llll3rdian8hlp case:;,) CASE NUMBER
GUARDIANSHIP OF (Name):
Minor 8F"o585 'l,i
DECLARATION UNDER UNIFORM CHILD CUSTODY
JURISDICTION AND ENFORCEMENT ACT (UCCJEA
1. I am a party to this proceeding to determine custody of a child.
2. [iJ My present address and the present address of each child residing with me is confidential under Family Code section 3429 as
I have indicated In Item 3.
3. There are (specify number): minor children who are subject to this proceeding, as follows:
(Insert the Information requested below. The residence information must be given for the last FIVE year.s.l
e. Child's name Place of birth Date of birth SeJ<
l
Expected Due Date: 3/18/17
Period of residence Address Peraon child lived wi1h (name and complete current ac/dJllss) Relationship

to oresent [i] Confidential [iJ Confidential


Child's residence (City, state) Person child lived wilh (name arui complete current address)

to
Child's residence (City, stclte) Peraon child lived wllh (name end complete current address)

to
Child's residence (City, State) Person ch!ld lived with (name and complete cunent address)

to
b. Child's name Place of blrtl\ Date of birth sex
D Residence information is the same as given above for child a.
(If NOT the same. l)rov/lle tile lnformattcn be/ow.J
Period of residence Address Person child lived with (name and complete current address} Relationship

to present t7 Confidential 17 Confidential


Child's residence (City, State) Person child lived with (name and complete cunent address)

to
Child's residence (City. StJJte) Person child lived wlih (nlilf!f! and comp/etfl c:ummt address)

to
Child's residence (Cit'/, state) Person chlld lived with (name and complete cum,nt address)

to

c. D Additional residence information for a child listed in item a or b is contlnued on attachment 3c.
d. D Additional children are listed on form FL-105(A)IGC-120(A). (Provide all requested information for additional children.) Pa1111 of 2

DECLARATION UNDER UNIFORM CHILD CUSTODY


F°:i=;:'�t':"���s•

FL-106/Gc-120 !R9Y- .1;anuary 1, 200s1


S�s- Pr!!t�l�"J�1�n.t��
JURISDICTION AND ENFORCEMENT ACT (UCCJEA} [it P.tus
Fl•105JGCw120
• -· .· l
r, e, . :,>. rili:;c;. ,. • ..•::ir��
- -........sHOEq.:JJJU:_· �P4:. .....���fle1U1'.!X:�:On .
.
_ A.�;r._q n:_._,f!QJJ,-��.:.: �- -.:;. - , ..
- -������,�:-��-r\4--i/ : 'f·f?: :�-�):;ij�(��-:: •
.• ·: ..-�". : · �... �-. ; .•.. ·: :-·:}:"{:·' •;:··--��-··>·:/4' (· ·:::..-:�·.
- .- :- ..,; .
¥ '. . '-"• · . ,- .

4. Do you have Information about, or have you participated as a party or as a witness or in some other capacity in, another court case
or custody or visitation proceeding, in California or elsewhere, concerning a child subject to this proceeding?
CJ Yes [iJ No (If yes, attach a copy of the orders (if you have one) and provide the following information):
Court order Your
Proceeding Case number Court or judgment Name of each child connection to Case status
(name, state, location) (date) the case

a.OFamily

b. D Guardianship
c.00ther

Proceeding Case Number Court (name, state, location)


d. CJ Juvenile Delinquency/
Juvenile Deoendencv

e. CJ Adoption

5. D One or more domestic violence restraining/protective orders are now in effect. (Attach a copy of the orders If you have one
and provide the following information):
Court County State Case number (tf known} Orders expire (date)
a. CJ Criminal


b.LJFamlly
Juvenile Delinquency/
c. Juvenile Deoendencv
d.00ther

6. Do you know of any person who is not a party to this proceeding who has physical custody or claims to have custody of or
visitation rights with any child in this case? D
Yes [iJ No (If yes, provide the following information):

a. Name and address of person b. Name and address of person c. Name and address of person

D Has physical custody L.....J Has physical custody L.. J Has physical custody
CJ Claims custody rights CJ Claims custody rights CJ Claims custody rights
D Claims vlsttation rights CJ Claims visitation rights D Claims visitation rights
Name of each chnd Name of each child Name of each child

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct
r 17

::::,:�::: :a�g:rs::
(TYPE OR PRINT NAME)
��� .c?'.
ECLARAN11
7. CJ Number of pages attached: ___

NOTICE TO DEC LARA.NT: You have a continuing duty to infonn this court If you obtain any information about a custody
proceeding in a California court or any other court concerning a child subject to this proceeding.

FL-1051GC-120 [Rav. Janulll)' 1, 2009] DECLARATION UNDER. UNIFORM CHILO CUSTODY Page 2 of2

JURISDICTION AND ENFORCEMENT ACT (UCCJEA)


FL-110
SUMMONS (Family·LawT CITACION (Derecho familiar)

NOTICE TO RESPONDENT (Name): Aaron Rollins l'OR COURT uscr ONf_ y


(SOLO PARA t!SO DE' LJI CORl'E'}
AV/SO AL DEMANDADO (Nombre):

You have been sued. Read the information below and on the next page. ....,.�nt....�!
--�,��

,rs o;�tt
Lo han demandado. Le.a I.a informacion a continuacl6n y en la pagina siguiente.

.....
Petitioner's name is: Rani Clara Sanderson
Nombre de/ demandante:
CASENUMBE
--.�-�.,�
/8y,:�---··�·

You have 30 calendar days after this Summons and Tiene 30 dias de calendario despues de haber recibido la
Petition are served on you to file a Response (fonn entrega legal de esta Citaci6n y Petici6n para presentar una
FL-120) at the court and have a copy served on the Respuesta (formularlo FL-120) ante la corte y efectuar la
petitioner. A letter, phone call, or court appearance entrega legal de una copia al demandante. Una carta o /lamada
will not protect you. te/ef6nica o una audienaa de la carte no basta para protegerlo.
If you do not file your Response on time, the court Si no presenta su Respuesta a tiempo, la corte puede dar
may make orders affecting your marriage or domestic 6rdenes que afecten su matrimonlo o pareja de hecho, sus
partnership, your property, and custody of your bienes y la custodia de sus hijos. La carte tambien le puede
children. You may be ordered to pay support and ordenar que pague manutenci6n, y honorarios y costos legates.
attorney fees and costs.
For legal advice, contact a lawyer Immediately. Get Para asesoramiento legal, p6ngase en contacto de lnmediato
help finding a lawyer at the California Courts Online con un abogado. Puede obtener infonnaci6n para encontrar un
Seff�Help Center (www.cowts.ca.gov/selfhelp), at the abogado en el Centro de Ayuda de las Cortes de California
California Legal Services website (www.lawheipca.org}. (www.sucorte.ca.gov), en el sitio web de Jos Servicios Legates
or by contacting your local county bar association. de Califomla (www.lawheJoca.orgJ o poniendose en contacto
con el colegio de abogados de su condado.

NOTICE-RESTRAINING ORDERS ARE ON PAGE 2: A VISO-LAS 6RDENES DE RESTRICCION SE


These restraining orders are effective against both ENCUENTRAN EN LA PAGINA 2: Las 6rdenes de restricci6n
spouses or domestic partners until the petition is estan en vigencia en cuanto a ambos c6nyuges o mlembros de
dismissed, a judgment is entered, or the court makes la pareja de hecho hasta que se despida la petici6n, se emita un
further orders. They are enforceable anywhere in fallo o la carte de otras 6rdenes. Cualquier agencia def orden
California by any law enforcement officer who has p(Jblico que haya recibido o vista una copia de estas 6rdenes
received or seen a copy of them. puede hacerlas acatar en cualquier lugar de California.
FEE WANER: If you cannot pay the filing ree, ask the EXENCION DE CUOTAS: Si no puede pagarla cuota de
clerk for a fee 111.1a!ver fonn. The court may order you to presentaci6n, pida al secretario un formulario de exenci6n de
pay back all or part of the fees and costs that the court cuotas. La corte puede ordenar que usted pague, ya sea en
waived for you or the other party. parte o par compteto, las cuotas y costos de ta corte previamente
exentos a petici6n de usted o de la otra parte.

1. The name and address of the court are (El nombre y direcci6n de la carte son):
(SEAL]
Stanley Mosk Courthouse
111 N. Hill Street
SAME AS-ABOVE
Los Angeles 90012
2. The name, address, and telephone number of the petitioner's attorney, or the petitioner without an
attorney, are: (El nombre, direcci6n y numero de telefono def abogado def demandante, o def
demandante si no tiene abogado, son):
Mark Vincent Kaplan
Law Offices of Schuchman & Kaplan
1875 Century Park East, 880 ��
Los A.�geles, CA 90067 '"I'),-�
310-473-0798 ��
. i"�
Date (Fecha): Clerk, by (Secretano, por) Deputy (Asistente)
• ��·.. ,
Page 1 of2

"�
FOffll Adopted for Mandatory Use SUMMONS FaniilyCada, §§232, 233, 2024.7, 2040, 7700;
Judicial Council of California
FL-110 [Rev. January 1, 2015) (Family Law) So� Coda of Civil PrcceckJra. §§ 412.20, 416.60-416.90
www.courts.ca.gov
FL-110
STANDARD FAMILY LAW RESTRAINING ORDERS ORDENES DE RE.STRICCION ESTANDAR DE DERECHO
FAMILIAR
Starting immediately, you and your spouse or domestic En forma inmediata, usted y su c6nyuge o pareja de hecho
partner are restrained from: ttenen prohibido:
1. removing the minor children of the parties from the state 1. Jlevarse de/ estado de California a Jos hijos menores de las
or applying for a new or replacement passport for those partes, o solicitar un pasaporte nuevo o de repuesto para los
minor children without the prior written consent of the hijos menores, sin el consentimiento previo por escrito de la
other party or an order of the court; otra parte o sin una orden de la carte;
2. cashing, borrowing against, canceling, transferring, 2. cobrar, pedir prestado, cancelsr, transferir, deshacerse o
disposing of, or changing the beneficiaries of any cambiar el nombre de los beneficiarios de cualquier seguro u
insurance or other coverage, including life, health, otro tipo de cobertura, como de vida, salud, vehiculo y
automobile, and disabllity, held for the benefit of the discapscidad, que tenga como beneficiario(s) a las partes y
parties and their minor children; su(s) hl]o(s) menor(es);
3. transferring, encumbering, hypothecating, concealing, or in 3. transferir, gravar, hipotecar, ocultar o deshacerse de
any way disposing of any property, real or personal, cualquier manera de cualquier propiedad, inmueble o
whether community, quasi-community, or separate, without personal, ya sea comunitaria, cuasicomunitaria o separada,
the written consent of the other party or an order of the sin el consentimiento escrito de la otra parte o una orden de
court, except in the usual course of business or for the la carte, excepto en el curso habitual de actividades
necessities oflife; and perasnales y comerciales c para satisfacer las necesidedes
de/a vida; y
4. creating a nonprobate transfer or modifying a nonprobate 4. crear o modlflcar una transferencia no testamentaria de
transfer in a manner that affects the disposition of property manera que afecte la asignaci6n de una propiedad sujeta a
subject to the transfer, without the written consent of the transferencia, sin el consentimiento por escrito de la otra
other party or an order of the court. Before revocation of a parte o una orden de la corle. Antes de que se pueda
nonprobate transfer can take effect or a right of ellminar la revocaci6n de una transferencia no
survivorship to property can be elimlnated, notice of the testamentaria, se debe presentar ante la carte un aviso de/
change must be filed and served on the other party. cambio y hacer una entrega legal de dicho aviso a la otra
parte.
You must notify each other of any proposed extraordinary Cada parte tiene que notlficar a la otra sobre cualquier gasto
expenditures at least five bosiness days prior to incurring these extraordinario propuesto por lo menos cinco dfas habiles antes
extraordinary expenditures and account to the court for all de realizarlo, y rendir cuenta a la carte de todos /os gastos
extraordinary expenditures made after these restraining orders extraordinarios realizados despues de que estas 6rdenes de
are effective. However, you may use community property, restricci6n hayan entrado en vigencia. No obstante, puede usar
quasi-community property, or your own separate property to propiedad comunitaria, cuasicomunitaria o suya separada para
pay an attorney to help you or to pay court costs. pagar a un abogado que lo ayude o para pagar Jos costos de la
carte.

NOTICE-ACCESS TO AFFORDABLE HEALTH AVISO-ACCESO A SEGURO DE SALUD MAS ECONOMICO:


INSURANCE: Do you or someone i!"! your household need l,Necesita seguro de saiud a un costo asequibie, ya sea para usted
affordable health insurance? If so, you should apply for o alguien en su hogar? Si es asi, puede presentar una solicitud con
Covered California. Covered California can help reduce the Covered California. Covered California lo puede ayudar a reducir el
cost you pay towards high quality affordable health care. For costo que paga par seguro de salud asequible y de alta calidad.
more information. visit www.coveredca.com. Or can Covered Para obtener mas informaci6n, visite www.coveredca.com. o llama
California at 1-800-300-1506. a Covered California al 1-800-300-0213.
-.....-......,.,_.
WARNING-IMPORTANT INFORMATION ADVERTENCJA-IMFORMACION IMPORTANTE
California law provides that, for purposes of division of .De acuerdo a la Jey de California, las propiedades adqulrldas
property upon dissolution of a marriage or domestic por las partes durante su matrimonio o pareja de hecho en
partnership or upon legal separation, property acquired fonna conjunta se consideran propledad comunitarla para
by the parties during marriage or domestic partnership in fines de la divisi6n de blenes que ocurre cuando se produce
joint form is presumed to be community property. If either una disolucl6n o separacion legal de/ matrimonio o pareja de
party to this action should die before the jointly held hecho. Si cualqulera de las partes de este caso llega a
community property Is divided, the language in the deed fallecer antes de que se divida la propledad comunitaria de
that characterizes how title Is held (i.e., joint tenancy, tenencla conjunta, el destino de ta misma quedara
tenants in common, or community property) will be determinado por las c lilusulas de la escritura
controlling, and not the commuirdty property correspondiente que describen su tenencia (por �-, tenencia
presumption. You should consult your attorney if you conjunta, tenencia en comun o propiedad comunitaria) y no
want the community property presumption to be written por la presuncion de propiedad comunitaria. SI quiere que la
into the recorded title to the property. presunci6n comunltarla quede reglstrada en la escrltura de
J /a propied��• deberia consu/�'....����u_n_abog ado. _____
_ _ _ _ _
.-.<���- ►:_...__________

FL-110 [Rev. January 1, 2015]


SUMMONS Page2of2

{family Law)

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