She’s Defending a Child Abuser!

STATE OF RHODE ISLAND                         FAMILY COURT

WASHINGTON, Sc.

MARGARITA E. PALANGE,

Plaintiff

vs.                                                             C. A. NO. W12-0361

STEVEN J. PALANGE,

Defendant

MOTION TO ADJUDGE IN CONTEMPT

NOW comes the Plaintiff, MARGARITA E. PALANGE, and states that this Honorable Court did issue an Order dated June 13, 2018 which restrained and enjoined the Defendant from bothering, harassing or interfering with the Plaintiff at any time or place; that since that time, Defendant has embarked on concerted effort through internet postings to damage the reputation of the Plaintiff and otherwise harass the Plaintiff by, amongst other things, disparaging Plaitniff’s parenting skills and relationship with her daughter; Plaintiff has recently specifically named Plaintiff and the child in his disparaging comments; said conduct is an intentional violation of the Orders of this Court.

WHEREFORE, PLAINTIFF PRAYS:

1) That the Defendant be adjudged in willful contempt for his aforesaid conduct;

2) That this Honorable Court restrain and enjoin the Defendant from mentioning the Plaintiff in any fashion, and from publishing the minor child’ name, on the internet or in any other forum;

3) That this Honorable Court award Plaintiff sole custody of the minor child insofar as Defendant’s conduct is indicative of his inability to cooperatively parent with the Plaintiff as required by Duke v. Duke, 510 A2d 430 (RI 1986) and Horton v Horton, 891 A2d 885 (RI 2006).

4) That the Defendant be ordered to pay for the reasonable costs incurred by the Plaintiff in prosecuting this motion, including a reasonable counsel fee; and

5) That the Plaintiff be awarded such other and further relief as this honorable court may deem just.

MARGARITA PALANGE,

By her attorney

/S/ Richard E Updegrove, Jr., Esq.

UPDEGROVE LAW, LTD.

Richard E. Updegrove, Jr., Esq.

314 Oliphant Lane

Middletown, Rhode Island 02842

(401) 847 5684   Bar No. 2245

THIS MATTER IS ALREADY ON THE CALENDAR FOR HEARING BEFORE THE WASHINGTON COUNTY FAMILY COURT ON THE 24TH DAY OF SEPTEMBER, 2018 AT 9:00 A.M.

CERTIFICATE OF SERVICE

I hereby certify that, on the 7th day of August, 2018:

□  I filed and served this document through the electronic filing system on the following parties: _______________________________________.

The document electronically filed and served is available for viewing and/or downloading from the Rhode Island Judiciary’s Electronic Filing System.

□  I served this document through the electronic filing system on the following parties:

__________ ________________________________________.

The document electronically served is available for viewing and/or downloading from the Rhode Island Judiciary’s Electronic Filing System.

□X  I mailed/faxed/emailed or  □  hand-delivered this document to the attorney for the opposing party and/or the opposing party if self-represented, whose name is

TANYA GRAVEL, ESQ.,  at her normal email address .

/S/      RICHARD E. UPDEGROVE, JR.

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