STATE OF NEW MEXICO ·
COUNTY OF SANDOVAL
THIRTEENTH JUDICIAL DISTRICT COURT
D-1329-DM-2011-00075
ANDREA Y TRUJILLIO
Petitioner,
vs.
SALIM M SAMJI
Respondent.
EMERGENCY MOTION TO MODIFY COURTS MOST RECENT CUSTODY ARRANGEMENT FOR FULL TIME CUSTODY AND CARE OF CHILD TO BE WITH RESPONDENT
COMES NOW Salim Samji, pro se, and respectfully request that this Honorable Court amend the current visitation order and compel the Petitioner to allow for proper visitation and prevent alienation and estrangement.
FACTS
1. The most recent timesharing and custody plan was set forth on November 26, 2013.
2. Since this order was in place, Petitioner has disappeared. Respondent is aware that she is currently under investigation by CYFD, and they too cannot locate her.
3. Counsel is aware that Petitioner and her estranged husband are currently separated.
4. Respondent has had no communication with Petitioner about time sharing, custody arrangements or anything concerning child. It is concerning because the child has been taken out of the State without his permission and knowledge. It is assumed that Petitioner’s estranged husband who she is currently separated from is taking child without Petitioner.
5. Respondent cannot locate or reach Petitioner to request her position.
6. Respondent is concerned that ongoing time with the Petitioner’s estranged husband who she is separated with is not permitted in the most recent timesharing and custody plan that was set forth on November 26, 2013.
WHEREFORE, Respondent respectfully requests this Court to schedule an emergency hearing and award him full custody of the child.
Submitted by:
/s/ Salim Samji
ALL LITIGANTS MUST COMPLY WITH LR13-118 Motion practice; package procedure
I HEREBY CERTIFY that on this 21 day of October, 2022, a true and correct copy of this pleading was delivered to the last known address of the Petitioner.
/s/ Salim Samji
SALIM SAMJI
HCS Pub. April 14, 21, 28, 2023