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STOP LEGAL ABUSE OF A MOTHER

New Jersey Court Defrauds Mother of $1.4M in Legal
Fees & Eliminates All Parenting Rights

Mother Launches $400M Suit Against Judiciary

Demand Judge Sogluizzo Step Down
CONTACT STU RABNER & GLENN GRANT TODAY
stuart.Rabner@judiciary.state.nj.us
glenn.grant@judiciary.state.nj.us

Family Court – The Brilliant Racket (TM)
Remember: It’s Conflict For Cash

Actual Plea Being Ignored By Rabner & Grant:

Messrs. Grant, and Chief Justice Rabner:

On May 2,2014, I filed a civil complaint in the Hudson County Law Division, Civil Part, against Hudson County Family Court Judge, Maureen Sogluizzo, P.J.F.P., Hudson County Vicinage, Superior Court and State of New Jersey. I filed for Jury Demand, Demand for Discovery and Deposition Notice against Maureen Sogluizzo In Official capacity as a Judge of the Superior Court of New Jersey, Maureen Sogluizzo, in “personal” capacity and as employee of Corporation of State of New Jersey (also defined as person”); Hudson County Court Vicinage; Superior Court of New Jersey; State of New Jersey in its corporate “personal” capacity, jointly, severally and,/or in the alternative.

On May 6,2014, I received an Order From Judge Peter F. Bariso Jr., A.J.S.C who is the assignment Judge of Hudson County, stating the following “On motion of this court sua sponte, in order to preserve the appearance unbiased hearing, IT IS ON THIS 6th DAY OF MAY, 2014, ORDERED that venue be transferred to Essex County for disposition by a Superior Court Judge to be designated by the Assignment Judge.”

On May 13,2014, I received a track assignment notice from Essex County – Civil Division notifying me of a new Docket number, ESX L-003415’1,4 (EXHIBI #3) On May L9,2OT4,I filed a motion with Hudson County Assignment Judge Bariso to disqualify/recuse Defendant Judge Maureen Sogluizzo. Judge Bariso clearly stated in his Order, dated May 6, 2074,that there was a conflict of Interest, and in order to show impartiality and lack of bias, the case was transferred to Essex County from Hudson County so I could get a fair hearing.

Judge Maureen Sogluizzo who is now a Defendant in this instant case refuses to disqualify herself from my family court matter, Docket No. FM-09-1722-09, and wants to conduct two (2) hearings in a family court Judge capacity on the 13th of June,2014, where plaintiff ex-husband, (name redacted), wishes to sanction me for no reason other than he and his former attorneys at the Beilan, Miklos & Makrogiannis law firm (whom I sued in an earlier lawsuit and are no longer representing my former husband because of conflict of- interest and lack of impartiality; or so I think) are in concert with Judge Sogluizzo and want to extort money from me.

Defendant Judge Sogluizzo wrongfully ordered the relocation of my minor daughter to North Carolina in direct contravention to six (6) evaluation reports from experts, including psychiatrists and psychologists, three (3) of which were appointed by her who stated that I should have had unsupervised shared parenting at the least and sole custody because the father who had his own agenda to remove the mother from the child’s life through the relocation and parental alienation. My former husband has been in North Carolina since July 2013 and my daughter is suffering severe emotional distress since being removed from my custody, and New Jersey, where all of her friends, school, therapists, and maternal family are. My former husband has no family in the United States.

Defendant Judge Sogluizzo acted improperly and denied my former husband’s motion for relocation, calling it inimical to the child’s “best interests” because of the aforementioned reasons to not allow the child to move because everything for her is in New Jersey. Within 20 days Defendant Sogluizzo changed her mind and sent my daughter to North Carolina with my former husband-without the prerequisite plenary hearing involving a “Baures v. Lewis ” relocation hearing, and without a “best interest” hearing. Defendant Judge Sogluizzo postponed the plenary hearing, because she told me that her mother-in-law died and that if I don’t drop the plenary hearing (at that time), I would have to wait another 3 months to have overnight visitation with my then 7 year-old daughter. Defendant Judge Sogluizzo also has ignored various motions where I have requested equal time with my daughter. This is all supported by all mental health evaluation expert reports but she ignores it and now has set up a hearing on June 23rd, 2013,which is to be for an expansion of my time with my child and the entire summer parenting time with my child.

In light of the law suit which makes her a Defendant, Judge Sogluizzo will now act in a vindictive fashion violating Canon 3 of the NJ Code of Judicial Conduct (Judge must be impartial). As a defendant she is not capable of being impartial and must be disqualified immediately from my case as an acting Judge. Most importantly all parties and the minor child now reside in North Carolina. I am only using the above address in care-of (Under my mother) because I am in and out of the state moving. Also under the UCCJEA, New Jersey’s exclusive, continuing jurisdiction is retained until a court of this State determines that neither the child, or the child and one parent have a significant connection with this state, and that substantial evidence is no longer available in this state concerning the child’s care, protection, training and personal relationships. My former husband and my child moved to North Carolina as of July 1,2013. My former husband has taken up a job working for a large bank there and has married again. The child has been enrolled in school in North Carolina and is completing her Grade 2 in North Carolina. She goes to doctors and therapists in North Carolina and has no further contacts in New Jersey, other than her maternal grandparents and cousins whom she visits when with me. I have now established a residence and driver’s license in North Carolina. The case must be transferred to North Carolina given the two (2) sets of circumstances. I attach case law to support the transfer of Jurisdiction to North Carolina courts where all parties are scheduled for a hearing on June 9,2014 through a complaint that was filed in April 2014.

Defendant Judge Sogluizzo continues to act in a biased fashion and has financially and emotionally ruined me and my family, including ruining the well-being of my daughter. I would strongly request that in the interest of impartiality, and integrity of the courts, that Defendant Judge Sogluizzo no longer hear any of my matters and be removed from my case, because not only is she the defendant in my civil action in Essex County,but under the UCCJEA, she no longer has jurisdiction over any of the parties or the child.

Respectfully:

Monisha Shivani

Hon. Peter Bariso, A.J.S.C. (fax no. (201) 795-0725,
Judge Maureen Sogluizzo, P.J.F.P. (fax no. (201) 795-6199)

Families Civil Liberties Union
www.fclu.org