That since the entry of the Final Judgment or last modification thereof, there has been substantial, and/or material, and/or anticipated, and/or unanticipated, and/or voluntary, and/or involuntary changes in circumstances, which warrants a modification of the Final Judgment.
That the Father has “completely and absolutely” complied with the Court’s Orders, by the Honorable Judge Maria Espinosa Dennis, stated in paragraph 29 and Father has notified the Honorable Court by filing “Notices of Compliance”.Petitioner/Father complied with “temporary supervised visitation” at the minor child’s day care facility from 2009 through 2011 and also with 36 Family Court Services’ Supervised Visits. Family Court Services Report filed by Supervised Visitation Specialist Monica Escobar, L.C.S.W. throughout 2012, 2013, 2014, and the last visit on January 24th, 2015.
That the Father has absolutely complied with Honorable Judge Maria Espinosa Dennis Orders and therefore the Court must grant the Father normal and reasonable timesharing as stated in Paragraph 31 of the Final Judgment.
That accordingly and pursuant to the Final Judgment, Petitioner/Father has complied with ALL requirements of this Honorable Court. This creates important and substantial changes in circumstances as prescribed by Honorable Judge Dennis warranting Modification of Timesharing to allow the Father reasonable timesharing which may include overnight timesharing, school holidays, school breaks, and summer vacations with the minor child.
That the Father has demonstrated to be a fit and able parent to his older child, DK (born on 9/20/99) the subject minor child’s older brother, with whom the Father spends normal and reasonable timesharing since the divorce on June 4, 2004 under Broward County’s 17th Judicial Circuit Case Number 02-24972.
That this Petition for Modification of Timesharing is in the best interests of the subject minor child because the child will be able to spend a greater amount of time with her father, older brother, and paternal family consistent with the presently stated Legislative Intent of Florida’s Family Law Statutes and,
That the subject minor child (ZN) has expressed a desire to spend more time with her Father in his residence of which she visited often while parties were residing together, and that said place of residence affords the minor child significantly greater accommodations than Petitioner and Respondent’s previous shared place of residence in Miami-Dade County, Florida.
That the Father has proven to show responsibility, concern, love and affection for his children as described by Honorable Judge Dennis in the Final Judgment on paragraph no. 33 and subparagraphs A through S on pages 5, 6, and 7.That on page 1 of the Family Court Services’ (“FCS”) Supervised Visitation Report’s Visitation Progress dated January 29th, 2013 submitted by Supervised Visitation Specialist Monica Escobar, L.C.S.W., which is based on the observations of Rafael Castro, Ph.D. and Maria Puentes, M.S.W. the FCS’s Supervised Visitation Observers stated that “Mr. Inguanzo displayed behaviors indicative of being nurturing, patient, and attentive to ZN’s needs”, and that “she (ZN) appeared to enjoy her Father’s company”, and that “ZN and her Father Displayed a good level of interaction.
That the Father has demonstrated to this Honorable Court a disposition, desire, and capacity to act upon his children’s needs. And the Father has proven that he will always encourage that BOTH Parents have extremely close parent-child relationships.Father has proven successful co-parenting of children since the birth of his son, DK, the subject minor child’s brother.A Child Support Guidelines Worksheet, Florida Family Law Rules of Procedure Form 12.902(e), can and will be filed again if it pleases the Honorable Court.
WHEREFORE, I, David M. Inguanzo, Petitioner/Natural Father, respectfully request and prays that this Honorable Court grant this Amended Supplemental Petition to Modify Visitation / Time-Sharing, and Establish Parenting Plan/Timesharing Schedule as follows:
Issue an Order Modifying the current timesharing schedule to afford Father overnight normal and reasonable timesharing to include sharing of school holidays and breaks, and summer vacation with the subject minor child consistent with Honorable Judge Dennis’ ruling in her Order of July 8th, 2010.
I, David M. Inguanzo,Petitioner/Father, understand that I am swearing or affirming under oath to the truthfulness of the claims made in this petition and that the punishment for knowingly making a false statement includes fines and/or imprisonment.Dated