In the petition

In the petition

F,C.A.$$440,44247,449,45t,46t,466,467,652,654; S.S.L, $ lll.g 4-lr tzlt997 FAMILY COURTOF THE STATE OF NEW YORK COIINTYOFNEWYORK In the Matterof a C...

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F,C.A.$$440,44247,449,45t,46t,466,467,652,654; S.S.L, $ lll.g

4-lr tzlt997

FAMILY COURTOF THE STATE OF NEW YORK COIINTYOFNEWYORK In the Matterof a CustodyrVisitation Proceeding Linda Williams, Petitioner, - against-

File #: Docket#:

4309 V-14371-03/08G 2NDAMENDED PETITION FOR MODIFICATION OF AN ORDER OF CUSTODY

DamonAnthony Dash, Respondent. The undersignedPctitioner respectfully showsthat: Petitioner,Linda Williams, residesat ***AddressConfidential*{'*. Petitioner,Linda Williams, hasa child-in-commonwith the respondent,DamonAnthonyDash. Petitioner,Linda Williams, is the motherof thechild, DamonA. DashII. Respondent,Damon Anthony Dash,residesat Respondent, DamonAnthony Dash,hasa child-in-commonwith the petitioner,Lmda wrlliams. Respondent, DamonAnthony Dash,is the fatherof the child, DamonA. DashII. An orderdatedNovember26,2007was enteredwhereinseefile for specifics. The name,presentaddress,dateof birth andsocialsecuritynumberof eachchild who is thesubjectof this proceedingareas follows:

Nerre

Ad4ress

Datq.gfBirth

# $ogiefSecuriqv

DamonA. DashII My sonis at imminent riskliving io u-nstaUle homewith no structure or superyisionand I fear "oo for the safetyand well-being of my child in r safeand loving environmentliving with I want him and me. Sincethe entry of said order, there has beena changeof circumstancesin that there has been educationalneclectof the ehild hv the Respondentand it has becomeextremely extremeto the point

that, helpin this matter.nn* iriJ'* ".,1;" theRespondent.'

m"ooo ao*o*ard since J"Tfi;":,::XTltff; spirar ever "

f and chronic truancy's t (latenesses absences)underachievementsand disnrptivebehaviorthisyear.ACS hasinformed thePetitionerthat the Respondenthas a court orderprohibitingACs from talking tolintendewing him or the children. The Respondent/Father'slinrncial situation ig on a downwrrd spinnl as well. Petitioner statesthat he is liquidating all of his assets. He has already sold thc home in CAr one apartment in NYC, and the onethat he is currently occupying is up for sale.Respondentis alsosuffering through mtny other legal troubles including a rape case,I tax case,and a troubled marriage. Petitioner statesthat the Respondentis a flight risk becausehe has a history of fleeingwith the child. On March 21,2003the Respondentwas issueda warant of arrest for abscondedof a child (Our son Damon Dash II).

No: u-r.:??:#0"J3 Docket 4-11

Respondedwts arresteduntil he producedthe chitd. Respondentis also in contemptbecausehe has beenviolatlng the court order by not providing the child with a driver or spendingmoney while visiting the Petitioner. The Respondenthastrken awaythe drlver all together.The child takesthe subwayto and from school.The child wrs surprised and very upset at the Respondenttaking the driver away.The Respondentstatedin the pastthat the child is in dangerand is a kidnaping risk due to his celebritystatus.Petitioner agreesthat the child is a kidnaping risk Respondentneglectedthe child by not taking the child to the doctor or dentist yearly, child stated that his sister goesto the doctor and he doesnot. The child hrs reportedto the Petitionerthat he was living with not hot water or electricityfor two months in his bedroom. Petitionerstatesthat there is a l0 Million Dollar Trust Fund that the Respondentwts orderedto put in placefor the child but shehasnot yet receiveda copy of it as proof that it was done. Respondenthasa history of drug use. Respondenthas a history of mental illnessin his family, his mother was in and out of a mental institution. Petitioner alsostates that therewasan incident in which the Respondentts uncleCarlton (Respondent'smother'sbrother) committedsuicidein November2007the daybeforeThanksgivingby shootinghimselfin theheadon his own front lawn. Then the Respondenttook thechild to the hospital morguewith him rnd had the child presentastheypulled out the body. Respondentdid not take any of his other children to witness this and should not of taken the stid child. Petitioner statesthat her son said is was very, very traumatic and feels his father ncver sbould of taken him to see something like that..... Clearly emotionalneglectto only this child. The child no longerhasanyoneat hometo preparehis mealsbecausethe Respondentcut backon all of his staff. The RespondentlosUsoldhis comprniessohe doesnot havethe incomehe usedto. These are other reasonswhy the Petitionerneedsproof of the 10Million doller Truse rnd EducationalFund for the childs future. ..4 - ab

custoqyot'ruexespondent On March 31,2008the deanwrote tne Respondentto iet him know from this point on the child can not be late or absentmore then 3 times or he will be kicked out of school for good.Petitionerstatesthat the child wss lateto schoolon April 3, 2008.Petitionerstatesthat there is no legalreasonwhy custodywas eyer changedfrom her to the Respondent Petitionerstatesthat the Respondentis clearly unfit and the Petitioneris the lit parent. Petitionorstatesthat the child hasalwaysrttendedsummerc,rmpand ever sinceNovember2006the child has beggedthe Respondeutto pay for BasketbaltCamp at Hofstra University. Last year 2007 a few monthsbeforethe summer,the child statedto thePetltionerand the Respondentthat hewanted to go to BasketballCamp at Hofstra University.On May 25, 2007the child calledthe Petitionerwith the Respondentbecausethe RespondentwantedthePetitionerto sendall of the campinformation to him and his Assistrnt Nancy. (Petitionersentinformation to both) Due to Judge Knipps prolonging thevisitationcasefromJune200Tto the endofAugust200?myson's summerwasruined.Petitioners sonfor the past few months and over this weekendstrted that he wanted (hopes)the Respondentto pay for Hofstra Camp. The child hasonly 2 summersto enjoy summer camp becausehe is 16years old. The child statedto the Petitioner that he wanteda normal life with his mother. Petitionerstatesthat shedoesnot want her sonfalling through the cougfuiystem cracksagainin Judge Knipps courtroom.The Petitioner statesfrher sonor her will bdftFeatedfairly becausesheliled a petition lrrstyear in November 2007to haveJudgc Knipps requsedbff the caseand it wasdenied. Petitioneralsolilcd e complaint (lotter) to JudgeKnipps bossJudgeJosephLaual. Petitioncrstates that her casesin the past hrve becnprolongedby JudgeKnipps and shehopesthat this matter will be handledexpeditiously.

,/

r.r", v-Ie!??3osiooJ3 Docket 4-11

the order should be modified in the following By reasonof said zubsequentchangeof circumstances, respects: Petitioner is requestingimmediatcemergencycustodyof the child. Petitioner requestsfull solecustodyof the child. Petitioner alsorequertethat the RespondentBe directed to take a drug test. Petitioner requestsa copy of the 1999trust and cducationalfund that the Respondentwas ordered to setup. Potitioner requeststhat the court order an ACS investigrtion. Petitioner is requestingany and all papcrs that prohibit ACS from talking to/interviewing the Respondentand the children. Petitioner requestthat the Respondentprys $3,600in futl for Hofstra Basketball Camp by May 5' 2008.Petitioner requesta jury trial No previousapplicationhasbeenmadeto anycourt or judge for the relief hereinrequested. WHEREFORE,Linda Williams respectfullypraysthat the said orderbe modified in theserespectsset forth aboveand for suchother relief asto the Court may seemjust andproper.

Dated:April 8,2008

VERTFICATION STATEOFNEWYORK) :ss: couNTY oF NEW YORK) LindaWilliamsbeingdulysworn,deposes andsays: That he/sheis the Petitioner in the above-entitledproceedingand is acquaintedwith the factsand circumstancesthereof;that he/shehasreadthe foregoingandknows the contentsthereof; that the same is tue to his/her own knowledge,exceptas to mattersthereinstatedto be allegedon informationand belief and asto thosematten he/shebelievesit to be

Swornto beforeme on

Chief Clerk or Designee