Sytch Motion for Modification

7/30/2019 Sytch Motion for Modification

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NO. N23N-CR-12-0132781-S

STATE OF CONNECTICUT

VS.

TAMARA SYTCH

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SUPERIOR COURT

GEOGRAPHIC AREA

23

December 4, 2012

MOTION TO MODIFY PROTECTIVE ORDERS

The defendant, Tamara Sytch, through her undersigned counsel, respectfully requests this

court modify all existing No Contact Protective Orders to Partial Protective Orders for the purpose of

allowing the defendant, Tamara Sytch, to speak, and interact, withDamien Selvaggio, the party

classified as the victim under Connecticut Law.

In support of this request the defendant, Tamara Sytch, through her undersigned counsel,

represents as follows:

1) At this time a full no contact order is in place, preventing either party from having contact

with each other.

2) At this time, the defendant Tamara Sytch, and the party classified as the victim,Damien

Selvaggio, believe the order should be modified, and request, said action be taken, with the purpose


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of the modification to allow the parties to speak over the phone and via electronic mail.

In further support of the Motion the defendant, Tamara Sytch, through her

undersigned counsel represents the following additional facts.

3) At this point the defendant, Tamara Sytch, has completed the detoxification portion of her

treatment at the Caron Foundation, and has been inpatient for a period of close to 50 days. Alcohol

or drugs will play no role in any interaction between the defendant, Tamara Sytch, andMr. Selvagio

which were at the center of, and the main cause of past events which led to court involvement. In

short the major contributing factor, which led to the defendants arrests, is no longer present.

4) Both parties have not spoken since approximately October 18, 2012, allowing for ample time

for the emotional elements of this case to subside and allowing both parties to interact like rational

adults.

5) Tamara Sytch is currently housed at Concept 90, in Harrisburg Pennsylvania, and any

contact will be via telephone or electronic mail. As a result, there exists no risk there will be another

domestic dispute like those that have already taken place and make up the subject matter of her

pending charges. This is an extremely regimented facility and any behavior deemed unacceptable

would lead to the loss of phone and inter-net privileges.

6) In addition, the purpose of the defendant participating in treatment is to allow her to address


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certain issues and avoid finding herself in similar situations in the future. At this time the failure of

the parties to speak with each other has created a situation of uncertainty and questions for both

parties, which tends to undermine the defendants current treatment goals. In essence, it is easier to

concentrate on moving forward without questions lingering from the past. Allowing the parties to

speak would essentially allow for the possibility of closure and the ability for both to move forward.

7) In the undersigneds understanding these facilities are concerned with following court orders

and are only concerned with compliance of said orders. The undersigneds understanding is if the

court will allow contact, they take no issue with such a decision nor have an opinion.

8) Finally,Mr. Selvaggio has contacted the undersigned on numerous occasions offering

information that has been helpful to the undersigned in formulating and understanding a treatment

plan for the defendant. He has been polite, has thanked me for my becoming involved in the case

and can be described as an asset to the defense. To be clear, he has been an asset to the defense in

many ways providing a great deal of insight related to certain situations that has proven extremely

valuable. At this point the undersigned believesMr. Selvaggio has a great deal of insight to offer the

defendants treatment providers and this will only serve to benefit the defendant and her treatment

goals.


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WHEREFORE, the defendant, Tamara Sytch, respectfully requests that the Motion for

Modification of Protective Order, be granted and modified from a Full Contact Order to a Partial

Protective Order, for the reasons stated therein and for such other grounds as may be asserted at a full

hearing on the merits thereof.

THE DEFENDANT

TAMARA SYTCH,

BY _______________________________________

Rob Serafinowicz (423695)

The Law Offices of Rob Serafinowicz, LLC

52 Holmes Avenue

Waterbury, CT 06702

Telephone Number: (203) 755-0267

Fax: (203) 528-4302

[email protected]

Her Attorney


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O R D E R

The foregoing motion having been heard, it is hereby

ORDERED:

GRANTED / DENIED

THE COURT

BY__________________________, J.

CERTIFICATION

This is to certify that service has been made upon the following counsel pursuant to the

Connecticut Rules of Practice:

Office of the States Attorney

Geographic Area 22

121 Elm Street

New Haven, CT 06510

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Rob Serafinowicz, Esquire

Documents

Sytch Motion for Modification