Commonwealth of Massachusetts

The Trial Court

Suffolk Division Probate and Family Court Department Docket 07D0465

COMPLAINT FOR CIVIL CONTEMPT

Amir Shakir, Plaintiff

vs.
Lakeisha Gilliard, Defendant

1). Plaintiff, who resides at 104 Brush Hill Road, Milton, Massachusetts 02186
Was the spouse of defendant, who now resides at 6 O’Bierne Place, Roxbury,
Massachusetts 02119

2). By order of the Court, dated 10/29/2007 and modified 2/11/2010, defendant was
ordered:

(a) to grant plaintiff visitation rights with minor child Shakirah Shakir
(b) make up all missed visits on or before ONE WEEK after missed visits (as amended
on 2/11/2010)

and this order is sill in force

3). Defendant has not obeyed this Honorable Court’s order and

(a) plaintiff has been denied visitation rights on 2/12, 2/13, 2/14, 2/17, 2/26, 2/27, 2/28
and 3/3
(b) defendant has violated the order on 2/12, 2/13, 2/14, 2/17, 2/19, 2/20, 2/21, 2/24,
2/26, 2/27, 2/28 and 3/3 by:

forcibly blocking visits with plaintiff and minor child Shakirah Shakir on 2/12, 2/13,
2/14, 2/17, 2/26, 2/27, 2/28 and 3/3

Willfully failing to make up visits within one week (2/19, 2/20, 2/21 and 2/24) as
ordered by the Honorable Judge Levine on 2/11/2010.

4). Wherefore, plaintiff requests that defendant be required to appear before this Court to
show cause why said defendant should not be adjudged in contempt of Court and for such
other relief as to said Court may seem just.

Respectfully Submitted

Amir Shakir
104 Brush Hill Road
Milton, MA 02186
617-301-3569

Date:_____________