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  • IN THE MATTER OF: BARBARA MONDERINE Other Civil Petition (General Jurisdiction) document preview
  • IN THE MATTER OF: BARBARA MONDERINE Other Civil Petition (General Jurisdiction) document preview
						
                                

Preview

1 KELSEY L. O’ROURKE, Bar No. 322676 PERRY, JOHNSON, ANDERSON, 2 MILLER & MOSKOWITZ, LLP 438 1st Street, 4th Floor 3 Santa Rosa, California 95401 Telephone: (707) 525-8800 4 Facsimile: (707) 545-8242 Email: orourke@perrylaw.net 5 Attorneys for Petitioner, 6 BARBARA MONDERINE 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES 10 BARBARA MONDERINE, Case No. 11 Petitioner. VERIFIED PETITION FOR DECLARATORY RELIEF 12 PERRY, JOHNSON, ANDERSON, Date: MILLER & MOSKOWITZ LLP 13 Time: Dept.: 14 15 Petitioner, BARBARA MONDERINE, by and through her attorney Kelsey 16 O’Rourke, for her Petition, upon knowledge with respect to herself and her own 17 acts, and upon information and belief as to all other matters, respectfully alleges 18 as follows: 19 I. NATURE OF THE ACTION 20 1. Petitioner, BARBARA MONDERINE, is pursuing her right to claim 21 dual Italian citizenship pursuant to the civil law doctrine of jure sanguinis 22 Italian Law 555/1912, Art. 7 (blood line citizenship) as a descendant of her 23 deceased Italian paternal grandparents, Giuseppi Monderine and Maria Rosa 24 Monderine, née Loria, who immigrated from Naples, Italy to Pennsylvania. 25 2. In order to qualify for jure sanguinis, all relevant vital records 26 documents with name and/or date discrepancies require a Court Order that the 27 relevant ancestors are deemed to be “one and the same person”. In this Petition, 28 Petitioner seeks the Court’s intervention to determine that in spite of the 1 VERIFIED PETITION FOR DECLARATORY RELIEF