1    William M. Hilton, CFLS
             Attorney At Law
        2    Box 269
             Santa Clara, California 95052
        3    TEL: (408) 246-8511  FAX: (408) 246-0114

        4    Attorney for [Name of Client]

        5

        6

        7

        8                     SUPERIOR COURT OF [Name of State]

        9                      COUNTY OF [Name of County]

       10

       11    [Style of Case]                        )   Case Number:
                                                    )
       12    [Plaintiff/Petitioner]:  [Ptn: Name]   )
                                                    )   PARENT'S RIGHT TO
       13    [vs/and]                               )   KNOW THE RESIDENCE
                                                    )   OF THE CHILDREN
       14    [Defendant/Respondent]:  [Res: Name]   )
             _______________________________________)
       15

       16    1.0    ABSENT AN AFFIRMATIVE SHOWING OF DETRIMENT BY THE

       17           CUSTODIAL PARENT, THE NON CUSTODIAL PARENT HAS A RIGHT

       18           TO THE KNOWLEDGE AS TO WHERE THE CHILDREN ARE RESIDING.

       19    1.1    A parent is entitled to know where the children of the

       20           relationship reside.  In re Marriage of Oldfield (1979)

       21           94 Cal.App.3d 259, 262 [156 Cal.Rptr. 224, 225]

       22

       23

       24

       25

       26

                                         Page 1






        1    1.1.1      A parent cannot be deprived of this knowledge absent

        2               an affirmative showing on the part of the other

        3               parent that it would be unwise for the other parent

        4               to be in possession of the children's residence.  In

        5               re Marriage of Oldfield (1979) 94 Cal.App.3d 259,

        6               262 [156 Cal.Rptr. 224, 225].

        7    2.0    AN ATTORNEY WHO IS REPRESENTING A PARTY TO AN ACTION

        8           MUST DISCLOSE THE ADDRESS AND RESIDENCE OF THAT PARTY.

        9    2.1    The power of a court to direct the disclosure of the

       10           client's address has long been recognized.  Falkenhainer

       11           v Falkenhainer (1950) 97 N.Y.S.2d 467, 468.  Accord:

       12           Anonymous v Anonymous (1969) 298 N.Y.S.2d 345

       13    2.2    When a client has appeared in an action in which the

       14           address is sought and the client has sought the use of

       15           the courts and the information is necessary not only to

       16           protect the rights of a party adverse to the client, but

       17           also the interests of an innocent third party - the

       18           minor child - the address of the client is not

       19           privileged information. Dike v Dike (Wash. 1968) 448

       20           P.2d 490, 497-498.  Accord:  Matter of Jacqueline F.

       21           (1979) 47 N.Y.2d 215 [391 N.E.2d 967, 970-971]

       22    3.0    SUBMISSION

       23    3.1    Respectfully submitted on [Date Submitted].

       24                                        __________________________
                                                 William M. Hilton, CFLS
       25

       26

                                         Page 2