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DC Court of Appeals Brief King v Pfeiffer, Interference by CFSA in DC Superior Court Proceeding

DC Court of Appeals Brief King v Pfeiffer, Interference by CFSA in DC Superior Court Proceeding

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Brief before the DC Court of Appeals seeking reversal of arbitrary lower court decision where the Court refused to order an independent medical examination of a seriously ill child who suffers from severe chronic neutropenia of unknown cause under the care of a military research doctor-father.
Brief before the DC Court of Appeals seeking reversal of arbitrary lower court decision where the Court refused to order an independent medical examination of a seriously ill child who suffers from severe chronic neutropenia of unknown cause under the care of a military research doctor-father.

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Published by: legaltruth on May 16, 2011
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02/10/2013

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2LIST OF OTHER PARTIES AND THEIR COUNSEL
Appellee:
Dr. Michael Pfeiffer, Phd, formerly with Georgetown University/Medstar, now with theVeterans Administration Hospital in Washington, DC. His attorney is Sean W. O’Connellof Arlington, Virgina
 
3
TABLE OF CONTENTSSTATEMENT OF THE ISSUES PRESENTED FOR REVIEW
............................. 1
 
BRIEF STATEMENT OF THE CASE
................................................................... 2
 
STATEMENT OF FACTS
..................................................................................... 3
 
The August 5, 2009 Hearing
................................................................................................................................18
 
The Lower Court’s Rulings
.................................................................................................................................19
 
ARGUMENT
....................................................................................................... 23
 
I. THE COURT WAS UNFAIRLY PREJUDICED AND ACTED ERRONEOUSLY BYALLOWING THE FATHER TO SEQUESTER THE MOTHER’S COUNSEL, BY ALLOWINGQUESTIONING OF MATTERS THAT ONLY SEQUESTERED COUNSEL WAS FAMILIAR, BYALLOWING VIOLATIONS OF THE MOTHER’S CONSTITUTIONAL RIGHTS, AND BYALLOWING AN EX PARTE IN CHAMBERS MEETING WITH BY JAMES P. TOSCANO, ESQ.
....................................................................................................................................................................................24
 
The Father Violated The Legal Standard For Calling Opposing Counsel As A Witness and Achieved ItBy Violation of the DC Rules of Professional Conduct
............................................................................................28
 
II. THE COURT ABUSED ITS DISCRETION WHEN IT REFUSED -- SOLELY ON THE BASISTHAT THE COURT DID NOT CONSIDER COUNSEL MORRIS “LEAD COUNSEL” -- TOCONSIDER MOTIONS, SUPOENAS AND OTHER ACTIONS FILED OR TAKEN BYMOTHER’S COUNSEL MORRIS, DENYING HER RIGHTS TO DISCOVERY AND A FAIR HEARING AND CAUSING LACK OF CONSIDERATION OF ALL OF THE EVIDENCEAVAILABLE TO THE COURT
........................................................................................................................29
 
III. THE COURT’S REFUSAL TO ALLOW ALL OF MOTHER’S EXPERT WITNSSES TOTESTIFY WAS AN ABUSE OF DISCRETION -- INCLUDING WHERE THE COURT ADMITSTHAT ONE OF THOSE EXPERTS WAS A QUALIFIED HEMATOLOGIST/ONCOLOGIST
.....31
 
CONCLUSION
.................................................................................................... 33
 
APPENDIX

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