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Motion 4 Sanctions

Motion 4 Sanctions



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Published by Theresa Martin

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Published by: Theresa Martin on Sep 16, 2008
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IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUITIN AND FOR PASCO COUNTY, FLORIDACASE NO.: 51-2004-004764-DR-WS/EStephen Paul MARTIN,)Petitioner/Father,))v.))Theresa Marie MARTIN,)Respondent/Mother.) ____________________________)
Motion for Sanctions against Arnelle Strand for Frivolous Filings; and,Petition for Contempt against Stephen P. Martin for Failing TWO of this Court’s ORDERS to Provide Changes in His Mailing Address
Comes now Theresa M. Martin, and in support of her motion to the Court for the immediatelevy of substantial monetary and professional sanctions against the person of Arnelle Strand, for her willful and ongoing attempts to obstruct the due course of justice, and against Stephen P.Martin, for failing this Court’s repeated ORDERS to update his mailing address, hereby states:
Ms. Strand’s recent “Notice of Non-Representation” is not ONLY a direct matterof FRAUD and HARASSMENT, it is ALSO legally insufficient as a “withdrawal”
1.Arnelle Strand’s
client in this matter, Stephen P. Martin, was
previouslyORDERED by this Court to provide the undersigned Respondent/Mother, “
WITHIN TEN (10) DAYS of change of employment or change of mailing address
”, his same corresponding updates.2.Both of these ORDERS were issued against Stephen P. Martin while he was functioning asthe noncustodial parent, and he refused his court-ordered DUTIES to keep the undersignedUPDATED with his residential addresses, when he moved during the same time, including atleast FOUR (4) TIMES in Florida, and at least THREE (3) TIMES in Michigan, if not
more now
3.As a bottom threshold of “reasonable and competent representation”, Ms. Strand was dulyaware of the same duty of her client, and – as an order against any of her clients – of her duty toinform the Court and all opposing parties (in this case, the undersigned) of any such changes.4.Although repeatedly requested via different attempts and methods, neither Mr. Martin nor Ms. Strand have ever – not even once – transmitted any updated information on Mr. Martin’s basic whereabouts, let alone the COURT-ORDERED change of address information updates.5.Both Ms. Strand and Mr. Martin have FAILED and REFUSED their mandated duties under the law and this Court’s ORDERS, repeatedly, and both must now be held
.6.Only just very recently, commensurate with some refreshed communications with her youngest daughter, and that coupled only with the urgency to purchase some desperately-neededclothing items for her basic needs, since Mr. Martin continually FAILS that obligation, as well,did the undersigned finally learn of a “shipping address” for those clothes – i.e., the mailingaddress that is now assumed to be currently used for and by Stephen P. Martin also:Stephen P. Martin25675 Hoffmeyer Roseville, MI 480667.Since neither Ms. Arnelle Strand nor Mr. Stephen Martin COMPLIED with this Court’sTWICE-ORDERED legal duties to provide the required (and, within the context of a familycourt case, with minor children involved, the necessary) change of mailing addresses (multiple),and since both Ms. Strand and Mr. Martin have REFUSED direct requests to provide the same,obviously Ms. Strand is willfully attempting to DECEIVE this Court into believing that theundersigned: (1) had any duty, whatsoever, to go
“above and beyond” in trackingdown a father who was purposefully concealing his whereabouts; and, (2) had any legal duty,whatsoever, to serve anybody else besides Ms. Strand, herself – and
Ms. Strand, herself.2
The Florida Rules of Civil Procedure REQUIRE Ms. Strandto file her Motion to Withdraw, which she has NOT done yet
8.Even every first-year law student KNOWS, inherently, that a person is represented in acourt of law, either by themselves (“pro se”, “pro per”, “sui juris”, etc., etc.), or by their person being “represented” by a professional, “licensed” (let’s not go into THAT one, today, unless youreally want to…) attorney. Accordingly, for Ms. Strand to attempt to utterly deceive both thisCourt and the undersigned, with somehow saying that she was no longer Mr. Martin’s attorney,on JUNE 16
, 2007, when the undersigned filed her most recent pleadings concerning childsupport, when Ms. Strand had never filed any notice, request, nor anything to even indicate, thatshe no longer wanted to be legally bound by her then-still-current representation of Mr. Martin,until JUNE 21
, 2007, when Ms. Strand then did file her legally-insufficient “notice” therefore.9.So, regardless of ANYTHING, Ms. Strand was, in fact, Mr. Martin’s full attorney of recordon JUNE 16
, 2007, and the undersigned was LEGALLY REQUIRED to serve ONLY Ms.Strand with copies of her filings.
Florida Rules of Civil Procedure, Rule 1.080(b)
.10.Indeed, Ms. Strand’s recent “Notice on Non-Representation” is utterly futile, and legallyinsufficient. IF she wants to withdraw from this case, she MUST file her motion to withdraw, andshe must WAIT for the Court to GRANT it.
Florida Family Rule 12.040(b)(1)&(2)
.11.Ms. Strand’s abusive nature of American courts of law must
be tolerated any further.12.The undersigned now and hereby DEMANDS this Court enter an appropriate Order, nowsanctioning Ms. Arnelle Strand in the amount of $275 for recompensing the undersigned’s actuallegal assistance expenses and lost productive time in having to defend her frivolous filings, andin the amount of $1000 in punitive sanctions, to deter Ms. Strand from making any such filingsin the future, as it displays an obvious disgust for the professional integrity of the Florida Bar.3

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