ALEXANDER J.

NEIGHBORS
1411 W Megan St
Chandler, AZ 85224
(480) 734-8649

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

AND FOR THE COUNTY OF MARICOPA COUNTY
In Re the Marriage of:
Case No. FC2016-009166
JORDAN NEIGHBORS, ) Case assigned to the Honorable Suzanne Cohen
Petitioner, )
) RESPONDENTS PREHEARING STATEMENT
And ) FOR TEMPROARY ORDERS HEARING
)
ALEXANDER J NEIGHBORS, ) ON DEC 20, 2016
Respondent )

I, Alexander Neighbors herby submit my prehearing Statement for the Temporary Orders
Hearing currently scheduled on Dec 20th 2016.

A. STATEMENT OF UNCONTESTED FACTS

1. The Parties lived together since Dec, 2007 after they were originally married.
2. Respondent is trying to get the Petitioner and respondent into marriage
counseling as it is in the best interest of the Children.
3. Respondent has requested a mental evaluation to get petitioner the mental
health services she needs to help her, so that she can manage and understand the
children’s feelings and needs better.
4. Petitioner holds a Doctorate degree.
5. Respondent holds a Bachelors degree.
6. The Parties Divorced in 2010 but still lived together and remarried FEB 21,
2014.
7. There are 3 children to wit Ayvah Neighbors born 20OCT09 age 7 , Jocelyn
Neighbors born 10SEP2012 Age 4 and Oliver Neighbors Born 28th July2015
Age 1.

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 8. Mother and Father had made family Holiday Travel plans to go visit Jordan’s
family in Idaho. Father agreed to the plans back in Aug before petitioner filed
for divorce because it was a holiday Travel plan for the entire family.
9. Trip to Idaho was supposed to be a fun family trip for Christmas where we all
could be together in Idaho. Ticket exhibit contains The Fathers name is listed as
having a ticket for the flight.
10. Jordan Neighbors is Already a physician, she has already completed her Doctor
training. She is currently trying to achieve a specialty in OBGYN.
11. Respondent Alexander Neighbors has financially supported Petitioner
throughout the entire time she was in medical school to achieve her Doctorates
degree.

B. CONTESTED ISSUES OF FACT AND LAW

1. Legal Decision Making and Parenting Time.
a. Father is concerned for the children’s safety as the mother in law (Children’s
Grandma) will be present in Idaho and she will have unsupervised access to
the children.
b. Petitioner’s paternal Mother (Children’s Grandma) has filed over the past
week 2 independent Child Protection Service Child abuse complaints.
Against Guy Neighbors (Alex’s Father) and Alex Neighbors. When she
files these false complaints it creates unnecessary Harassment to the
Respondent and the Respondents family.
c. Jordan’s maternal Mother (Children’s Grandma) continues to file anonymous
Child abuse reports to CPS. CPS has told me if she keeps filing false reports
they are going to take the children. It’s not right that my children suffer
because of the grandma being out of control.
d. Father is not worried about mother’s activities with the children, but father is
concerned because Jordan’s maternal mother (Children’s Grandma) is going
to be in Idaho at the same time as the children and will be unsupervised with
the children. Yvette Stewart has made comments about absconding with the
children over a year ago when the first Child protective service complaint

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 was filed against Jordan. Yvette said that she would have no problem taking
the children to Idaho and hiding them so that CPS would not be able to take
them from us.
e. Mother has moved to central Phoenix and is currently blaming the Father
because she is not able to be present with the Children in Chandler Arizona.
Yet her own actions and work schedule have caused her to not be present in
the children’s lives.
f. Mother claims that when the father does not allow her to see the children at
or past their bed time and that the father is preventing reasonable access to
the children.
g. Father back in OCT 2016 before the Preliminary injunction was filed
changed the Auto insurance in an attempt to lower monthly expenses and
prevent insurance fraud.
h. Father canceled the Auto policy in OCT 2016 with USAA and opened up a
policy with Gieco.
i. Mother Refused to provide her address in Central Phoenix so father was
forced to use her work address.
j. Father updated the insurance because mother lived in a higher risk city and
father did not want to participate in INSURANCE FRAUD. When a vehicle
is insured in a city that you do not live it is insurance fraud.
k. At No Time was the petitioners Vehicle not insured.
l. Father is a Co-signer for the 2016 Van.
m. Petitioners Health insurance through Tri-care has not been canceled. Jordan
Neighbors can not be legally removed from DEERS and TRICARE until a
divorce Decree is entered.
n. Mother has continually wanted to pick the kids up at 8pm on School nights.
Mother gets upset when she is not able to pick the kids up before their bed
time on a school night. Mother then claims that father is preventing her from
having quality time with the kids. Mother does not understand that the kids
have to be in bed at their bed time or it is extremely hard to get the kids up
and ready at 6:30AM for school.

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 o. When mother left the house on AUG 31, 2016 she gave Final Authoritative
Decision making to the children’s father.
p. Mother Does not keep father informed of her work schedule making it
difficult to setup co-parenting arrangements.
q. Mother’s maternal grandparents Greg and Yvette Stewart have been visiting
with the children this entire time. There is currently an agreement in place
between Greg Stewart and Alex Neighbors. Greg must give me advance
notice he would like to see the Grand kids. He is then able to pick them up
but they must be returned home same day on 7pm for school nights and
8:30pm for weekends.
r. Greg is allowed to pick the kids up from school.
s. Yvette is not allowed to pick up the kids from school. She will on many
occasions pick the kids up without asking or telling the father she has them
in her possession. She also does not get the children to school on time.
t. Mother lives far enough way that she has caused a challenging co-parenting
situation, as she often gets off of work late and it is not reasonable to have
her visit with the kids at their bed time.
u. Father is not trying to keep the children away from mother. Father has gone
out of his way to make sure there is contact between children and mother. By
meeting her at locations away from the house so she can visit with them.
v. Mother tried to have father arrested for an allegation domestic Violence
REPORT# 16-135864. Officer Verdugo arrived on scene to see Mother
squeezing her own arm at the location mother claimed she was grabbed,
Officer Verdugo gave Mother a warning of TRESSPASS. Officer Verdugo
also instructed Father to not allow mother back into the House at 1411 w
megan st Chandler AZ
w. Jordan or Jordan’s Mother continue to file multiple fraudulent CPS reports
against me and my father. This is a violation of the preliminary Injunction
preventing harassment.
2. Temporary Financial assistance.

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a. Petitioner holds a Medical Doctorate degree and has superior income
generating opportunities.
b. If petitioner quit her residency today could work as a family care doctor
making over $200k a year.
c. Father has not cut mothers access to community funds.
d. Mother still has health insurance(Vision, Dental, Life, Health)
e. Mother has vehicle insurance.
f. Mother does not reasonably contribute towards the Children’s living
expenses.
g. Father informed Mother that father is not able to pay for all of the children’s
expenses and then pay for all of Petitioner’s Expenses.
h. Petitioner’s Parents have paid for her attorney and for her new place.
Jordan’s Bank records reflect she has had to pay very little for her own
expenses to date.
i. Petitioner was well aware of the financial situation she would put herself and
family if she rented a $1,300 apartment in central phoenix instead of a $650
apartment in Chandler AZ.
j. Respondent has to do what’s in best interest of the children and ensure they
have everything they need. Paying for Petitioner’s expenses would put
Respondent in a financial hardship.
k. Petitioner is currently qualified to work as a physician. She is not qualified to
work as a OBGYN specialty physician.
l. Respondent needs Petitioner to start contributing more to the children’s
expenses. As currently many of their expenses are being put on credit cards.
m. Petitioner believes that “Guy Madison Neighbors” the Fathers own father is
trying to alienate the children’s relationship with their mother and Maternal
grandparents. This is inaccurate as he has conducted no such activity.
n. Respondent’s Father “Guy Madison Neighbors” came out to provide support
to both the respondent and petitioner for 3 months, without any issues to
report.

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 o. The Trip to Idaho was an entire family trip. It was to spend time together as
a WHOLE FAMILY. Not just to visit a dyeing grandma. This Grandma has
had cancer before 2 or 3 other times in the past.
p. I did not agree for petitioner to take the 3 children to Idaho.
q. Petitioner does not have Extensive ties to Arizona. Her extensive ties are in
Idaho. Her parents are the only 2 people in her family that live in Arizona.
Everyone else lives in Idaho and Washington.
r. Petitioner has not disclosed the dollar amount of the assistance she is
receiving.
3. Attorney Fees. Jordan’s maternal Mother paid the Attorney fee’s. Neither Jordan nor
Alexander Neighbors have the financial means to pay for an attorney as all of the
money Respondent makes goes to supporting, housing, feeding, and raising 3
children on his own. Petitioner’s Attorney Claims mother is unable to continue to
pay for attorney fee’s yet she has not paid any of the fee’s herself from her own bank
accounts, and the documents filed in court show she has not paid any attorney fees
to date.
a. Witnesses
i. Petitioner,
ii. Respondent
iii. Kaitlin N Elsenheimer
iv. Erin Hefley
v. Daniela Degenstein
vi. Yvette Stewart
vii. Renee (owner of the Growing place Preschool)
viii. Guy Madison Neighbors
ix. Officer J. Verdugo
x. Amy Hodgson (CPS Agent)
xi. Stephanie Steward, LMSW (Children’s Counselor)
xii. Attorney Thomas A. Morton
xiii. Any Witness properly disclosed and timely listed by petitioner.
b. Exhibits

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 i. .None
c. SUMMARY OF ALL SETTLEMENT NEGOTIATIONS.
i. None.
d. AFFIDAVIT OF FINANCIAL INFORMATION
Father has not completed the financial Affidavit of financial Information.
frequent allegations of child abuse to Child Protective Services has caused
unnecessary harassment. Every visit was 4 hours or more in the evening.
Each visit resulted in unsubstantiated claims of child abuse and neglect.
Frequent trips to the children’s counselors Stephanie in the city of sun lakes
has also taken away from the time needed to complete the Affidavit of
financial information.
e. SETTLEMENT
i. There has been no settlement between the parties.

Per Rule 14.b: “I declare state under penalty of perjury that the foregoing is true and correct.

Executed on 18th Of DEC 2016”

__________________________________ 12/18/2016

Alexander J. Neighbors

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 Certificate of Service

I hereby certify that a true and correct copy of the foregoing document emailed out to all parties.

Respectfully Submitted

_ Date___18 DEC 2016_______

ALEXANDER J NEIGHBORS

Jordan Neighbors

stewajor@gmail.com