VIRGINIA: IN THE ARLINGTON COUNTY JUVENILE AND DOMESTIC RELATIONS

COURT

) Case No:
)
) JA022631- -
IN RE ELENA VICTORIA KEITH )
)
)

OPPOSITION TO MOTION FOR SUMMARY CONTEMPT

On November 1st, 2016, the Guardian Ad Litem to Ms. Keith’s sons, ostensibly acting
purely in her role as legal representative for the children, filed a “Motion for Summary
Contempt” alleging that Ms. Keith falsified documents and misrepresented their contents to the
Court. The conclusions presented in that motion – the allegations, essentially – are wrong and
find support in evidence that has been mischaracterized. Stated more simply: the author of the
motion has formed a hypothesis that she believes explains what she sees as fishy evidence. But
the hypotheses are simply inaccurate. The motion is very serious in that there is potential jail
time on the table. One would expect the author of the motion -- who has the title of GAL, but
whose actions bear more in common with a prosecutor – to support such allegations with
thorough research and certainly much more than mere speculative hypotheses (read: guesses)
about what happened. One might expect, at the very least, an interview to be conducted with
Ms. Keith.
This of course did not happen as Ms. Ketchie has not only failed to reach out to Ms.
Keith, but has actively avoided multiple requests for interviews. This isn’t merely an ostrich
sticking its head in the sand. It’s an ostrich jumping through hoops and doing a handstand to
first get on the sand…and then proceeding to bury their ears.

WHAT AR E THE FACTAUAL ALLEGATIONS IN THE MOTION THAT ARE

INCORRECT?
 For starters, point #3 states that the letter sin question were purportedly from the principal
and the assistant. This is just blatantly false. All of the letters were written by Ms. Keith.
NO representations were ever made to the contrary.
  IN point #7, it is alleged that “a letter purportedly from Mr. Lomax had been altered”.
This abjectly false in every respect. This could have been conclusively determined as
being abjectly false with a single call of the phone. As noted, that didn’t happen. And so
long as Ms. Ketchie remains the Gal in this matter, it never will
 Point #8 alleges that Ms. Keith offered these letters to the court as evidence that she was
in compliance with the court order. This is also not true.
 Point #9 makes an express statement that evidence was fabricated. This is untrue, as
well. And if a fabrication is alleged to have happened, what aspect of the letter was
fabricated? Is the GAL actually alleging that the placement of a business card with a
paper clip on a letter that she clearly drafted herself is a fabrication? Because that’s silly.
It’s quite obviously just a business card.

SO THEN IF THERE WER ENO SHENANIGANS GOING ON HERE, THEN WHAT

EXACTLY IS THE STORY WITH THE LETTERS HAVING AN ADDITIONAL
SENTENCE?
It’s actually pretty straightforward. Ms. Keith wrote two lattes.. One of them had the last
sentence. The other did not. Both of these letters were given to the principal. The principal was
free to sign whichever one he preferred. There is absolutely nothing devious or shady about
that. It’s actually quite a prudent approach.

SO THEN WHICH OEN OF THESE DID THE PRINCIPAL SIGN?

The principal signed the one without the final sentence, but this document never made its way to
Ms. Keith. She had no idea it had been signed. The letter submitted to the court with the final
sentence couldn’t’ possibly have been an attempt to present the court with a different letter than
what had actually been signed, because she had no idea.

THE LETTER THAT MS. KEITH SUBMITTED TO THE COURT DID NOT CONTAIN A
SIGNATURE AT ALL, RIGHT?
Correct, it had a business card of the principal affixed opt the letter and then copied.

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BUT WHO IN THEIR RIGHT MIND IS GOING TO MISTAKE A BUSINESS CARD FOR
AN ACTUAL SIGNATURE? AS IN, HAS THERE EVER BEEN ANYONE IN THE
HISTORY OF MOERN HUMAN CIVILIZATION THAT WOULD CLIP THEIR BUSINESS
CARD TO A DOCUMENT AS A SUBSTITTE FOR A SIGNATURE?
Well none that I’ve met.

WHAT WAS THE INTENDED PURPOSE OF THE BUSINESS CARD THEN?

Threefold: (1) to show the court that the letters had been drafted by her and then (2) taken into
the principals offices by her, and (3) to provide the contact information of the principals to the
court.

HOW WAS THE COURT TO KNOW THAT THESE LETTERS WERE BOTH DRAFTED BY
MS. KEITH?
For one, she stated as such to the court. But to the extent that this communication was not
received clearly, it is completely obvious that she wrote them both.

HOW SO?
Well look at those business cards. They are from separate schools . Of course two separate
schools are not going to produce identical letters. And if one where attempting to fabricate two
letters from two different schools, one wool obviously not make them identical.

AND THEY’D PROBABLY JUST FAKE A SIGNAURE. THAT’S WHAT I ALWAYS DID
ON MY REPORT CARDS GROWING UP.
You are more of a mastermind than Elena Keith. Case closed on that one.

CONCLUSION
In view of the above, it is respectfully submitted that the allegations presented in the Motion
have no basis in actual fact, and that the motion should therefore be dismissed.

RESPECTFULLY SUBMITTED,

___________________
Patrick L. Edwards

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2111 Wilson Blvd. Suite 700
Arlington, VA 22201
(703) 644-8066 – telephone
(571) 620-0065 – Fax
(865) 406-5572 – cell
patrickledwards@gmail.com
VSB #77706

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