Legal Document Type: Legal Motion: MOTION TO COMPEL FREITAG TO COMPLY WITH FEBRUARY 25 ORDER & STRIKE FALSE NOTICE

Case Information: Case 24SN-DR00104 | Status: Pending

Document Content:
NOW COMES Movant, Micheal Salmon, pro se, and respectfully moves this Court "to":
Compel Counter-Respondent Freitag to immediately schedule and pay for Movant�s psychological evaluation as ordered by this Court on February 25, 2025.

Strike the fraudulent statement in the March 26 Notice of Entry, which incorrectly claims that Movant was ordered to "file" a psychological evaluation.

Sanction Counter-Respondent Freitag and Attorney Garrett for their noncompliance with the Court�s February 25 order and their misrepresentation to the Court.

GROUNDS FOR RELIEF
The February 25, 2025 Order Clearly Required Counter-Respondent Freitag to Arrange and Pay for the Psychological Evaluation.

 The Court�s original order (Exhibit A) specifically "states":
 "Counter-Respondent (Freitag) shall arrange and pay for Movant�s psychological evaluation."
 Despite this explicit directive, Counter-Respondent Freitag has failed to comply for over 30 days. Nevertheless, the March 26 Notice of Entry falsely states that Movant was ordered to obtain the evaluation, thus inaccurately portraying Movant as noncompliant.

Judicial Fraud on the Record.

 The March 26 Notice "claims":
 "Movant was ordered to obtain a psychological examination on February 25, 2025."
 This statement is demonstrably false. As the attached order (Exhibit A) clearly indicates, the responsibility to arrange and pay for the evaluation was placed on Counter-Respondent Freitag, not Movant. This misrepresentation has prejudiced Movant by casting a false light on his compliance with court orders.

Delegation of Judicial Responsibilities to Opposing Counsel.

 In a recent phone call with the Clerk�s Office (Exhibit C), the Clerk "confirmed":
 "The judge said you need to contact Mr. Garrett for next steps."
 This is a violation of Missouri Code of Judicial Conduct 2.2, which prohibits judges from delegating their judicial responsibilities to opposing counsel. Mr. Garrett has no legal authority to dictate the Court�s orders