Legal Document Type: Legal Petition: PETITION FOR IMMEDIATE ACCESS TO MINOR CHILD AND REQUEST FOR EMERGENCY HEARING

Case Information: Case 25DM781 | Status: Pending

Document Content:
PETITION FOR IMMEDIATE ACCESS TO MINOR CHILD AND REQUEST FOR EMERGENCY HEARING
  COMES NOW the Petitioner, Micheal Lawrence Salmon, biological father of Felix Day Salmon, and respectfully requests this Court to immediately grant temporary custodial access and set an emergency hearing regarding the welfare of the minor child, Felix Day Salmon. Petitioner has been denied all contact with his son for over three months due to a combination of jurisdictional confusion and procedural failures in an out-of-state proceeding. The result has caused severe emotional harm to both father and child and continues to violate Petitioner’s fundamental parental rights.
  Petitioner respectfully recommends the Court schedule an immediate hearing to award him at least one month of uninterrupted custodial time as a temporary, make-up period for the extensive and unjustified denial of access. Following this, Petitioner requests a fair and full evidentiary hearing to address all matters properly under Kansas jurisdiction. At the previous Missouri hearing, the Petitioner voluntarily produced all financial records, communication logs, and phone data, while the opposing party produced no evidence and was not held to any reciprocal standard. The result was a lopsided proceeding in which no factual rebuttal was considered.
  This Court has both the authority and the responsibility to intervene in the best interests of the child and to correct the procedural imbalance that has thus far deprived both child and father of their right to maintain their familial bond.
  This Court has proper jurisdiction under K.S.A. § 23-37, as both the minor child, Felix Day Salmon, and both parents currently reside within the State of Kansas. Any temporary relocation to Missouri was both recent and not made in good faith, as Respondent had expressed her intention to return Felix to Stone County, Missouri just weeks before the six-month statutory residency mark, suggesting the move was strategic rather than child-c