Legal Document Type: Legal Motion: EMERGENCY MOTION FOR JUDICIAL NOTICE OF PROCEDURAL DEFAULT, FOR IMMEDIATE TRANSFER OF CUSTODY, AND FOR CLARIFICATION OF JURISDICTIONAL RIGHTS TO PURSUE PERJURY-BASED CLAIMS IN KANSAS

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

Document Content:
COMES NOW, the undersigned Petitioner, Micheal Lawrence Salmon, and respectfully moves this Court to take Judicial Notice of Procedural Default and to immediately issue an order for full custodial transfer of the minor child, Felix Day Salmon, to Petitioner, for the reasons stated "below":

I. PROCEDURAL DEFAULT & ABANDONMENT OF DUTY
The Guardian ad Litem originally appointed by this Court, Brooke D. Gibson of Rooney McBride & Smith, LLC, has filed a formal decline of appointment dated April 18, 2025, citing fabricated conduct unsupported by fact and in direct contradiction to recorded interactions now entered into evidence.

No substitute Guardian ad Litem has been appointed since her declination, despite this Court being aware of the urgent necessity due to the pending final hearing, serious allegations of parental alienation, and legal misconduct affecting the welfare of the child.

This failure constitutes a procedural default under Missouri Supreme Court Rules 68.01 and Rule 129.02, as the child's right to representation has been effectively ignored by the Court for over 70 days since the initial order.

II. EVIDENT COLLUSION, PERJURY, AND JURISDICTIONAL SPILLOVER FROM KANSAS
Petitioner provides notice that matters arising from this case are not confined to Missouri jurisdiction. A series of acts involving fraud, perjury, and collusion�including testimony and sworn statements by Carolyn Salmon, the Layne Project, Crycella Freitag, Stephanie Reed, Natasha Kluttz, Kelly Truelove and Jozef Hanratty�are directly tied to the deprivation of the Petitioner�s parental rights.

These acts occurred primarily in Wyandotte County, Kansas, where Felix resided for the majority of his life, and where multiple witnesses lied to both courts and law enforcement to create the false appearance of instability.

Regardless of Missouri's continued silence, Petitioner reserves all rights to prosecute and subpoena individuals under Kansas law and intends to pursue civil and crimi