Legal Document Type: Legal Motion: EMERGENCY MOTION FOR TEMPORARY CUSTODY AND EX PARTE RELIEF

Case Information: Case 25DM781 | Status: Pending

Document Content:
EMERGENCY MOTION FOR TEMPORARY CUSTODY AND EX PARTE RELIEF
  I. EMERGENCY BASIS
  1. Petitioner respectfully moves this Court to grant temporary sole legal and physical custody of Felix Day Salmon, age 2, on an emergency basis.
  2. The child is currently suffering from daily untreated allergic reactions, presenting in the form of coughing, congestion, and respiratory distress.
  3. The mother, Crycella Elizabeth Freitag, has refused to take Felix to an allergist or seek treatment, despite repeated symptoms and parental requests, constituting ongoing medical neglect.
  4. Crycella has demonstrated a pattern of abuse, interference, and contempt of court, including but not limited "to":
  Attempting to abduct Felix in June 2024 and calling the police to enforce an unlawful relocation to Kansas, directly violating the court’s jurisdiction and parental agreements.
  Willfully destroying and interfering with Felix’s communication with Petitioner by refusing all contact, confiscating devices, and failing to honor phone time—despite Petitioner allowing Felix free and unrestricted access to a phone and tablet.
  Ignoring multiple court orders without consequence, including orders regarding custody, communication, and medical care, while the court has failed to act—raising serious concerns of racial bias and systemic neglect of due process.
  5. Crycella has also exposed Felix to unsanitary and unsafe living conditions (previously documented in filings and hearings), and cold weather without appropriate clothing or shelter, directly contributing to his respiratory symptoms and physical discomfort. These repeated actions reflect a proven and escalating disregard for Felix’s health, safety, and well-being. Petitioner believes immediate intervention is necessary to prevent further harm.
  II. JURISDICTIONAL STATEMENT
  Felix has resided in Kansas for 25 out of the past 29 months.
  The Missouri court (Stone County Case No. 24SN-DR00104) has not issued a valid custody order.
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