Legal Document Type: Legal Petition: COUNTER-PETITION FOR SOLE CUSTODY

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

Document Content:
COMES NOW the Respondent, Micheal Lawrence Salmon, and pursuant to Missouri law, files this
Counter-Petition for Sole Custody in response to the original petition filed by Crycella Elizabeth Freitag,
respectfully requesting the Court to consider the "following":
1. Procedural Background
a. Parties
? Respondent/Counter-"Petitioner": Micheal Lawrence Salmon, biological father of Felix Salmon
? Petitioner/Counter-"Respondent": Crycella Elizabeth Freitag, biological mother of Felix Salmon
? "Child": Felix Salmon, born 12/20/2022
b. Jurisdictional Basis
Pursuant to Missouri Revised Statutes Chapter 452, this Court maintains jurisdiction over the parties and
subject matter, "as":
? The minor child resides within the state of Missouri
? Both parties have submitted to the jurisdiction of this Court
2. Remote Appearance Request
Respondent/Counter-Petitioner respectfully requests permission to participate remotely via WebEx in the
upcoming hearing scheduled for 01/03/2025 and 01/10/2025 due to the following substantive "reasons":
Compelling Circumstances
1. Childcare "Constraints": Limited alternative childcare options
2. Time "Limitations": Minimal preparation time and work schedule restrictions
3. Geographic "Challenges": Approximately four-hour travel distance from Respondent's residence
3. Grounds for Sole Custody
A. Established Caregiving History
Respondent's Primary Caregiving "Role":

? Served as primary caregiver for Felix since birth
? Provided consistent, stable home environment
? Made significant personal and professional sacrifices to support the child's well-being
? Implemented structured educational and developmental support
B. Petitioner's Parenting Deficiencies
Documented Challenges in Petitioner's "Parenting":
? Chronic financial irresponsibility
? Consistent pattern of neglectful behavior
? Repeated extended absences from child's daily life
? Unstable living arrangements
? Minimal financial or emotional contribution to child's upbringing
C. Living Environmen