Legal Document Type: Legal Motion: MOTION TO STRIKE DECLINED APPOINTMENT OF GUARDIAN AD LITEM, AND PRESERVE RECORD FOR SANCTIONS AND CIVIL ACTION

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

Document Content:
COMES NOW, Movant, Micheal Lawrence Salmon, and respectfully requests this Court to strike the recently filed �Declination� of Guardian ad Litem Brooke D. Gipson, filed by Rooney McBride & Smith, LLC, in tandem with Ozarks Legal and for the immediate dismissal of Case No. 24SN-DR00104. This Motion is made on the basis of materially false statements, documented misconduct, and ethical violations presented in the filing submitted by Ms. Gipson�s firms. In support of this Motion, Movant states the "following":

1. Procedural Timeline Proves Fabrication
Brooke D. Gipson was appointed Guardian ad Litem by this Court on April 12, 2025.
The Declination, submitted by Rooney McBride & Smith, LLC, states that Movant called the firm "within the last two days before the guardian could even officially accept the appointment"�i.e., April 10 or prior.
Therefore, any interaction alleged occurred before Ms. Gipson�s appointment�when she had no role, duty, or standing in the case.
This alone invalidates the claim of conflict of interest and undermines the entire basis for declination.

2. Recorded Communication Contradicts Their Claims
The firm claims Movant �called multiple times, yelled at staff, and threatened to sue the firm.� This is categorically false.
Every call was recorded. The tone remains professional throughout. No yelling occurred.
The �threat� referenced was a statement that if the firm refused to acknowledge or respond to lawful inquiry, Movant would be forced to subpoena their records and potentially seek legal remedy.
This is not a threat�it is due process.

3. Ethical and Legal Issues with the Filing
The Declination was signed with a typed font signature (Lobster font) rather than a real, verifiable signature from Ms. Gipson. On the back, it was just italics in Arial.
Under Missouri Supreme Court Rule 55.03 and Rule 4-3.3, submitting filings containing falsehoods and improper signatures may constitute sanctionable conduct and grounds for discipline.
The firm�s