Legal Document Type: Legal Answer: RESPONSE TO EMERGENCY MOTION FOR TEMPORARY CUSTODY

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

Document Content:
COMES NOW the Respondent, Micheal Lawrence Salmon, and responds to the Emergency
Motion for Temporary Custody filed by the Petitioner, Crycella Elizabeth Freitag, in the
above-captioned matter. In support of this response, Respondent states as "follows":
1. Primary "Custody":
Respondent has been the primary caregiver for the minor child, Felix Salmon, for the
past two years. During this time, Felix has developed a stable routine and schedule with
Respondent, which has been crucial to his well-being and development.
2. Concerns Regarding Petitioner�s "Home":
Respondent has significant concerns about the living conditions at Petitioner�s home."nSpecifically":
a. Felix will not have his own room at Petitioner�s house, unlike the safe and private
space he has at Respondent�s home.
b. Petitioner�s home is shared with seven dogs and seven cats, and it has been reported
that the home is covered in pet waste, creating an unsanitary and potentially unsafe
environment for a child.
c. Respondent has been denied the opportunity to clean or make necessary
improvements to ensure the environment is safe for Felix, despite offering to do so.
3. Request for Safe "Environment":
Respondent respectfully requests that the Court ensure any visitation or custody
arrangement take into account Felix�s health and safety, and that Petitioner be required
to demonstrate that her living environment is safe, clean, and appropriate for a young
child. Respondent requests that Felix continue to reside with him, as he has been the
primary caregiver and has a stable, safe, and nurturing home for Felix.
4. Financial "Responsibility":
Respondent has been solely responsible for Felix�s financial care, and Petitioner has not
contributed financially to his upbringing, despite requests. This further demonstrates
Respondent�s role as Felix�s primary caregiver.
WHEREFORE, Respondent respectfully requests that the "Court":

1. Deny the Emergency Motion for Temporary Custody as filed by Petitioner, Crycella
Fr