Legal Document Type: Legal Motion: Motion for Declaratory and Injunctive Relief, with Notice of Anticipated Class Certification Following Discovery

Case Information: Case 25CV325 #6 | Status: Pending

Document Content:
COMES NOW Plaintiff, Micheal Lawrence Salmon (“Plaintiff”), pursuant to K.S.A. § 60-223 and
  Rule 23 of the Kansas Rules of Civil Procedure, and respectfully moves this Court to certify this
  matter as a class action and grant declaratory and injunctive relief as "follows":
  I. INTRODUCTION
  This action arises from the systematic, unauthorized, and procedurally unlawful conduct of The
  Layne Project, Inc.—a third-party entity repeatedly empowered by Kansas courts without
  adequate oversight, transparency, or legal foundation. The Layne Project acted without
  Plaintiff’s consent, outside judicial order, and against explicit, on-record objections. These
  actions caused measurable harm to Plaintiff and, based on extensive research and
  correspondence, a substantial number of similarly situated parents across Kansas.
  In addition, the involvement of outside actors, churches, and witness networks connected to
  court activity—specifically Christ Connect Church and individuals operating under religious or
  informal authority—has led to an expanded pattern of coordinated misconduct.
  This case addresses institutional collusion, witness manipulation, due process violations, and
  covert communication pipelines between unregulated entities and judicial actors—all shielded
  from public scrutiny.
  II. CLASS ACTION CRITERIA
  
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  Plaintiff seeks certification on behalf of all persons within Kansas who, within the last five "years":
  ● Were referred to The Layne Project for supervised visitation, parenting services, or
  custody-related evaluations without opportunity to formally object or without transparent
  documentation of referral;
  ● Were subjected to undisclosed, unilateral communication between The Layne Project
  and judicial actors without notice or consent;
  ● Were subjected to inconsistent and opaque financial practices that masked eligibility for
  fee waivers or falsely imposed financial obligations;
  ● Were subjected to non-gover