Legal Document Type: Legal Motion: EMERGENCY MOTION FOR JUDICIAL CORRECTION, HEARING REQUEST, AND SANCTIONS FOR MISREPRESENTATION OF COURT-ASSOCIATED PROVIDER

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

Document Content:
COMES NOW, the Movant, Micheal Lawrence Salmon, appearing pro se, and respectfully moves this Court to take immediate judicial corrective action and schedule an emergency hearing in light of ongoing violations of due process, false representations made by opposing counsel regarding third-party service providers, and the resulting deprivation of Movant’s custodial access. In support thereof, Movant states the "following":

I. IMMEDIATE "ISSUE": USE OF NON-EXISTENT ENTITY TO OBSTRUCT REUNIFICATION
The entity referred to as "KidCentric" has been referenced in prior discussions related to court-ordered services or evaluations in this case.
Upon investigation, there is no active or registered business operating under the name "KidCentric" in the State of Kansas. The only such entity was forfeited and administratively dissolved.
Movant was placed in a position of relying on this non-existent provider for crucial services affecting his custodial rights, including but not limited to visitation facilitation and psychological evaluation pathways.
This constitutes material misrepresentation by opposing counsel and/or a grave procedural error by the Court, as no party should be ordered or expected to comply with an order that references a defunct or non-operational entity.

II. EVALUATION PROVIDER IS REFUSING CONTACT DUE TO JOSH GARRETT
The Court additionally ordered Movant to obtain a psychological evaluation through Midtown Psychological Associates, and threatened contempt if he failed to comply.
Movant made every good faith effort to schedule said evaluation; however, Midtown Psychological Associates has explicitly refused to provide services due to their refusal to work with Garrett Law Firm, who represents Respondent.
This renders the evaluation directive legally and practically impossible to comply with, through no fault of the Movant.
Yet, Movant remains under the implied threat of contempt and suffers continued separation from his son, Felix, without legal basis.

III.