Legal Document Type: Legal Motion: MOTION TO STRIKE UNILATERAL PSYCHOLOGICAL EVALUATION AND REQUEST FOR COURT-APPOINTED NEUTRAL EVALUATOR

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

Document Content:
COMES NOW, Movant, Micheal Lawrence Salmon, and respectfully moves this Court to strike any outstanding order or implication requiring participation in a psychological evaluation conducted by Midtown Psychological Services, and in support thereof, states the "following":

1. Procedural Background
On or about February 26, 2025, Movant was contacted by Midtown Psychological Services, stating they had been contacted by Sarah, an associate of the Garrett Law Firm, and had been assigned to conduct a psychological evaluation of Movant allegedly pursuant to a court order.
The provider confirmed the initial communication came solely from Respondent’s legal counsel, with no record of direct court appointment or oversight. Further, Respondent Crycella Freitag personally paid for the evaluation, a clear breach of neutrality and procedural integrity.
Movant immediately requested written clarification regarding the referral process, scope of evaluation, and the provider’s neutrality. No clarification or court confirmation was received.

2. Midtown Psychological Has Withdrawn
On April 9, 2025, Movant contacted Midtown Psychological Services. During this call, a representative from their office stated that Midtown Psychological has formally declined to be involved in this case and has requested that the Garrett Law Firm not contact their office again.
The provider’s withdrawal confirms that the original evaluation order was not arranged through a neutral process, but instead unilaterally initiated and funded by Respondent and her legal team.

3. Request for Court Relief
Movant is not opposed to participating in a psychological evaluation so long as it "is":
Court-appointed through a neutral selection process, and
Conducted by an evaluator with no prior affiliation with either party.
In light of these developments, Movant respectfully requests that the "Court":
Strike any evaluation order referencing Midtown Psychological or resulting from unilateral appointment by Respondent’s cou