The below motion to expose and dismiss the outrageous Kansas Paternity Fraud was filed today. The time has come to stop this nonsense once and for all.
IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT, IN
AND FOR PINELLAS COUNTY, FLORIDA
UCN: 52 2015 DR 001625 FDXX XX
Leah R. Krier,
Spencer C. Young,
MOTION TO CONTEST
Spencer C. Young, respectfully moves this Honorable Court to grant this Motion to Contest for
mistakes of fact concerning whether a delinquency exists, and as grounds therefore would show:
1. This matter represents an outrageous paternity fraud emanating from the state of Kansas, which pursuant to the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), has no jurisdiction. Pursuant to the UCCJEA, the “home state” for the Petitioner and her child during the relevant time-period (i.e., greater than six months prior to the fraudulent filing and thereafter) is North Carolina (NC) . . . NOT Kansas. This clear and convincing fact is readily verified through public records, including: (1) NC Voter Registration; (2) NC Motor Vehicle Registration; (3) NC DMV for Driver Licenses; (4) U.S. Post Office Records; (5) Federal and NC Income tax returns; (6) NC Property tax records (for real estate and automobiles); (7) Phone number, where Petitioner’s phone number has been 919-357-3575 (“919” is a North Carolina exchange); (8) Employment records show since the time before her child was born, Petitioner has been a flight attendant for Air Wisconsin, who has been based out of the Raleigh-Durham Airport in North Carolina; (9) Petitioner’s addresses since her child was born have been: (a) 134 Meadowmont Village Circle in Chapel Hill, NC; (b) 2702 Richmond Road in Durham, NC; (c) 3107 Skybrook Lane in Durham, NC; and currently (d) 1009 Molesworth Drive in Morrisville, NC. Uninterrupted residency in NC of the Petitioner and her child can also be verified by: (i) Dr. Stacy Heath of Harris and Smith in Durham, NC (919-967-8052), who has been Petitioner’s gynecologist since 2007; (ii) Dr. Christopher Morton of Chapel Hill (NC) Pediatrics (919-942-4173), who has been the pediatric physician for the Petitioner’s child since 2008; (iii) Deborah’s Day Care in Durham, NC (919-596-3636) which Petitioner’s child attended; and (iv) the Durham NC Public School System (919-560-3833), where, upon information and belief, the Petitioner’s child currently attends school.
2. The UCCJEA expressly forbids “Jurisdiction Shopping”, which is defined as seeking a jurisdiction that clearly favors one of the parties, and in the matter at hand, the jurisdiction that especially favors the Petitioner is Barton County, Kansas (KS), which is where this egregious paternity fraud emanated. This is a clear instance of jurisdiction shopping because: (1) the Petitioner grew up in Barton County, KS; and (2) Petitioner’s large extended family (e.g., grandparents, parents, siblings, aunts, uncles, cousins, nieces and nephews) all live in Barton County KS.
3. The UCCJEA expressly prohibits imposing “inequitable hardship” for any party, which is defined as holding hearings where one of the Parties in the paternity matter is unable to attend due to: (1) Distance – the hearings were held over 1,000 miles distant from Respondent’s residence; (2) Economic Considerations – as a victim in “the worst bank foreclosure fraud in U.S. history” (a distinction readily verified by Google search), Respondent had insufficient funds to travel to Kansas, nor otherwise able to engage KS-based legal counsel to attend on his behalf; and (3) Emotional Considerations – Respondent’s wife of 24 years had passed away and the hearings were held during the week of her funeral.
4. The Petitioner is a criminal felon, who has committed FIVE instances of grand larceny against the Respondent, where she made off with Respondent’s property valued at $275,000, including a Mercedes Benz S-350 Automobile, Jewelry (e.g., diamonds); Artwork (e.g. Monet, Dali), Computers (e.g., desktops, iPads, laptops); Musical Equipment (e.g., guitars, keyboard piano, amps); Televisions & Sound System (Sony); Furniture (e.g., chairs, chaises, tables); Lighting (e.g., lamps); Kitchenware (e.g., pots, pans utensils, cutlery, glassware); Appliances (e.g., Washer & Dryer); and Clothes & Other personal items of value. Petitioner’s thefts were made possible by a corrupt retired NC judge (David Q. LaBarre), who has been her boyfriend and was recently convicted for drunk driving. In the event paternity did exist, the Petitioner has been prepaid in full by multiples.
5. Paternity does not exist as there is NO DNA evidence of paternity, and Petitioner has a extensive track record of widespread promiscuity.
6. Theft & Malicious Prosecution Lawsuit was filed against Petitioner by Scott Orsini of Orsini & Rose on behalf of Respondent, however O&R filed it in the wrong jurisdiction and failed to achieve any of the objectives he was engaged for. Mr. Orsini was directed to have this paternity fraud dismissed while Respondent completed the book he was writing, Cannibals in White Shoes. When Respondent was no longer able to pay O&R’s mounting bills, Mr. Orsini abruptly resigned leaving Respondent in a compromised position and defenseless.
7. In support of these irrefutable facts, the following website links are incorporated by reference, as the corroborating evidence amounts to literally hundreds of pages, and also comes in the form of pithy information-rich videos: (1) Video summary of the Paternity Fraud http://dai.ly/xkvoue ; (2) FIFTEEN Independent Sources Confirm The Jurisdictional Element Of The Kansas Paternity Fraud http://tinyurl.com/hld7jjf ; (3) Details of the Grand Larceny perpetrated by the Petitioner and her boyfriend (LaBarre) http://tinyurl.com/ort89ef; (4) the list of property stolen by Petitioner and LaBarre http://tinyurl.com/mdz68jz; (5) Conviction of LaBarre http://www.wral.com/longtime-durham-judge-pleads-guilty-to-dwi/15414834/ ; (6) Petitioner’s promiscuity https://www.youtube.com/watch?v=_cm-l1Zzk5g ; (7) Scott Orsini’s Failures to achieve any objectives http://www.morganstanleygate.com/2015/09/scott-orsinis-failures.html; (8) Respondent’s book is currently available on Amazon https://www.amazon.com/dp/B01MRZE464; and (9) the complete details of this paternity fraud can be accessed at http://www.morganstanleygate.com/search/label/Paternity%20Fraud;
Based on the aforementioned mistakes of fact, a delinquency does NOT exist.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy hereof has been furnished by mail to the persons listed below this 14th day of March, 2017.
Leah R. Krier Florida Dept. of Revenue – Largo
1009 Molesworth Dr. 11351 Ulmerton Road #220
Durham, NC 27560-7639 Largo, FL 33778
Telephone No. 919-357-3575 Telephone No. 727-588-6800
Telefax No. n/a Telefax No. 727-588-4921
DATED: March 14, 2017
Signature of party signing certificate and pleading
Printed name: Spencer C. Young
Address: 1194 Lindenwood Drive
Tarpon Springs, FL 34688
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