Souad, I have reviewed the motions completed by Geoff. To have a better opportunity at success in the motions, we need to submit evidence in support of them. I recommend you collect the following evidence so we can append it to the motions. 1. Motion to enjoin girlfriend from being at the exchange location. a. Is there a transcript or order that supports the statement that the referee ordered that the girlfriend is not a suitable party? b. Geoff states in paragraph 5 that he contacted Pickney’s attorney to ask her not to allow Geoff to bring the girlfriend around. Did Geoff do it by email? If there is an email or correspondence we should append it to the motion. 2. Motion to prohibit taking the children to CA a. The doctor’s report says nothing about what caused the rash. It could be as a result of normal activity that any child would engage in and not from negligence of the parent. Without more this motion appears frivolous. We will lose credibility with the court. Speak to the doctor or get me his or her name so I can speak to him. He should write a letter to specifically say what the diagnosis is and what, in his medical opinion, caused the rash. Without that the evidence in support of this motion is of no relevance to the issue b. Please provide a copy of your phone record either cell or landline that shows the calls that were made from your phone to Pickney’s during the period when he had the children. Without evidence it is just going to be your word against his. c. In paragraph 3, the motion states that the petitioner rarely saw the children. Instead of telling the judge/referee that he rarely saw the children, let’s show him. Do you have a record of when he picked up or saw the children? If you do not, it is going to be your word against his. d. Do you have anything from Pinckney that states he intends to have the girlfriend’s son take care of the children, or someone besides you who heard him say it? If not, we have to be prepared for him to deny it. And if he doesn’t deny it, he’s going to say that you misunderstood what he said. Please let me know if you have the evidence I am asking for. Without it, these motions will be denied or will become moot because he will just say I will not bring girlfriend around and no one will care from the children but me, regardless of the truth. Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO The Law Firm of Puckett & Faraj, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax DETROIT METRO The Law Firm of Puckett & Faraj, PC 835 Mason Street Suite 150-A Dearborn, MI 48124 313-457-1390 Phone 202-280-1039 Fax The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. |