Counter Motion for Appointment of Guardian Ad Litem
Respondent, Ted Jeczalik files this Counter Motion against appointment of Guardian Ad Litem and states as follows:
1. Child related issues are important issues in this case.
2. The following children who are involved in this action have been born to the parties and were not adopted:
Name Date of Birth
Caroline Jeczalik September 9th, 1997
Paulina Jeczalik May 31, 2002
Lukasz Jeczalik August 4, 2003
3. The interest of the children who are subject of this counter motion would be best served if the court order stop to the abuse of the children by the Petitioner, Anna Michalik who does not allow the children to see the father giving them psychological stress and unnecessary mental pain.
4. The psychological behavior of Petitioner, Anna Michalik does not serve well being for the children and appointing Guardian Ad Litem will give the children additional stress as the Respondent, Ted Jeczalik have given the children always psychological comfort and provided for their well being and no Guardian Ad Litem can have better interest for the children then Ted Jeczalik, the father of the children. Guardian ad Litem can not know the facts of the children being abuse by the mother, Anna Michalik and her falls information she states in the court of law since 2010 such as no payment of child support by Ted Jeczalik when in fact Ted Jeczalik always paid child support.
5. By appointing by the Court any Guardian Ad Litem for the children, the Petitioner will further alienate the children from their father and the children will receive emotional stress from a Guardian Ad Litem that is not familiar with Petitioner, Anna Michalik child abuse.
Wherefore, Respondent respectfully requests this honorable Court not to appoint a Guardian Ad Litem to represent and protect the interest of the children subject to this action, and further order stop the petitioner, Anna Michalik from her abuse of the children by allowing the father to see the children without any restriction to serve the children best interest instead of any Guardian Ad Litem.
Respondent / Husband / Ted Jeczalik is financially unable to pay for any Guardian Ad Litem as submitted to the Court Income Tax Statement in 2012 is showing income not able to pay for any Guardian Ad Litem.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy hereof has been furnished by mail
delivery to the persons listed below this 20 day of April, 2012.
Audrey A. Jefferis, Esquire
8138 Massachusetts Ave.,
New Port Richey, FL 34653
Tel. 727-845-6174, fax 727-848-3091
Attorney for Petitioner
Ted Jeczalik, Respondent / Husband
P.O. Box 248,
Port Richey, FL 34673
Telephone No. 727-641-6709,
Fax 866-395-0966, Email: [email protected]