Counter Motion For Psychological Evaluation
Respondent, Ted Jeczalik files this Counter Motion for Psychological Evaluation for Anna Michalik and states as follows:
1. The psychological condition of Anna Michalik is at issue in this case because of erratic and unpredictable behavior in the presence of the minor children, the Husband and the Court including child abuse when Anna Michalik does not allow the children to see the father. The Wife is exhibiting behavior indicating of mental illness which deteriorated during these proceedings where she is involved in violence, waste of marital assets and fraud against the husband that she made homeless.
Ted Jeczalik has evidence of his Medical Exam in January 2012 that does not show any evidence of mental illness and it is another falls information submitted to the court by Anna Michalik accusing Ted Jeczalik of any mental illness.
2. Good cause exists for mental examination of Anna Michalik as the children abuse she exhibits for many years is adversely affecting the minor children. This child abuse by Anna Michalik is being submitted to the court for the second year by Ted Jeczalik who is unable to see his children because of Anna Michalik mental situation that is the cause of her abuse of the children including stealing the children's amusement park annual passes from Ted Jeczalik in March 2012 and not allowing unrestricted visitation for grandparents who came from Europe to help the children.
3. Evidence of Anna Michalik crimes that may be the result of her mental illness has been submitted to the Sheriffs Office in Document ( Pasco County Sheriff's Investigation Case No. 12-16701 for Forgery and Theft of Anna Michalik ) and ( Pasco County Sheriff's Investigation Case No. 120940726 for Anna Michalik waste of marital property ( towed away Ted Jeczalik's Van ) and Anna Michalik Forgery of Ted Jeczalik's signature on notice to the insurance companies or others of representation and assignment form, Sinkhole Public Adjusting, LLC, Kenneth C. Thomas - President, dated 5-21-2010
Above facts shows the need for Anna Michalik psychological evaluation.
4. The cost of the psychological evaluation should be the exclusive responsibility of Anna Michalik as Ted Jeczalik has no means of paying for any psychological evaluation as showed on submitted to the court Income Tax statement in 2012.
5. Because of mental problems of Anna Michalik, Ted Jeczalik can not agree for any requests by Anna Michalik's Motions Requesting Temporary Custody of Minor Child by Extended family.
WHEREFORE, the undersign respectfully requests that this Court issue an order requiring ANNA MICHALIK to submit to a psychological evaluation in reasonable time and place and in the manner and according to conditions set forth by this Court and establish protective rules governing the examination as may be appropriate.
At the same time Ted Jeczalik ask the Court not to take Anna Michalik falls information submitted to the Court in her motion for psychological evaluation of Ted Jeczalik as he takes health exam every other year showing no evidence of any mental illness.
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]