IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT,
IN AND FOR PASCO COUNTY, FLORIDA

Case No.: 51-2010-DR-5308-WS
Division: Z1
                                  
                    ANNA MICHALIK,
                    Petitioner/Wife,

                               and
                                                              
                        TED JECZALIK
                      Respondent/Husband

_________________________________________/                                                                                                                                                                                                                   
    
Husband's Second Counter Motion For Contempt

Answer

Respondent, Ted Jeczalik files this Second Counter Motion for Contempt against Anna Michalik and states as follows:



1.
Anna Michalik violated STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS before it became court order.  Because Anna Michalik violence and violation of STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS, Ted Jeczalik canceled STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS sending Anna Michalik cancellation notice. Ted Jeczalik also filed 3 times in the court motions in this matter:
  Anna Michalik Reconciliation Contract, Agreement, Court Stipulation was Cancellation dated  7-7-2012 and submitted to Petitioner.
 (C2) MOTION TO/FOR FRAUD AND RECONCILIATION AGREEMENT CANCELLATION dated 11-7-2011,
 (C3) MOTION TO/FOR CANCELLATION AND INVALIDITY OF STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS dated 1-30-2012
 (C4) MOTION TO/FOR CANCELLATION AND INVALIDITY OF STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS dated 3-21-201
Above documents were submitted to the Honorable Court and to the Petitioner and never were allowed for hearing.

2. On April 5, 2012, Ted Jeczalik filled in the court 
MOTION TO COMPEL DISCOVERY FOR REPORT AND RECOMMENDATION OF GENERAL MAGISTRATE and is waiting for hearing, showing additional evidence about Anna Michalik fraud where Anna Michalik  used incorrect information giving General Magistrate falls judgment.

3.
MOTION TO/FOR CANCELLATION AND INVALIDITY OF STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS was canceled before it became court order because of Anna Michalik violation of the stipulation therefore:

A. The Wife, Anna Michalik fraudulent entry to stipulation was to extort $1500.00 per month from Ted Jeczalik and not reconciliation with her husband Ted Jeczalik. Cancellation of stipulation and 3 motion for cancellation of stipulation are on file as evidence. Because of fraudulent activity of Ann Michalik and stipulation cancellation, Ted Jeczalik does not have any obligation to pay Anna Michalik $1500.00 especially when his Income Tax Statement submitted to the court in February 2012 does not allow for such payments as he also pays on regular basis child support. In addition, Anna Michalik violence and stipulation violation resulted in Ted Jeczalik prolong homelessness and substantial income loss.

B. Ted Jeczalik does not have any obligation to obtain Life Insurance as stipulation was canceled and Anna Michalik violent and fraudulent activity endangers Ted Jeczalik life therefor it is unconstitutional to order Ted Jeczalik to purchase life insurance when his life is endanger by Anna Michalik as beneficiary of life policy.

4. The Respondent has not willfully and intentionally failed to comply with the  MOTION TO/FOR CANCELLATION AND INVALIDITY OF STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS as stipulation was canceled by Ted Jeczalik, 3 motion for cancellation of stipulation were submitted to the court and Ted Jeczalik's income does not allow for paying Anna Michalik $1500.00 for unspecified support.

5. The Respondent submitted Income Tax statement in 2012 showing income that lowered child support monthly payments according to Florida Statue and table showing child support according to the amount of income.

6. Respondent has not willfully and intentionally failed to comply with the MOTION TO/FOR CANCELLATION AND INVALIDITY OF STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS as Ted Jeczalik's life became endangered by Anna Michalik violent and fraudulent activity.  It is unconstitutional for Ted Jeczalik to obtain life insurance when currently his life is endangered by Anna Michalik as beneficiary of life policy.


7. For RECOMMENDATION OF GENERAL MAGISTRATE, Ted Jeczalik submitted
on April 5, 2012,  MOTION TO COMPEL DISCOVERY FOR REPORT AND RECOMMENDATION OF GENERAL MAGISTRATE from which it shows that: 

A. Respondent, Ted Jeczalik use only the truth in evidence and the truth in evidence was published on line with good motives, therefore Ted Jeczalik used his constitutional right to use truth in evidence and Report and Recommendation of General Magistrate have no legal standing. In addition there is password protection for other viewers of Ted Jeczalik's on line truth in evidence on his web site.

All correspondence sent by Respondent, Ted Jeczalik have copies of original evidence of Petitioner Anna Michalik crimes involving forged signature on business checks, bank's statements and  property insurance  that was investigated by Pasco County Sheriff's Investigation Case No. 12-16701, 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.


Ted Jeczalik reserve the constitutional right under Article 1st of the American Constitution And Florida Constitution in SECTION 4 : "Freedom of speech and press
is stating that Every person may speak, write and publish sentiments on all subjects but shall be responsible for the abuse of that right. No law shall be passed to restrain or abridge the liberty of speech or of the press. In all criminal prosecutions and civil actions for defamation the truth may be given in evidence. If the matter charged as defamatory is true and was published with good motives, the party shall be acquitted or exonerated."

B. All material on Ted Jeczalik's Web Site use only the truth in evidence and the truth in evidence was published on line with good motives, therefore Ted Jeczalik used his constitutional right to use truth in evidence and there is password protection for other viewers of Ted Jeczalik's on line truth in evidence therefore all allegation of Anna Michalik are unconstitutional and unfound as all files on Ted Jeczalik are protected with user name and password and Anna Michalik again use incorrect information against ted Jeczalik in court of law.
8.
Respondent does not afford any lawyer's fees and because of wrongful actions of Petitioner, Respondent lost substantial time from his work incurring additional losses of income because of Petitioner incorrect information being submitted in latest Wife's Second Motion for Contempt.

9. Respondent does not agree with Petitioner Motion for Temporary Custody of Minor Child by Extended Family as the Petitioner in involved in many criminal activities that were investigated by Pasco County Sheriff:


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 pre marital assets - Vehicle Plymouth Voyager, 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, are showing that according to Florida Statues Ch. 61.075(5) a court may order an interim partial distribution upon good cause. The Petitioner has shown that good cause does not exists as the Petitioner, Anna Michalik has showed criminal activities and fraud used to obtain all marital property that she use exclusively since September 1, 2010. The Responded was a victim of Petitioner as Anna Michalik violence and criminal activities made Ted Jeczalik homeless and lowered means of earning money. Responded Ted Jeczalik can not cooperate in fraudulent and criminal activities of Petitioner Anna Michalik

10.  Anna Michalik still use lot of different names in all her illegal allegations against Ted Jeczalik including court documents, bank and insurance financial fraud. Anna Michalik has in her possession Certificate of Marriage ( License Number 9706855-0 ) where her name is different then she use against Ted Jeczalik. Ted Jeczalik  has current evidence from Cook County, State of Illinois, Vital Statistics as Certification of Marriage states her legal name as of 4-2-2012 is Anna Agnieszka Michalik.

All Court Documents, Bank of America and insurance document shows Anna Michalik Fraud as she use different first and last names including Ted Jeczalik last name.  This evidence shows that Anna Michalik is using illegally her name using fraud in Court of Law, Bank and Insurance companies. Current mortgage from Bank of America shows Ann Michalik Jeczalik and Sinkhole fraud show different combination of names for Anna Michalik.


In Stipulation from May 17, 2011 Anna Michalik used name as Anna Michalik Jeczalik when current Marriage Certificate does not show any other name but Anna Agnieszka Michalik.

Wherefore, Respondent respectfully requests that this honorable Court:

A. Find Respondent not in willful contempt of court.

B. Order the Petitioner, Anna Michalik to stop the Wife, Anna Michalik extorting Money from Ted Jeczalik as there are no passed or future due payments for Anna Michalik unspecified support, especially when Ted Jeczalik does not earn such amount of money, that was submitted with his Income Tax to the court in 2012.

C. Does not order the Respondent to obtain Life Insurance.

D. Does not order the Respondent to cease and desist and remove any evidence in truth that is not defamatory under the constitution and
is true and was published with good motive and is used only as evidence against Petitioner submitting incorrect information in Court of Law.
E. Enforce the law where Petitioner submitted in Court of Law incorrect information many times against Respondent Ted Jeczalik where his Civil and Constitutional rights were violated. The Court should enforce the law and the truth by any means available, including but not limited to incarceration, compensatory or coercive fines, suspension of driver's license, garnishment, suit money and costs and any other coercive sanction or relief permitted by law.

F. Award Respondent compensation for necessity of this motion and hearing and does not award Petitioner Attorney's fees.




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
FBN: 060526
 Attorney for Petitioner


  Ted Jeczalik, Respondent / Husband
         P.O. Box 248,
            Port Richey, FL 34673
            Telephone No. 727-641-6709, Fax 866-395-0966