Document: MOTION
Link: [Open PDF](https://42o.org/l3g4l/583.0 MOTION 2024-03-19 .pdf)
Filing Date: 2024-03-19
Summary (Justice Demanded)
Document title: MOTION
Unified Summary:
Aaron Surina, the respondent father, seeks a reconsideration of a court ruling concerning his children’s relocation and a modification of child custody. He contends that the court has misinterpreted and misrepresented previous hearings and orders, leading to an unjust relitigation of previously resolved issues. Mr. Surina alleges unethical conduct by Counsel Stanley Kempner Jr., accusing him of misrepresenting the legal process related to the custody modification trial, introducing narratives and orders from hearings Kempner neither attended nor was designated for, thereby complicating the case.
Mr. Surina believes his rights were violated due to Counsel Kempner’s actions, as a relocation hearing was held before the modification trial, despite him being entitled to residential time or visitation with his children under a court order. He feels his rights were denied by the unethical actions of Counsel Kempner.
The documents further reveal several discrepancies and potential instances of unethical conduct that have been detrimental to Mr. Surina. He has been substantially prejudiced as a non-relocating parent due to the relocation of his children without adequate notice or agreement, as mandated by RCW 26.09.510. Additionally, accusations have been made against Counsel Kempner for neglecting statutory guidelines for custody modification following the children’s relocation, an act that disregards established legal precedents and undermines the best interests of the children involved.
Mr. Surina’s motion for reconsideration calls for expunging any proceedings or orders based on these misrepresentations and seeks an amendment to the custody arrangement to award primary custody to him. This request suggests that the current custody arrangement may not be in the best interests of his children. The document also hints at an alleged local collusion aimed at circumventing statutory mandates, which Mr. Surina refers to as a ‘hijacking’ of the legal process.
In conclusion, the court documents indicate several instances of potential bias, unfairness, and unethical conduct against Aaron Surina, which have negatively impacted his rights as a father, and could prove detrimental to the best interests of his children. Hence, Aaron Surina requests the court to reconsider its ruling under RCW 26.09.260, which allows for the amendment of a parenting plan or custody order in light of substantial changes in circumstances and always prioritizes the children’s best interests.
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