Document: MOTION
Link: [Open PDF](https://42o.org/l3g4l//583.0 MOTION 2024-03-19 .pdf)
Filing Date: 2024-03-19
Summary (Justice Demanded)
In the document provided, Aaron Surina, the Respondent, is seeking reconsideration of the Court’s ruling regarding the relocation of his minor children, DMS and AAS, and the subsequent request for a modification of child custody. Aaron asserts that the Court’s decision was based on misinterpretation and misrepresentation of facts and prior court orders by Counsel Stanley Kempner Jr., which led to the unjust relitigation of resolved issues. Aaron argues that Counsel Kempner’s conduct not only violated ethical standards but also aimed to misconstrue the legal process concerning the custody modification trial.
Aaron highlights the statutory grounds for modification under RCW 26.09.260, emphasizing that the Court has the authority to modify a parenting plan or custody order if there is a substantial change in circumstances and it is in the best interests of the children. He points out that he did not petition the court for a relocation trial but rather a modification trial, which he was granted. However, he alleges that his rights were denied through the unethical actions of an officer of the court, referring to Counsel Kempner.
Aaron further argues that under RCW 26.09.450, even in the same school district where the non-moving party cannot object to relocation, they still have the right to a modification. He asserts that his rights were violated due to the unethical conduct of Counsel Kempner, who failed to uphold the legal standards and misrepresented facts and orders from previous hearings.
The document also highlights several instances of unethical conduct and potential judicial bias, including the lack of timely notice of relocation, disregard for legal precedents, factual misrepresentations, and a lack of transparency and fairness in legal proceedings. Aaron Surina requests the court to reconsider the prior rulings regarding relocation and custody modification, amend the custody arrangement to award primary custody to him for the children’s stability, and uphold their placement in the Spokane School District 81. These requests are framed in the context of seeking justice and protection for the children, emphasizing the importance of ethical and fair treatment in legal proceedings. Overall, the document reflects a strong stance from Aaron Surina in advocating for his rights and the well-being of his children, while also highlighting instances of potential unethical conduct, judicial bias, and injustices that have impacted their case.
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