Document: MOTION
Link: [Open PDF](https://42o.org/l3g4l//584.0 MOTION 2024-03-19 .pdf)
Filing Date: 2024-03-19
Summary (Justice Demanded)
In the document titled “MOTION,” Aaron Surina, the Respondent, is seeking supplemental relief in response to the unethical behavior demonstrated by the Petitioner’s counsel, Stanley Kempner Jr. Aaron highlights the failure of the Petitioner’s counsel to disclose critical information to the Court and himself, specifically regarding the modification of a custody hearing. This deliberate omission by the counsel is seen as an attempt to re-litigate issues that have already been decided in Aaron’s favor, putting him at a disadvantage as a pro se litigant. Aaron objects to the unethical behavior of the opposing counsel, citing their failure to disclose and misrepresentation of information, which lacks candor towards the tribunal and the new presiding judge. He requests judicial oversight and sanctions against the Petitioner’s counsel for perpetuating fraud upon the Court and displaying a lack of candor, despite their extensive legal experience. Aaron emphasizes the need to uphold the principles of Res Judicata and Collateral Estoppel and seeks acknowledgment of the objection to re-litigating issues already ruled upon, a thorough investigation into the conduct of the Petitioner’s counsel, imposition of appropriate sanctions for ethical breaches, reinforcement of the integrity of the judicial process, and a new trial for the modification of custody as previously ruled by the Court. The document reflects Aaron’s perspective of facing unjust actions and bias in the legal proceedings, underscoring the importance of ethical conduct and fairness in the pursuit of justice for himself and his children. It is crucial for Aaron to clearly outline the injustices he and his children have faced, any instances of judicial bias or unethical conduct, and the specific relief he is seeking to address any potential miscarriages of justice in his case.
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