The below motion to expose and dismiss the outrageous Kansas Paternity Fraud was filed today. The time has come to stop this nonsense once and for all.
IN THE CIRCUIT COURT OF THE 6TH JUDICIAL
CIRCUIT, IN
AND
FOR PINELLAS COUNTY, FLORIDA
REF: 15-0001625-FD
UCN: 52 2015 DR 001625 FDXX XX
Division: Family
Leah
R. Krier,
Petitioner,
and
Spencer
C. Young,
Respondent.
_____________________________________________/
MOTION TO CONTEST
Spencer
C. Young, respectfully moves this Honorable Court to grant this Motion to
Contest for
mistakes of fact concerning whether a delinquency exists, and
as grounds therefore would show:
1. This matter represents an outrageous
paternity fraud emanating from the state of Kansas, which pursuant to
the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), has no
jurisdiction. Pursuant to the
UCCJEA, the “home state” for the Petitioner and her child during the relevant
time-period (i.e., greater than six months prior to the fraudulent filing and
thereafter) is North Carolina (NC) . . . NOT Kansas. This clear and convincing fact is readily verified
through public records, including: (1) NC Voter Registration; (2) NC Motor
Vehicle Registration; (3) NC DMV for Driver Licenses; (4) U.S. Post Office
Records; (5) Federal and NC Income tax returns; (6) NC Property tax records (for
real estate and automobiles); (7) Phone number, where Petitioner’s phone number
has been 919-357-3575 (“919” is a North Carolina exchange); (8) Employment
records show since the time before her child was born, Petitioner has been a
flight attendant for Air Wisconsin, who has been based out of the Raleigh-Durham
Airport in North Carolina; (9) Petitioner’s addresses since her child was born
have been: (a) 134 Meadowmont Village Circle in Chapel Hill, NC; (b) 2702
Richmond Road in Durham, NC; (c) 3107 Skybrook Lane in Durham, NC; and
currently (d) 1009 Molesworth Drive in Morrisville, NC. Uninterrupted residency in NC of the
Petitioner and her child can also be verified by: (i) Dr. Stacy Heath of Harris
and Smith in Durham, NC (919-967-8052), who has been Petitioner’s gynecologist
since 2007; (ii) Dr. Christopher Morton of Chapel Hill (NC) Pediatrics
(919-942-4173), who has been the pediatric physician for the Petitioner’s child
since 2008; (iii) Deborah’s Day Care in Durham, NC (919-596-3636) which
Petitioner’s child attended; and (iv) the Durham NC Public School System
(919-560-3833), where, upon information and belief, the Petitioner’s child
currently attends school.
2. The
UCCJEA expressly forbids “Jurisdiction Shopping”, which is defined as seeking
a jurisdiction that clearly favors one of the parties, and in the matter at
hand, the jurisdiction that especially favors the Petitioner is Barton County,
Kansas (KS), which is where this egregious paternity fraud emanated. This is a clear instance of jurisdiction
shopping because: (1) the Petitioner grew up in Barton County, KS; and (2)
Petitioner’s large extended family (e.g., grandparents, parents, siblings,
aunts, uncles, cousins, nieces and nephews) all live in Barton County KS.
3. The
UCCJEA expressly prohibits imposing “inequitable hardship” for any party,
which is defined as holding hearings where one of the Parties in the paternity
matter is unable to attend due to: (1) Distance – the hearings were held
over 1,000 miles distant from Respondent’s residence; (2) Economic
Considerations – as a victim in “the worst bank foreclosure fraud in U.S.
history” (a distinction readily verified by Google search), Respondent had
insufficient funds to travel to Kansas, nor otherwise able to engage KS-based
legal counsel to attend on his behalf; and (3) Emotional Considerations
– Respondent’s wife of 24 years had passed away and the hearings were held
during the week of her funeral.
4. The
Petitioner is a criminal felon, who has committed FIVE instances of
grand larceny against the Respondent, where she made off with Respondent’s
property valued at $275,000, including a Mercedes Benz S-350 Automobile, Jewelry
(e.g., diamonds); Artwork (e.g. Monet, Dali), Computers (e.g., desktops, iPads,
laptops); Musical Equipment (e.g., guitars, keyboard piano, amps); Televisions
& Sound System (Sony); Furniture (e.g., chairs, chaises, tables); Lighting
(e.g., lamps); Kitchenware (e.g., pots, pans utensils, cutlery, glassware); Appliances
(e.g., Washer & Dryer); and Clothes & Other personal items of
value. Petitioner’s thefts were made
possible by a corrupt retired NC judge (David Q. LaBarre), who has been her
boyfriend and was recently convicted for drunk driving. In the event paternity did exist, the
Petitioner has been prepaid in full by multiples.
5. Paternity
does not exist as there is NO DNA evidence of paternity, and Petitioner has
a extensive track record of widespread promiscuity.
6. Theft
& Malicious Prosecution Lawsuit was filed against Petitioner by Scott
Orsini of Orsini & Rose on behalf of Respondent, however O&R filed it
in the wrong jurisdiction and failed to achieve any of the objectives he was
engaged for. Mr. Orsini was directed to
have this paternity fraud dismissed while Respondent completed the book he was
writing, Cannibals in White Shoes.
When Respondent was no longer able to pay O&R’s mounting bills, Mr.
Orsini abruptly resigned leaving Respondent in a compromised position and
defenseless.
Based
on the aforementioned mistakes of fact, a delinquency does NOT exist.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy hereof has been furnished by mail to
the persons listed below this 14th day of March, 2017.
Party
Other
Leah R. Krier Florida
Dept. of Revenue – Largo
1009 Molesworth Dr. 11351
Ulmerton Road #220
Durham, NC 27560-7639 Largo,
FL 33778
Telephone No. 919-357-3575 Telephone No.
727-588-6800
Telefax No. n/a Telefax
No. 727-588-4921
DATED: March 14, 2017
________________________________________
Signature of party
signing certificate and pleading
Printed name: Spencer C. Young
Address: 1194 Lindenwood Drive
Tarpon Springs, FL 34688
________________________________________
Telephone: 919-357-2844
________________________________________
Telefax: n/a
