MOTION FOR CHANGE OF VENUE

IN THE IN THE 11TH JUDICIAL CIRCUIT COURT

OF XXX COUNTY, XXX

 

In Re the Marriage of:

 

XXX,

 

Petitioner

vs.

 

XXX,

 

Respondent

  

Case No.: XXX

 

Division: 14

 

MOTION FOR CHANGE OF VENUE

COMES NOW the Petitioner, XXX, and moves this Court pursuant to Mo. R. Civ. P. 51.04 to change the venue of this matter to _____________ pursuant to _________. In support of the motion, Petitioner further states that:

  1. Petitioner requests this action be transferred to ___________ County for two reasons. First, this Court is biased. Second, it is convenient for all parties if the case is transferred.
  2. It is settled law that “[n]o party shall be precluded from later requesting any change of judge for cause” Mo. R. Civ. P. 51.05(d).
  3. Further, “[t]he judge promptly shall sustain a timely application for change of judge upon its presentation” Mo. R. Civ. P. 51.05(e).
  4. For the bias, the Court has failed to acknowledge and check the Respondent’s hostile conduct towards Petitioner. Petitioner has documented all instances of hostility for Respondent and Austin Sweet as follows:
  5. Plaintiff has evidence showing how Respondent turned off the cameras in Petitioner’s front door and backyard.
  6. Plaintiff also realized that the cameras was tampered with severally. Petitioner also got notification that there was motion at the front of his door.
  • Petitioner has photos of Austin Sweet making vulgar hand signals in the open. Austin also makes vulgar statements in the presence of Petitioner’s four-year-old daughter.
  1. Petitioner has a video showing electronic harassment, where music was playing from the air conditioning unit.
  2. Petitioner has a video showing Respondent and Austin alienating the daughter.
  3. Petitioner also has a video of Austin ridiculing him in the presence of the daughter.
  • Respondent also sent Petitioner a creepy text, telling him to turn the lights off, without good cause. This caused Petitioner unnecessary distress.
  • Respondent was very sick with symptoms of high dose exposure, which posed a high risk to the daughter. Petitioner suspects it was high dose radiation exposure. Besides, Respondent had boxes of blood in her car. High exposure to radiation can cause blood cancer and damaged blood cells.
  1. Petitioner has numerous texts showing detailed harassment from Respondent and Austin.
  2. Petitioner has reported the foregoing to the Guardian Ad Litem and the presiding judge. However, nothing has been done about it.
  3. Besides, Respondent has been lying before the Court severally, but the Court has done nothing about it.
  4. Further, this Court has allowed Respondent to put Petitioner’s family against his children because one of Petitioner’s siblings has a past criminal record. The record involves felony charges that involve threats to a preschool. It was a foolish act with no intentions. However, no child was injured or harmed in any way.
  5. Next, regarding the convenience of the parties, Petitioner recently moved out of St. Charles County. It follows; it is expedient that the case be transferred to her new County of residence.
  6. Petitioner will suffer unnecessary costs and expenses of travel in the event this Court denies his request to have the venue changed. It is therefore in the interest of justice to transfer this case to _________ County.

            WHEREFORE, these premises considered, Petitioner moves this court to disqualify itself from presiding in this case, as no reasonable, sane person could possibly, reasonably conclude that this court will be anything but unfair to Petitioner in light of the patent unfairness and mendacity evidenced by this court to date. Petitioner also requests this Court’s venue be changed for Petitioner’s convenience, since Petitioner moved out of this County. Petitioner therefore prays the venue of this Case be changed to ________ County.

 

Respectfully submitted,

 

 

DATED: ______

 

                    

 

______________________________

XXX

Pro Se

 

 

CERTIFICATE OF SERVICE

I hereby certify on the ____________day of _______________, 2023, that a true and correct electronic copy of the foregoing was sent through the Missouri e-Filing system to counsels of record.

 

 

 

______________________________

XXX

Pro Se

 

 

 

 

 

 

 

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