Sunday, May 9, 2004

In the Missouri Court of Appeals Eastern District ED No. 84021

Pro Se
In the Missouri Court of Appeals
Eastern District

Sharon Gayle Jeep, (SSN#)Petitioner,

And

David Gerard Jeep, (SSN#)Respondent

E. D. No. 84021

Cause No. 03FC-010670

Respondent's Brief
For the appeal

COMES NOW Respondent, David G. Jeep, and moves this Court to reverse the above referenced cause and or require a rehearing of the action.
Respondent states as follows:

1. The original petition should have been dismissed on the face of it. It did not reference anything that could have been construed as prior abuse nor expected abuse.

2. The petitioner did not check any boxes referencing physical abuse in her original petition for an order of protection.

3. There were no specific allocations of abuse asserted in the original petition for an order of protection.

4. The Petitioner in direct cross-examination confirmed that she had not marked anything on the original petition regarding any actual abuse.

5. The petitioner in direct contradiction to her original sworn assertion in her petition for an order of protections attempted to change her allegations and describe abuse outside the scope of her original petition.

6. The court over ruled the respondent’s timely objection during this testimony.

7. The petitioner was represented by counsel well in advance of the hearing, if it was indeed the petitioner’s feeling that she had been physically abused her counsel should have amended her petition in advance of the hearing.

8. The petitioner was obviously coached to testify on certain points again that were obliviously outside the scope of her original petition.

9. The respondent request that the court reverse the lower courts order in that the original petition for an order of protection did not reference anything that would have called for any order of protection for abuse.

10. If the court would like to here further on this issue and allow the respondent his right to face his accuser with full knowledge of their assertions, the respondent is not only willing but also very much eager for the chance.


WHEREFORE, Respondent prays that this Court reversing the lower courts decision based on the actual scope of the original petition and or order a new hearing to give the respondent fair warning to defend against the NEW allegations fairly.



______________________________________
David G. Jeep, Respondent
16325 Centerpointe Drive
Grover, Mo 63040-1602
Phone 314/277-5904, E-mail Dave@DGJeep.com

Dated this 9th day of May 2004

Pro Se


The Respondent David G. Jeep hereby confirms that a true and accurate copy of the enclosed Court Record Court File has been delivered to the Petitioner.


______________________________________
David G. Jeep, Respondent
16325 Centerpointe Drive
Grover, Mo 63040-1602
Phone 314/277-5904, E-mail Dave@DGJeep.com

Dated this 9th day of May 2004


Pro Se
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