IN THE CIRCUIT COURT OF THE COUNTY OF ST. LOUIS
STATE OF MISSOURI
In re the Marriage of:
Sharon Gayle Jeep, (SSN#)Petitioner,
David Gerard Jeep, (SSN#)Respondent
Case No.: 03FC-10670(M)No. Division 13
Motion before the Presiding Judge for the overturn of the above referenced order and thus the overturn and removal of all contempt citations resulting
from said order
COMES NOW the Respondent, David G. Jeep, and moves this Court to make and enter its Order in favor of the motion for the overturn of the adult abuse order and the resulting contempt citations.
Respondent states as follows:
1. The respondent was denied his right to due process in that the scope of the order was changed during the actual trial and the requirement of adequate notice was never afforded the respondent again per the right to due process, see attached orders .
2. A timely objection was made during the trial and two Motions to Set Aside for Reconsideration, December 5, 2003, and a Motion to set aside Judgment for rehearing by Judge or Commissioner, December 24, 2003, were both denied with out comment or foundation .
3. The Issue of an upheld “Order of Protection” infers abuse and it is being used as such to defame the respondent in the custody and the divorce action, but the Order was upheld without giving the Respondent his due process, thus the whole proceeding is flawed.
4. The Respondent wishes to have his day in court before a new judge. Commissioner Jones has consistently denied the Respondent his rights without cause or foundation and I believe is unable to make an impartial judgment on this issue.
WHEREFORE, the Respondent prays that the Presiding Judge will over ride Order and all subsequent resulting citations and orders noted and or referenced here.
David G. Jeep, Respondent
Dated this 21th day of November, 2004