CHANCERY COURT OF DESOTO COUNTY MISSISSIPPI
Debora Kay Turner Adkins Respondent / Applicant
VS. CAUSE NO. 07-05-0920
xxxxxxxxxAdkins Movant / Respondent
I. Motion for Re-Hearing
&
II. Response to Re-Hearing
COMES NOW, Movant / Respondent, xxxxxxxxx Adkins, hereby files this his Motion & Response and for good cause would show unto this respectful court the support facts as follows, TO WIT:
I. Motion for Extension of TRO
1. That on 24th, Feb. 2010, this court entered a Restraining Order to restrain Deborah Kay Turner Adkins from coming around xxxxxxxxx Adkins and his current wife and their home as this court finds that irreparable harm may come to his family if this restraining order were not being entered.
2. That this court ordered the parties to report back in six months after entering of said Restraining Order.
3. That at this time the six month period has expired and we hereby request this respectful court to re-hear it in order to keep said restraining order in force for following reasons:
3-1. That Deborah Kay Turner Adkins and her similar have constantly made harass calls at a nearly daily base, to xxxxxxxxx Adkins and his current wife after entering of said order;
3-2. That Deborah Kay Turner Adkins has threatened physical harm to the current wife of xxxxxxxxx Adkins.
3-3. That Deborah Kay Turner Adkins has had individuals to call Mr. Adkins and Ms. Luo to harass and intimidate them, drive into our driveway at all hours of the night and having them bang on doors and windows to harass. These individuals included a convicted murderer, a Nicholas Maxwell that is said to still be incarcerated. All these events combined with the constant demand of high life insurance on Mr. Adkins and his children lends to the belief that Debora Kay Turner Adkins psychologically can not let go of controling Mr. Adkins or cease harassment of him or his current wife and continues to hope for the windfall a life insurance policy would bring.
3-4. That Debora Kay Turner Adkins abnormal psychology habitually threaten other individuals through years, such as that she threatened one of the over 10 men who had affair with her during her marriage with xxxxxxxxx Adkins, that she would kill this man if he would break up with her, during the period that this man and his wife just lost his new born infant, not to mention that she committed $35,000 fraud in a Western Store in Collierville TN (See Exhibit A-Adultery)
WHEREFORE, PREMISES CONSIDERED, for the reasons set forth above, this his Motion for Extension of TRO is well-taken and should be granted by this Respectful Court.
II
Response to Re-Hearing Filed
by
Deborah Kay Adkins
1. That on Aug. 26th, 2010, on behalf of Debora Kay Turner Adkins, Vanessa Winkler Price entered a Motion for Re-hearing on a TRO of Feb. 26th, 2010, in which orders Movant / Respondent from having parties 4 children in presence of his current wife. ( Exhibit M - Motion )
2. That said for re-hearing TRO required by Deborah Kay Turner Adkins, never have any sufficient evidence for said order, and the reason it was being entered was because her lawyer Vanessa Winkler Price not only committ fraud of four thousand dollar of litigation fee ( Aug.-Dec. 2009 ) etc. but also misuses the trust of this court. ( see Exhibit F-Fraud of Vanessa Winkler Price)
3. That even though the father's side of said four children are high-educated but due to the facts of that their mother, Deborah Kay Turner / applicant herein, not only a Pseudo-Christians, but also during her marriage with xxxxxxxxx Adkins / Movant / Respondent herein, she is shamelessly proud of her adultery with several married men for financial / monetary benefits ( see Exhibit A – Adultery ), which is rarely difference from the determination of the prostitute and she even Abnormal Psychologicly threatened one of the over 10 married men who had affair with her when she was still in marriage with Mr. xxxxxxxxx /Movant/Respondent herein, that she would break this man's family, right after this man and his wife lost his new born infant, which obviously shows that Deborah Kay Turneris has a disability of basic reasoning & logic, which is a result of her low level of education.
4. That Mr. xxxxxxxxx Adkins, and his current wife, xxxxxxxx who has a master degree in MBA., & a B.A in Education, whose both parents are medicine doctors / Aero Space Engineer, should not be restrained in any way as other parents/step-parents due to the fact that there is not any history of abuse or violence against her own son or any other child except the hearsay of her ex-husband wishing to continue the cherade for his own case and financal gain as Debora Kay Turner Adkins is attempting to do to the extreme detriment of her own chidren.
5. That there were several medical situations of said children which put Mr. xxxxxxxxx Adkins in a dilemma, causing unneccesary stress and disruptions in Deobora Kay Turner Adkins's own childrens lives just for the harassment of their father / her ex-husband / Movant / Respondent herein.
6. That Mr. xxxxxxxxx Adkins and his current wife, Ms. xxxxxxxx, have their own 3 month old daughter, who is learning French & Spanish as foreign language beside learning Chinese and English as mother-tongue, and both her parents are trying to help her establish life goal of becoming a Aero Space Engineer or Medicine Doctor as her grandparents through attending 1 of top 100 universities of US as soon as she completes high school. Thus, Time & Engergy Wise, Ms. xxxxxxxx is more than happy that Deborah Turner keeps her children with herself if Mr. xxxxxxxxx were not her husband.
7. Wherefore, for the medical safety and the best interest of children, Deborah Kay Turner's application for continues of restraining xxxxxxxxx Adkins from having parties children in the presence of his current wife not over one hour / without his immediate supervise shall be denied / rejected with the reasons listed above which proves sufficiently that her request is Vexatious & Abnormal Psychology. And that Movant hereby also prays for such and other further general relief that he/she entitles and as in the premises that have appeared met and proper and so on.
Respectfully Submitted
آن وبيل آدكنز
_____________________________
xxxxxxxxx ADKINS
Movant / Respondent
(always make sure put your name and address or po box here,
Otherwise court can dismiss it)
CERTIFICATE OF SERVICE
I, , do hereby that I have this day hand delivered, U.S. mail, postage paid, and or emailed, faxed a true and correct copy of above and foregoing, to the usual business address of opposing party(ies): Ms. Vanessa Winker Price, POB 1406, Southaven, MS 38671, 662-536-1616, 662-349-2000
This the day of September 6, 2010.
آن وبيل آدكنز
_______________________________________
Adkins
(always make sure put your name and address or po box here,
Otherwise court can dismiss it)
Junior Auxiliary
No comments:
Post a Comment