IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT,
IN AND FOR PASCO COUNTY, FLORIDA

Case No.: 51-2010-DR-5308-WS
Division: Z1
                                  
                    ANNA MICHALIK,
                    Petitioner/Wife,

                               and
                                                              
                        TED JECZALIK
                      Respondent/Husband

_________________________________________/                                                                                                                                                                                                                   
    
Counter Motion to Compel Disclosure

Answer

Respondent, Ted Jeczalik files this Counter Motion to Compel Disclosure and states as follows:


1.  
On November 8, 2011, hearing officer Barbara Gorain and Sofia Bilokryla, Asistan Attorney General, Child Support Enforcement Section, verified copies of all child support payments being made on regular, monthly basis by Ted Jeczalik.

The Petitioner  Anna Michalik and her lawyer Audrey A. Jefferis, again submitted falls information to the Court as Anna Michalik does not receive child support.

2.   Respondent has filed Financial Affidavit and income Tax statement in this cause on February 21, 2012 to the Judge Patricia A. Muscarella under certified mail no. 7011 1570 0001 1589 4798

The Petitioner, Anna Michalik and her lawyer Audrey A. Jefferis, again submitted falls information to the Court as the Respondent has not filed financial affidavit in this cause.

Another falls information was submitted to the Court by
The Petitioner, Anna Michalik and her lawyer Audrey A. Jefferis, that compliance has long - since elapsed.

3.  
The Petitioner, Anna Michalik and her lawyer Audrey A. Jefferis, again submitted falls information to the Court as Mandatory Disclosure as all paperwork in this cause was sent on February 21, 2012 to the Judge Patricia A. Muscarella under certified mail no. 7011 1570 0001 1589 4798

Another falls information was submitted to the Court by The Petitioner, Anna Michalik and her lawyer Audrey A. Jefferis, that compliance has long - since elapsed.

4.
The Petitioner, Anna Michalik and her lawyer Audrey A. Jefferis, again submitted falls information to the Court as the Respondent has signed in May 2011 stipulation and the Respondent, Anna Michalik has violated terms of the stipulation and before the Stipulation became court order, the Stipulation was canceled by Respondent:

Anna Michalik Reconciliation Contract, Agreement, Court Stipulation was Cancellation dated  7-7-2012 and submitted to Petitioner.
 MOTION TO/FOR FRAUD AND RECONCILIATION AGREEMENT CANCELLATION dated 11-7-2011,
MOTION TO/FOR CANCELLATION AND INVALIDITY OF STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS dated 1-30-2012
MOTION TO/FOR CANCELLATION AND INVALIDITY OF STIPULATION ON TEMPORARY RELIEF AND OTHER MATTERS dated 3-21-201
Above documents were submitted to the Honorable Court and to the Petitioner

   5.    Respondent has made all objections and never waived such.
Another falls information about the Respondent was submitted to the Court by Petitioner, Anna Michalik and her lawyer Audrey A. Jefferis, that no objections have been made.

6.    Respondent has incurred substantial amount of income trying to defend himself from falls accusations and information
submitted to the Court by Petitioner, Anna Michalik and her lawyer Audrey A. Jefferis.

Wherefore, Respondent respectfully requests that this honorable Court:

A.    Grant an compensation to the Respondent for all time and income lost Respondent incurred defending himself from falls information and accusations in the Court by
Petitioner, Anna Michalik and her lawyer Audrey A. Jefferis, and

Does not grant an award of attorney's fees to Respondent and,

B.    Stop
Petitioner, Anna Michalik and her lawyer Audrey A. Jefferis, from submitting to the Court falls information as Respondent complied with mandatory disclosure pursuant to Florida Rules of Civil Procedure and the Florida Rules of Family Law Procedure.

C. Compel Petitioner to file Financial Affidavit and Mandatory Disclosure including proof of child support payments from Respondent.



CERTIFICATE OF SERVICE
 I HEREBY CERTIFY that a copy hereof has been furnished by mail
delivery to the persons listed below this 23 day of April, 2012.   
                                                                      
Audrey A. Jefferis, Esquire
8138 Massachusetts Ave.,
New Port Richey, FL 34653
    Tel. 727-845-6174, fax 727-848-3091
FBN: 060526
 Attorney for Petitioner


  Ted Jeczalik, Respondent / Husband
         P.O. Box 248,
            Port Richey, FL 34673
            Telephone No. 727-641-6709,
   Fax 866-395-0966,   Email: ted@tedjec.com