furious over Peter Walsh's misrepresentations

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY OF KENT

___________

ANNALISE MCMENAMIN,

                        PLAINTIFF,                                                    FILE: 03-09173-DC

VS.                                                                                          HON. STEVEN PESTKA

LARY HOLLAND (Pro Se),                                                  

                        DEFENDANT.                                               

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RESPONSE TO PLAINTIFF’S CRUDE FILING

            NOW COMES, the Defendant, Lary Holland’s (Pro Se), Response to Plaintiff’s Crude Filing and hereby represents and states as follows:

1.                  Plaintiff’s counsel is knowingly presenting false and misleading statements to this Court and to the Referee that the “Motion is simply a rehash of the same arguments that Defendant has unsuccessfully made to this court previously” in his late filed answer to Defendant’s Motion that was not seen prior to a scheduled hearing.

2.                  Defendant brought miscellaneous motions before this Court last year which were in large part granted, along with the parenting time provisions. However, Plaintiff’s counsel, true to his threat to Defendant, blocked entry of an Order and prolonged various issues throughout the Summer of 2004.

3.                  Plaintiff’s counsel then relies on Defendant rejecting a settlement negotiations session as a basis to refuse certain provisions that are indeed in the best interests of the minor children and seems to continue his ad hominem attacks on Defendant including yelling and raising his voice and belittling Defendant in one of the conference rooms.

4.                  To correct Plaintiff’s counsel in paragraph three, the fact that Defendant brings witnesses of various sexes and associations to protect against further false police reports of Plaintiff is diametric to his client whom attaches to men in romantic relationships in front of the children and then includes the children into her romantic frays and spats.

5.                  The only person whom engages in bad behavior is Plaintiff. She approaches Defendant in parks, parking lots, and in the police department throwing around threats, swearing, and causing great angst in the presence of the children, resulting in the children begging to not go with Plaintiff. Defendant has never escalated in front of the children, while Plaintiff has escalated in front of the children in the presence of all of her previous relationships and third parties. Additionally, Plaintiff attempts to cloud the minds of the children into thinking that Defendant is a bad person, and also follows the activities of Defendant and interferes with life at every corner.

6.                  Defendant will continue to bring witnesses and associates to observe the behavior of Plaintiff and the interaction of Plaintiff with the children as well as the interaction of Defendant with the children. Plaintiff’s counsel can make other assumptions that are irrelevant to this case.

7.                  Defendant will criticize the actions of Plaintiff when those actions place the needs of the children on the bottom of her list and whenever the children are being raised by some third party whom adds to the alienating tactics used by Plaintiff. Defendant will continue to fight for the children to have a privileged life instead of the life they are leading in the care of a hired babysitter whom is unable to have her own children and chooses to unilaterally bond with other peoples’ children.

8.                  Plaintiff’s counsel in paragraph four again relies on the failed settlement negotiations as a basis for his various crude arguments. To correct Plaintiff’s counsel Defendant did not  submit to this court the settlement agreement and objected to Plaintiff’s counsel when he attempted to submit the results to Judge Pestka. The basis of Defendant’s objection was upon MRE 408 and FRE 408 and granted by Judge Pestka. However, a segment of language was used at the COURTS DIRECTION with regard to parenting time despite Defendant’s concerns surrounding the granted objection.

 Dated: 6/17/2005                                                                     By: __________________

                                                                                                        Lary Holland