Motion to Reconsider, case 209931
If the Juvenile Court judge won't release the record so I can demonstrate to my sons mother that there is threat, and I had depended on the eventual release of the record for that purpose, then reconsideration and the testimony of a medical professional is in order. The affidavit is below in text rather than scanned.
AFFIDAVIT OF CHRISTOPHER A. BROWN SUPPORTING APPLICATION TO RECONSIDER.
State of California, Santa Barbara City and County of Santa Barbara, Address;_____________________________ Location; _______________________________.
Christopher A. Brown being first duly sworn on his oath deposes and says:
The application for an Order to Show Cause concerning legal custody and visitation modification, heard on September 14, 2000 in Department 12 before the Honorable Denise deBellefeuille, Judge of the Santa Barbara County Superior Court, was denied.
A subpoenaed a report of Santa Barbara Child Protective Services for the hearing, by the requested facsimile appearance, did not arrive. The new circumstance justifying the modification of the order made on September 14, is that respondent has filed a Petition for Release of Juvenile Court Record in an effort to gain possession of a Santa Barbara County Social Services Child Protective Services report (See EXHIBIT NINE of requests for judicial notice) and the petition was denied on November 3, 2000.
Respondent depended at the September 14, hearing, upon the eventual release of the C.P.S. report to inform the petitioner S. Brown of the threat to Harry Potter Brown as described in respondents O.S.C. concerning the source of the child's warts, (EXHIBIT THREE O.S.C attached) and the psychological threat. Since September 14, respondent has determined that the report will not be released by the Santa Barbara County Superior Court, Juvenile division and that the testimony of a medical professional is needed to establish the tangibility of the threat/injury and treatment to and for his son Harry Potter Brown. Respondent has since contacted a physician who can provide testimony verifying the validity of treatments as described in EXHIBIT EIGHT, O.S.C (attached).
Respondent has determined that petitioner will deny all visitation with his son since the September 14, hearing and the visitation order requires modification.
.......................................................................Affiant, Christopher A. Brown
Subscribed and sworn to before me on ..................................................(Date)
(print).....................................................................Notary, Officer of the Court
.......................................................................Notary
Requests for Judicial Notice (MOT. Reconsider)