THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT IN AND FOR ESCAMBIA COUNTY, FLORIDA RE: THE MARRIAGE

OF: JACKIE R. CAMERON Petitioner/Husband, CASE NO: 2012-DR-1993 and CHRISTINE S. CAMERON Respondent/Wife. ________________________________ RESPONDENTS SECOND MOTION FOR CONTEMPT BY PETITIONER OR ORDER ON AMENDED MOTION FOR CHILD CUSTODY, THE ESCAMBIA COUNTY SHARED PARENTAL RESPONSIBILITY AND IN VIOLATION OF FLORIDA STATUTES 61.13(3)(a), (k) and (q) COMES NOW Respondent, CHRISTINE S. CAMERON, by and through undersigned counsel and moves this Court for an Order holding Petitioner, JACKIE R. CAMERON, in direct and willful violation of the Order on Amended Motion for Temporary Custody of Minor Child and Other Relief executed by this Court on August 29, 2012, the Escambia County Shared Parental Responsibility Statement and in violation of Florida Statues 31.16(3)(a), (k) and (q) and in support thereof states: 1. 2. 3. This is an action for dissolution of marriage filed on May 23, 2012. There is one (1) Minor Child born in this marriage, to wit: SWC; DOB 11/12/11. There are allegations of domestic violence, against Respondent AND Minor Child

by Petitioner, as well as allegations of illegal drug use by Petitioner. 4. On August 7, 2012, Petitioners Amended Motion for Temporary Custody of

Minor Child and Other Relief was heard by this Court. 5. On August 29, 2012, the Court executed the Order on Petitioners Amended

Motion for Temporary Custody of Minor Child and Other Relief, which is attached hereto as Exhibit A.

VIOLATION OF ORDER ON AMENDED MOTION FOR CHILD CUSTODY AND THE ESCAMBIA COUNTY SHARED PARENTAL RESPONSIBILITY 6. The Order states, in part, the right of first refusal is to be granted to either

parent. See Paragraph 6, page 7 of Exhibit A. Petitioner has, on a daily basis, violated Respondents rights of first refusal, and even in a pleading filed on December 20, 2012, admitted that his mother, Minor Childs paternal grandmother is Minor Childs primary caretaker while Minor Child is with Petitioner. 7. Petitioner ignores the Courts order and continues to allow Minor Child to be

cared for by his office staff, his mother or any person who is not the Petitioner to wit: a. On September 19, 2012, while Respondent was leaving Santa Rosa

County after meeting with a SRSO Detective about the fraud/grand theft investigation of a 1967 Ford Mustang by Petitioner, she witnessed the paternal grandmother driving east-bound on Highway 90. Paternal grandmother did NOT have Minor Child with her. When Respondent asked Petitioner Minor Childs whereabouts, Petitioner could not provide an honest response, and later indicated that the Minor Child was, in fact, at his office while he was out at a hearing. On that very same day, Petitioner filed his Verified Objection to Respondents Petition for Relocation, stating that the paternal grandmother kept Minor Child daily, from 7:00 am through 4:00-4:30. Petitioner did not afford Respondent the right of first refusal. b. On September 21, 2012, Petitioner informed Respondent that Minor

Child was ill. Petitioner informed Respondent that Minor Child was being cared for by his paternal grandmother. Petitioner did not afford Respondent the right of first refusal. Moreover, when Respondent called paternal grandmother for an update about Minor Childs illness, her call was sent to voice mail and never returned. 2

c.

On December 4, 2012, Petitioner informed Respondent that he was not

able to spend any time with Minor Child due to Petitioners illness of that weekend. Petitioner did not give Respondent the right of first refusal. d. On December 20, 2012, the news was reporting a 55% chance of a

tornado in Pace, Florida, where Petitioner lives. Respondent informed Petitioner of the storms and asked where Minor Child was and who was caring for him. Petitioner refused to inform Respondent Minor Childs whereabouts, except to say that he was not with Petitioner. Respondent was not given right of first refusal to care for Minor Child. 8. On October 31, 2012, Petitioner violated Paragraph 22 of the Escambia County

Shared Parenting Schedule. On said date, Minor Child was ill and being transported daily, in the cold, from Petitioner to Respondent. Respondent, solely for the sake of Minor Child and not to sacrifice time with Minor Child, offered that he stay with Petitioner. Petitioner refused, citing plans for the Halloween holiday. 9. Respondent is actively seeking employment in Escambia County; however,

remains unemployed and able to care for Minor Child. 10. Petitioner has been in contempt in the past regarding Minor Child. Respondent

filed her Verified Motion for Contempt by Petitioner of Order on Amended Motion For Temporary Custody of Minor Child and Other Relief, the Escambia County Shared Parental Responsibility Statement and Violation of Florida Statutes 61.13(3)(c), (3)(s) and (3)(l) on September 7, 2012, after Petitioner kept Minor Child, then 9-months-old, from Respondent for six (6) consecutive days. This Verified Motion is attached hereto as Exhibit B. Then-counsel of record, Ann E. Meador, did not set the same for hearing. VIOLATION OF FLORIDA STATUTES 61.13(3)(a)(k) and (q)

11.

Petitioner is in direct and willful violation of F.S. 61.13(3)(a) in that he fails,

consistently, to facilitate or encourage the close and continuing parent-child relationship between Minor Child and Respondent. Petitioner, on numerous occasions, including today, informs Respondent that he is and will continue to punish her by not letting her have access to Minor Child. 12. Petitioner is in direct and willful violation F.S. 61.13(k) in that he has fails to

provide a consistent schedule for Minor Child. In attempting to agree on child-care facilities for Minor Child, Respondent has requested that Minor Child be placed in the same facility, centrally located, or located in Escambia County, for consistencys sake. Minor Child has been deprived of any consistent schedule since August 8, 2012, and it affects his learning abilities, disposition and mood, among other things. Petitioner demands Minor Child attend a daycare that is convenient to him, in Santa Rosa County, without regard to the facilitys cleanliness or its educational goals and record. Petitioner is concerned only with meeting his own needs and is in no way concerned about the consistency of Minor Childs schedule. 13. Petitioner is in direct and willful violation of F.S. 61.13(3)(q) in that he fails to

provide Minor Child an environment that is free from substance abuse. Respondent knows Petitioner to ingest at least one Lortab daily, which he procures illegally. Moreover, Petitioner has objected to Respondents motion for drug testing. WHEREFORE, Respondent prays unto this Court to enter an Order finding Petitioner in contempt of the Order on Amended Motion for Temporary Custody of Minor Child and Other Relief executed by this Court on August 29, 2012, the Escambia County Shared Parental Responsibility Statement and to have violated Florida Statutes 61.13(3)(k) and (q) and, because Respondent is able to provide the much-needed, consistent schedule Minor Child needs, and

communicates willfully and meaningfully with Petitioner, order Minor Child to Respondents care on a daily basis, with Petitioner receiving Wednesdays and every other weekend with orders to communicate with Respondent; or, alternatively, to hold Petitioner in contempt, sanction and reprimand Petitioner. I HEREBY CERTIFY that a copy of the foregoing Respondents Motion for Contempt by Petitioner of Order on Amended Motion For Temporary Custody , the Escambia County Shared Parental Responsibility Statement and Florida Statutes 61.13(3)(a)(k) and (q) was furnished to Jackie R. Cameron, Petitioner, via email at jrod@jrodcameron.com and liz@jrodcameron.com on this 20 day of December 2012. /s/ Ch r i sti n e S. Cook CHRISTINE S. COOK, ESQ. FLA. BAR No: 0528439 CHRISTINE SUE COOK, LLC 890 South Palafox Street - Suite 109 Pensacola, FL 32502 (850) 572-7159 (877) 249-6279 fax christine@christinescook.com
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