Thomas A. Morton 023374 THOMAS A, MORTON, PLC 2917 N. Ave., Ste. 100 Phoenix, Arizona 85013 (602) 595-6870 tom@thomasamortonlaw.com Attorney for Petitioner IN THE SUPERIOR COURT OF THE STATE OF ARIZONA EN AND FOR THE COUNTY OF MARICOPA In re the Matter of No. C2016-009166 JORDAN NEIGHBORS, REPLY REGARDING MOTION TO STRIKE and ALEXANDER NEIGHBORS, (assigned to the Hon. Respondent. Dewain D. Fox) Petitioner, through counsel, replies regarding her motion to strike filed July 6, 2017. In his response, Respondent did not even address the fact that the Court held him as a vexatious litigant and ordered him to seek leave of the Court before filing additional motions. He also did not even address the fact that is motion that is the he did not seek leave of the Court to subject of the motion to strike. Therefore, Respondent has tacitly admitted the he was required to seek leave of the Court and failed to seek leave of the Court be ling his motion and the Court should strike it. What Respondent address in response, however, is worthy of sanction. He spend the entirety of the response making allegations that are untrue and irrelevant to the motion to strike. Many of Respondent’s allega ons are not only irrelevant to the motion to strike, but are irrelevant to the dissolution ofeo Soe wo ns jage and would be defamatory had they not occurred in a court mar filing. Many of the allegations are only cheap personal attacks and could only have been made to try to embarrass Petitioner and her family. Furthermore, in his attempts to j y his violation of the court’s order that he seek the Court’s leave to file additional motions, Respondent claims that Petitioner asked for the information in the reports from DCS in her discovery. This is deceptive because Petitioner did not ask for copies of any DCS reports. She propounded Uniform Interrogatories, which ask for minimal information and not copies of un-redacted reports. See Arizona Uniform Family Law Interrogatories, Number 10. At no point does she ask for copies of reports. Exhibit 1. Therefore, this attempt at justification for violation of a court order is based on deception. Also, Respondent knowingly made a false statement to the Court when he claimed that Petitioner’s counsel is harassi g him by making false statements to the stat: Respondent knows this is a lie because it has already been explained to him by the stete bar and by counsel that the report was made regarding Respondent's father engaging in the unauthorized practice of law by running an unlicensed document preparation business in Arizona. Exhibit 2. The state bar akenly sent the complaint to Respondent because Respondent has already made complaints against counsel that the bar dismissed without investigating. Counsel then alerted the state bar to its mistake. Exhibit 3.ne 1] copy mailed this x 201746r day of July, Alexander J. Neighbors 1411 W. Megan Street Chandler, AZ 85224 Respondent in pro perEXHIBIT 1oe yam YD Thomas A. Morton 023374 THOMAS A, MORTON, PLLC 2916 N. 7 Avenue, Suite 100 Phoenix, Arizona 85013 (602) 595-6870 tom@thomasamortonlaw.com Attorney for Respondent IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA xe the Matter of No. FC2016-009166 JORDAN NEIGHBORS, RESPONDENT! S NOTICE OF Petitioner DISCOVERY TO RESPONDENT and ALEXANDER NEIGHBORS, Respondent. TO: Respondent Alexander Neighbors, and her attorney: Petitioner requests Respondent answer the following Interrogatories and produce the following documents within 40 days. DEFINITIONS AND INSTRUCTIONS Respondent incorporates by reference the “Instructions for Use” fom the Uniform Family Law Interrogatories. “Identify” means give name, address nd phone number. UNIFORM INTERROGATORIES Provide complete responses to Uniform Family Law wyREQUEST FOR PRODUCTION See Exnibit A Dated this day of June, 2017. THOMAS A. MORTON, PLLC Original and one copy mailed this day of June, 2017 to: Alexander Neighbors 1411 W. Megan Street Chandler, AZ 85224 Respondent in pro per yaIncome Inform: EXHIBIT A Copies ofall individual or joint income tax returns (Federal and State) for 2015 and 2016 including copies of all W-2 forms reflecting income earned by you or your spouse. All employment contracts for any employment engaged in within the past two (2) years. All of your pay stubs from January 1, 2016 to the present. ‘All documentation evidencing any benefits, commissions, bonuses, shareholder distributions, stock options and/or perquisites which you have received or been eligible for during the past two (2) years. Investments a All securities or a schedule ofall securities which you own or in which you have, or have had, any interest in whatsoever either alone or jointly with any other person or persons from January 1, 2015 to the present, together with any appraisals or statements of value. All leases, contracts, commercial paper, and the like including, but not limited to, mortgages, deeds of trust, promissory notes, etc., which you have, or have had, any interest in whatsoever either alone or jointly with any other person or persons from January 1, 2015 to the present. Insurance. [All life insurance policies and/or annuities which you own or in which you have, or have had, any interest in whatsoever, either alone or jointly with any other person or persons from January 1, 2015 to the present. All health-related insurance policies which cover or have covered either you, your spouse, or minor children during the past twelve (12) months. All disability-related insurance policies which cover or have covered either you, your spouse, or minor children (if any) during the past twelve (12) months. Pension, Profit Sharing and Retirement Plans,a. _Alldocumentation evidencing pension, profit sharing, 401K, incentive savings, IRAs or other retirement plans in which you are a participant, including all documents disclosing the assets held by such plans, together with all periodic statements or Banking and Other Institutional Records. a All savings passbooks, bank statements, and certificates of deposit for any and all savings accounts in which you own, or claim any interest whatsoever, or in which youare, or were authorized to make withdrawals, whether said accounts were in your name alone, in the name of another person, or in your name and another as joint tenants, from January 1, 2016 to the present. b. All cancelled checks, check registers and monthly bank reconciliation statements for all checking accounts for which you are/were a signor, from January 1, 2016 to the present. ©. Allevidence of safe deposit boxes maintained in your name alone or jointly with other persons, including: a copy of the signed entry card, documents reflecting the location and box number and a set of keys for all boxes. 4. Copies of all financial statements prepared by you or on your behalf, including but not limited to, statements or loan applications prepared for submission to lending institutions, from January 1, 2016 to present. Real and Personal Property a All leases, deeds, titles, bill of sale or contracts of sale property which you own or in which you have, or have had, any interest in whatsoever, either alone or jointly with any other person or persons from during the marriage to the present, together with all appraisals of statements of value for each property. Estate Planning Documents. @ All Last Wills and Testaments, testamentary trusts, living trusts, or any other type of estate planning document which you have executed, and any testamentary documents or living trusts created by a third person under Which you now have, or reasonably expect to have in the future, 2 monetary interest in the form of income and/or lump sum inheritance. Indebtedness.a. All credit card receipts and monthly statements covering all credit card accounts belonging to you or in which you have, orhave had, any interest in whatsoever, either alone or jointly with any other person or persons, from January 1, 2016 to the present. b. All written fee or letter agreements, billing statements, invoices and the like, evidencing arrangements for and payment of attorney's fees and costs related to the pending legal action, c. All documents evidencing other loans or indebtedness of either spouse ‘including but not limited to, mortgages, deeds of trust, promissory notes, etc., and all documents, memoranda, amortization schedules and the like, evidencing principal/interest balance due, 9. Exhibits Allexhibits which may be submitted for trial or hearing scheduled orto be scheduled herein, including without limitation, all written and/or recorded statements of either spouse and/or potential witnesses or other persons having knowledge of any facts relevant to issues in controversy between the parties. 10. Other. a. All documents identified in the preceding answers to Uniform and Non-Uniform Interrogatories.