To Prevent Deadbeat Dad From Paying Child Support – Monica Timmerman files insulting Rule 11.02 violating motion filled with frivolous allegations and no evidentiary support to Judge Valerie Smith To Be Heard Friday May 20,2022

By Shelby County Observer Staff

As we continue to investigate legal bad apples in Shelby County, our investigative team at Shelby County Observer with the help of our legal counsel, gives proof that Monica Timmerman’s Rule 11.02 violating motion is filled with frivolous allegations with no evidentiary support. 

Since our investigative report on Legal Bad Apples two years ago the Tennessee Bureau of Investigation has indicted former Shelby County Assistant District Attorney Glenda Adams, after a year-long investigation. Memphis attorney Paul Springer has been convicted of stealing the thousands of dollars his client was awarded in a settlement. Bryan Donaldson a prominent Mid-South attorney is accused of rape.

Timmerman’s motion to the Judge Valerie Smith is numbered and the response below is based upon court documents such as transcripts as well as interviews with certain key parties involved. 

1. Timmerman: Mother is in violation of this Court’s order requiring the parties’ to undergo a psychological evaluation, as she has not completed same, despite being able to do so.

Response: 

In violation of rule 11.02 the mother is being harassed with a motion that is not based on fact and which is causing her an unnecessary increase in attorney fees, the mother has undergone a psychological evaluation. 

2. Timmerman: Father has not had any personal contact with the child since the entry of this court’s order in which mother has been listening and/or feeding the child her words to say to Father, such as Father feels his contact with the minor child creates additional unnecessary anxiety within the child because of Mother’s behavior surrounding the same.

Response: 

Also, in violation of rule 11.02 the mother is being harassed with a motion that is not based on fact and which is causing her an unnecessary increase in attorney fees, according to the courtroom transcript , the court on 11/8/22 ordered no forced visitation. The court also ordered the father to call or text the child 4 times a week which the father has never done in the past 6 months. 

Also, according to the same transcript the GAL also recommended no forecrd visitation for fear of the minor child’s reported suicidal ideations. 

“ … mother has been listening and/or feeding the child her words to say to Father,…” in violation of rule 11.02 this frivolous allegation has no evidentiary support. 

3. Timmerman: Mother has not allowed any in-person visitation with the minor child in at least seven (7) months, despite this Court’s orders to the contrary.

Response: 

Again, in violation of rule 11.02 the mother is being harassed with a motion that is not based on fact and which is causing her an unnecessary increase in attorney fees, according to the courtroom transcript, the court on 11/8/21 ordered no forced visitation. The court also ordered the father to call or text the child 4 times a week which the father has never done.

Also, according to the same transcript the GAL also recommended no forecrd visitation for fear of the child’s reported suicidal ideations. 

4. Timmerman: Mother has allowed the child to travel outside of the state with her pastor, Gregory Kiner.

Response: 

Again, in violation of rule 11.02 this frivolous allegation has no evidentiary support. We called the church and we discovered the child has never traveled alone outside the state with her pastor or any church official on a church trip without the mother being present. 

5. Timmerman: Father submits that Mother has alienated him from the minor child, and can demonstrate same by Mother’s refusal to follow this Court’s orders as to Father’s parenting time, right to unimpeded phone conversations, interference with the child’s representation by her appointed attorney, and Mother’s refusal to sign the release for records for the Guardian ad Litem.

Reponse: 

Again, in violation of rule 11.02 this frivolous allegation has no evidentiary support. 

Again, also, in violation of rule 11.02 the mother appears to be harassed with a motion that is not based on fact and which is causing her an unnecessary increase in attorney fees, according to the courtroom transcript, the court on 11/8/21 ordered no forced visitation. The court also ordered the father to call or text the child 4 times a week which the father has never done.

Also, according to the same transcript the GAL also recommended no forecrd visitation for fear of the child’s reported suicidal ideations. 

6. Timmerman: Father submits that Mother has knowingly and willfully disobeyed this Court’s order and is in contempt of same.

Response: 

Again, also, in violation of rule 11.02 the mother appears to be harassed with a motion that is not based on fact and which is causing her an unnecessary increase in attorney fees, according to the courtroom transcript, the court on 11/8/21 ordered no forced visitation. The court also ordered the father to call or text the child 4 times a week which the father has never done.

Also, according to the same transcript the GAL also recommended no forecrd visitation for fear of the child’s reported suicidal ideations. 

7. Timmerman: Father submits that Mother has demonstrated that she is not a stable and fit parent, and that she has attempted to deceive and manipulate these court proceedings through interference with privileged communications and parental alienation.

Response: 

Again, in violation of rule 11.02 this frivolous allegation has no evidentiary support. The father is in violation of the courts 11/8/21 order to call the child 4 times a week. The mother’s order for injunctive relief was granted by the court. 

8. Timmerman: Father submits that ongoing exposure to Mother’s toxicity, alienation, and manipulation will result in permanent and substantial mental and emotional harm to the child.

Response: 

Again, in violation of rule 11.02 this frivolous allegation has no evidentiary support. 

9. Timmerman: Father submits that is in the best interest of the minor child that Father be named primary residential parent.

Response: 

Again, in violation of rule 11.02 this frivolous allegation has no evidentiary support. The child’s Medical Safety Plan cites the father and his family as the trigger and as unsafe to be around the child. 

10. Timmerman: Father submits that is the best interest of the minor child that Mother be allowed supervised visitation only pending further orders from this Court.

Response: 

Again, in violation of rule 11.02 this frivolous allegation has no evidentiary support. According to the Youth Villages, the Medical Safety Plan for the child shows the mother “ is a source of comfort “ for the child and the father and his father are high risk individuals for the child which should be monitored. 

11. Timmerman: Father submits that Mother’s recent behavior support a mental health evaluation at her expense.

Again, in violation of rule 11.02 this frivolous allegation has no evidentiary support. It is the father who is on the Mississippi Domestic Abuse Registry. It is the father who is cited by Youth Villages as a high risk individual for the minor child. It is the father who has been cited by Youth Villages for verbally abusing the child. According to our research, the mother has no criminal records and all doctors and counsellors have cited the mother as a source of comfort for the child. 

Monica Timmerman’s motion is not based in fact. How any attorney could in good conscience file such a fraudulent motion clearly illustrates why the Shelby County Observer began this series investigating legal bad apples in the Mid-South. All in the legal community we have spoken too have said the mother has a right to file a motion for sanctions against Monica Timmerman and her law firm – Cordell & Cordell

6000 Poplar Ave #225 – based upon Rule 11.03.

11/8/21 the judge clearly said “ I will grant injunctive relief as to phone calls… I’m not going to order forced visitations until I hear from Ms. English .”. The dad is in contempt for never following a consistent phone call schedule

On page 51 the judge order the dad to call the minor child or text the minor child 4 days a week so they could build a relationship. The deadbeat dad has never done it in the past 6 months

Pages 59 and 60  from the court transcripts clearly shows that the GAL intervened as well to stop visitation with the dad mandating that the dad first establish consistency in calling the child.

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Staff@shelbycountyobserver.com