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csmotiontocorrect

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Calibri; \*Riched20 10.0.22621 **IN THE CIRCUIT COURT OF [COUNTY], FLORIDA** **FAMILY DIVISION** **CASE NO.: [Your Case Number]** **[Your Name],** Petitioner, vs. **STATE OF FLORIDA DEPARTMENT OF REVENUE and [Mother's Name],** Respondents. --- ### **MOTION TO CORRECT THE RECORD & ADJUST ARREARS** COMES NOW, the Petitioner, [Your Name], pro se, and respectfully moves this Honorable Court to correct the record and adjust the arrears owed based on erroneous calculations and wrongful enforcement while receiving Temporary Assistance for Needy Families (TANF). In support thereof, Petitioner states the following: 1. Petitioner was previously jailed for non-payment of child support while being an active recipient of TANF, a status which prohibits enforcement actions such as incarceration. 2. After Petitioner's release, the Florida Department of Revenue (DOR) issued a letter confirming that Petitioner was, in fact, receiving TANF at the time of incarceration. 3. During a subsequent hearing, the State Attorney reviewed the records and confirmed that Petitioner was on TANF but failed to take corrective action, instead advising Petitioner to "get out of here while ahead." 4. This constitutes a due process violation and wrongful imprisonment under *Turner v. Rogers*, 564 U.S. 431 (2011), which mandates an ability-to-pay hearing before incarceration. 5. Petitioner requests an official correction of the record, removal of arrears accrued during the TANF period, and any other relief deemed just and proper. WHEREFORE, Petitioner prays this Court grant this Motion, correct the arrears balance, and provide appropriate relief. Respectfully submitted, [Your Name] [Your Address] [Your Phone Number] --- ### **MOTION TO VACATE JUDGMENT DUE TO IMPROPER NOTICE & DENIAL OF DNA TESTING** COMES NOW, the Petitioner, [Your Name], pro se, and moves this Court to vacate the judgment against him on the grounds that his due process rights were violated through improper case merging, denial of DNA testing, and improper service of legal notices. In support thereof, Petitioner states: 1. Petitioner was not married to the child's mother at the time of birth and was denied his right to request a DNA test under Florida Statutes 742.12. 2. The Court improperly merged Petitioner's case with a previous case without affording him the opportunity to challenge paternity. 3. The State Attorney and Hearing Officer admitted in open court that they had the correct address for Petitioner but knowingly sent legal notices to an incorrect address, depriving Petitioner of the opportunity to appear and contest the allegations. 4. This resulted in a default judgment against Petitioner and subsequent contempt proceedings without due process. 5. The Court's actions constitute a violation of Petitioner's constitutional rights under the Fourteenth Amendment and Florida law. WHEREFORE, Petitioner requests that this Court vacate the judgment, allow for DNA testing, and provide any other relief deemed just and equitable. Respectfully submitted, [Your Name] [Your Address] [Your Phone Number] --- ### **JUDICIAL MISCONDUCT COMPLAINT** (To be filed with the Florida Judicial Qualifications Commission and/or the Florida Bar) To Whom It May Concern: I, [Your Name], file this complaint against the Florida Department of Revenue, the assigned Hearing Officer, and the State Attorney in my child support case for misconduct, including: 1. Wrongful imprisonment despite being an active TANF recipient. 2. Knowingly sending court documents to the incorrect address despite having the correct one, leading to default rulings. 3. Denying my right to request DNA testing before establishing paternity. 4. Admitting in court to procedural errors but refusing to take corrective action, leading to financial harm and wrongful enforcement. 5. Using coercion and misinformation to compel compliance with unlawful orders. I request a formal investigation into these violations and appropriate disciplinary action. Sincerely, [Your Name] [Your Address] [Your Contact Information] ---