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ALEXANDER J.

NEIGHBORS
1411 W Megan St
Chandler, AZ 85224
(480) 734-8649

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA


AND FOR THE COUNTY OF MARICOPA COUNTY
In Re the Marriage of:
Case No. FC2016-009166
JORDAN NEIGHBORS, ) Case assigned to the Honorable Suzanne Cohen
Petitioner, )
) MOTION FOR DISMISSAL
And )
)
ALEXANDER J NEIGHBORS, )
Respondent )

MOTION FOR DISMISSAL

1. I, Alexander Neighbors request the court dismiss the current case No. FC2016-009166
because of the violation of rule of law called the clean hands doctrine.
a. Petitioner in open court during the hearing on Dec 20 stated that her mother
Yvette Stewart paid for her attorney. Yvette Stewart also paid for all of the filing
fees to bring the action into court.
b. Yvette Stewart has committed crimes against the respondent when she filed false
reports of child abuse. (See Exhibit 1.) 47 page report from CPS in which Yvette
Stewart made false atrocious claims of child abuse against the respondent and the
petitioner.
c. Yvette Stewart claimed that Ayvah was being sexually assaulted by the
Respondent.
d. Yvette Stewart claimed that the Respondent leaves on trips and leaves the
children home alone.
e. Yvette and or the petitioner claimed that the respondent’s father, the children’s
grandfather was choking the children out of anger.

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f. Yvette and or the petitioner made accusations that the children were being
neglected.
g. Yvette and or the petitioner made accusations that the respondent was
withholding food from the children as a form of punishment.
2. When Yvette and or the petitioner knowingly made false accusations of child abuse,
child neglect, and child endangerment with Child Protective Services they violated Rev.
Stat. § 13-3620.01:
a. False Reporting Rev. Stat. § 13-3620.01 A person acting with malice who
knowingly and intentionally makes a false report of child abuse or neglect, or a
person acting with malice who coerces another person to make a false report of
child abuse or neglect, is guilty of a Class 1 misdemeanor.

Clean hands doctrine


n. a rule of law that a person coming to court with a lawsuit or petition for a court
order must be free from unfair conduct (have "clean hands" or not have done
anything wrong) in regard to the subject matter of his/her claim. His/her activities
not involved in the legal action can be abominable because they are considered
irrelevant. As an affirmative defense (positive response) a defendant might claim
the plaintiff (party suing him/her) has a "lack of clean hands" or "violates the
clean hands doctrine" because the plaintiff has misled the defendant or has done
something wrong regarding the matter under consideration. Example: A former
partner sues on a claim that he was owed money on a consulting contract with the
partnership when he left, but the defense states that the plaintiff (party suing) has
tried to get customers from the partnership by spreading untrue stories about the
remaining partner's business practices.

SUMMARY
Therefore , the respondent is asking the court to dismiss the case as the petitioner
and the petitioner’s mother have engaged in the commission of crimes of “False
Reporting” in order to get an unfair advantage in this case. When they engaged in
this activity they “violated the clean hands doctrine” They file filed a total of

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over 8 complaints in a 2 week span. All of the CPS complaints that were filed
were all found to be unsubstantiated. I am also asking the court to establish a
restraining order against Yvette Stewart preventing her from coming within 1000
yards of the house

Respectfully submitted this 10 day of Jan, 2017.

__________________________________ 4/26/2018

Alexander J. Neighbors

Certificate of Service

I hereby certify that a true and correct copy of the foregoing document emailed out to all parties.

Respectfully Submitted

_ Date___6 Jan 2017_______


ALEXANDER J NEIGHBORS