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IN THE LICKING COUNTY COMMON PLEAS COURT

DOMESTIC RELATIONS DIVISION


Mechelle M. Thompson
XXXX
XXXX
DOB: XXXX
SSN: XXXX
First Petitioner
vs.
CASE NO: 06 DR 01297
Kenneth W. Oswalt
92 Lancaster Drive
Heath, Ohio 43056
DOB: 10/13/60
SSN: xxxx
Second Petitioner
MOTION TO DENY THE SECOND PETITIONERS REQUEST FOR DOCUMENTS
The First Petitioner moves the court to deny the Second Petitioners Request for
Documents. Memorandum in Support is below.
__________________________
Mechelle M. Thompson
First Petitioner, Pro Se
XXXX
XXXX
XXXX
MEMORANDUM IN SUPPORT
The First Petitioner has already provided tax and financial documentation to the Court and
the Second Petitioner. The Second Petitioner needs these documents to advance himself in
negotiations currently underway between the First and Second Petitioner in a pending settlement
with a sexual harassment complaint against the Second Petitioner by the First Petitioner. The
Federal investigation by the EEOC investigation into the actions of the Second Petitioner and his
employee Brian Waltz has been ongoing since 2013. These documents are of use to determine my
income for settlement purposes and to provide the Second Petitioner further access into my
personal life.

The Second Petitioner has voraciously pursued the First Petitioner in a cycle of stalking
and harassment for almost three years. The Second Petitioner continues to insinuate himself into
the First Petitioners life, going so far as to breaking into the First Petitioners home on multiple
occasions over the course of three years. The Second Petitioner has lied in legal documents
provided to EEOC in the Federal Investigation but the Second Petitioner has admitted breaking
into the First Petitioners home through his previous counsel. The First Petitioner can provide the
Court with a recording of this admission but the Licking County Clerk of Courts Office will not
allow recordings to be provided. The First Petitioner was forced to move because of the Second
Petitioners continued to break into the First Petitioners residence.
Further, the Second Petitioner stalks the First Petitioners residence by parking down the
street and watching the First Petitioners residence. The Second Petitioner has also broken into
the First Petitioners new residence by obtaining house keys from the Parties daughters backpack.
When the Second Petitioner became aware that the First Petitioner had found out that he
once again found a way to gain entrance to her home, he initiated an investigation through his
office to find out if the First Petitioner had purchased a firearm for personal protection. This
investigation was done with Licking County resources on Licking County taxpayers time.
The Second Petitioner still continued to harass the First Petitioner by leaving evidence of
having been inside her residence. This evidence has been turned over to the EEOC as further proof
of the Second Petitioners ongoing harassment and to the police as the First Petitioner has serious
and long-standing concerns for her personal safety.
The Second Petitioner has gone so far as to leave a floral card at the First Petitioners
residence with the pre-printed words I Love You underlined twice. This was followed by the
following written note on the card, And Im watching your every move. The Burglar. Having
known the Second Petitioners handwriting for fifteen years, I am unquestionably able to identify
the Second Petitioners handwriting. In addition, during the deposition in which the Second
Petitioner questioned the First Petitioner, his attorney repeatedly referred to the Second Petitioner
as burglarizing the First Petitioners residence.

As the attention of the Second Petitioner was repeatedly ignored, the Second Petitioner has
become increasingly angry and hostile towards the First Petitioner. At one point, while the First
Petitioner was dropping off a coat to the Parties child, the Second Petitioner yelled to the child
and told her that she did not have his permission to speak to the First Petitioner and to get back
inside his residence. His behavior continued to escalate when on January 8, 2015 the Second
Petitioner stated that he would not allow the Parties child to leave his residence when his visitation
was over. The First Petitioner was forced to have the Heath Police come to the Second Petitioners
residence to escort the child from the residence. The Second Petitioner told law enforcement
officers and the First Petitioner that if the First Petitioner would just talk to him and have
conversations with him, he would have agreed to let the Parties child leave the residence at the
appointed time.
The Second Petitioners aggressive behavior continued as he defied the Courts Judgment
Entry dated April 9, 2014, page seven. In December of 2014 the First Petitioner had turned over
a request for medical/optical/dental reimbursement for the Parties childs expenses for the year of
2014. On page seven of the entry, the Court clearly specified that Reimbursement of out-ofpocket medical, optical, hospital, dental, or prescription expenses paid for the child is to Mechelle
Thompson. The Second Petitioner went to each of the childs doctors, dentist, orthodontist, and
optometrist and paid them for bills that the First Petitioner had already paid in full. Not one of the
offices reached out to the First Petitioner for reimbursement. As of this date, the First Petitioner
has not received full payment for the amount (over three thousand dollars) that the Second
Petitioner was to reimburse the First Petitioner. The Second Petitioner gave the First Petitioner a
check in the amount of 230.87 when not every office would take his money for bills that were
already paid in full. The Second Petitioner is a meticulous, detail-oriented attorney that is very
much aware of every aspect of the law due to his many years of experience and his elected position
as Licking County Prosecutor of Licking County. His actions were purely out of an insatiable
need for ongoing harassment.
In addition, the Second Petitioner has lied to this Court in the last hearing. The Second
Petitioners counsel told the First Petitioner that the Judge had agreed to let the First Petitioners
income stand at $10,700. The Second Petitioners legal counsel if I would agree to that. I stated
yes but the Second Petitioner provided the First Petitioner with a different worksheet than what

was provided to the Court. The Second Petitioner gave the First Petitioner with different figures
on the following lines of the child support worksheet: Health Insurance Expense, Adjustment
Additions, Adjustment Subtractions, Obligation After Adjustments, Obligors Obligation, Actual
Annual Benefit, Final Child Support Figure with Health Insurance, c/s per mo. With health ins,
Actual Health Expense Exp. Adj. The First Petitioner did NOT agree to Child Support worksheet
presented to the Court. The Second Petitioner continues to show a pattern of abuse of his position
as Licking County Prosecutor, harassment of the First Petitioner, and yet more examples of directly
lying in investigations through federal agencies and to this Court.
The Second Petitioner has also filed false documents with the Heath City Schools for his
visitation schedule with the parties child. The Second Petitioner is the legal representation for the
Heath City Schools. He is the person that the school contacts when there are any legal issues, such
as the false documents he provided. He presented these to the First Petitioner as well. The Second
Petitioner also lied to the First Petitioner and demanded the First Petitioner allow him visitation
on July 4, 2014 during the First Petitioners two weeks uninterrupted visitation with the Parties
child. The Second Petitioner was aware that there is an exception to the July 4 visitation but
insisted nonetheless. The First Petitioner felt forced to comply.
The First Petitioner had to threaten filing a contempt of court motion to get the Second
Petitioner to let the Parties child go with her for her year of Halloween trick or treating. The First
Petitioner has also had to call the Heath Police Department to make the Second Petitioner release
the Parties child after his visitation was over. The Second Petitioner stated to the First Petitioner
and to the Police that he was upset that the First Petitioner wouldnt talk to him and he would have
let the child go if the First Petitioner would just talk to him and have conversations with him.
Further, the Second Petitioner has defied the order of the Court dated April 9, 2014, page
seven.

In December of 2014 the First Petitioner had turned over a request for

medical/optical/dental reimbursement for the Parties childs expenses for the year of 2014. On
page seven of the entry, the Court clearly specified that Reimbursement of out-of-pocket medical,
optical, hospital, dental, or prescription expenses paid for the child is to Mechelle Thompson.
The Second Petitioner went to each of the childs doctors, dentist, orthodontist, and optometrist
and paid them for bills that the First Petitioner had already paid in full. Not one of the offices

reached out to the First Petitioner for reimbursement. As of this date, the First Petitioner has not
received full payment for the amount (over three thousand dollars) that the Second Petitioner was
to reimburse the First Petitioner. The Second Petitioner gave the First Petitioner a check in the
amount of 230.87 when not every office would take his money for bills that were already paid in
full. The Second Petitioner is a meticulous, detail-oriented attorney that is very much aware of
every aspect of the law due to his many years of experience and his elected position as Licking
County Prosecutor of Licking County. His actions were purely out of an insatiable need for
ongoing harassment.
The Second Petitioner also has threatened to take the Parties childs cell phone away from
her so that she cannot call the First Petitioner. The First Petitioner bought the cell phone for the
Parties child because the Second Petitioner would take every phone in the house aware from the
Parties child while she was in his care so that she could not contact the First Petitioner. The
Second Petitioner continues to insist that if the Parties child does not comply with the strict
guidelines he has set forth in his residence that the phone will be taken. Some of the requirements
are to be adhered to while in the care of the First Petitioner. This is a violation of Rule 19 in which
the Parties child is allowed reasonable access in which to contact the other party.
PARAGRAPH PARTIALLY REDACTED TO PROTECT THE PRIVACY AND
WELL-BEING OF THE MINOR CHILD.

Because the Second Petitioners position as

Licking County Prosecutor it was determined that local authorities would not be an option to
investigate the Second Petitioner, and her physician is in the process of dealing with this matter
with authorities outside of Licking County. The Second Petitioners actions continue to show
flagrant disregard of the law and complete disregard for the Parties childs well-being.
The requested records are not necessary for a final hearing in a case that began in 2012.
The Second Petitioner has previously been provided with all essential records. The Second
Petitioners request has nothing to do with this matter and is purely a self-serving request in which
to pursue details of the First Petitioners life that he no longer has access to.
To protect the First Petitioner from further violation, and for the above reasons, the First
Petitioner would ask that the Second Petitioners Request for Documents to be denied.

______________________________
Mechelle M. Thompson
First Petitioner, Pro Se
XXXX
XXXX
XXXX
CERTIFICATE OF SERVICE
The undersigned attorney at law certifies that a true and correct copy of the foregoing
was served upon Ken Oswalt, Second Petitioner, 92 Lancaster Drive, Heath, Ohio 43056 via
U.S. Mail on this 23rd day of February, 2015.
___________________________
Mechelle M. Thompson
First Petitioner, Pro Se

IN THE LICKING COUNTY COMMON PLEAS COURT


DOMESTIC RELATIONS DIVISION
Mechelle M. Thompson
XXXX
XXXX
DOB: XXXX
SSN: XXXX
First Petitioner
vs.
CASE NO: 06 DR 01297
Kenneth W. Oswalt
92 Lancaster Drive
Heath, Ohio 43056
DOB: 10/13/60
SSN: xxxx
Second Petitioner

ENTRY
For good cause shown, the First Petitioners Motion to DENY the Second Petitioners
Motion to Provide Documents is hereby GRANTED.

_______________________
JUDGE

________________________
Mechelle M. Thompson
First Petitioner, Pro Se
XXXX
XXXX
XXXX

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