STATE OF MICHIGAN

IN THE PROBATE COURT FOR THE COUNTY OF ST. CLAIR

In the Matter of:                                                                            File No 16-11-0322-01 GA

Jacqueline Gauvin (Lii- deceased)                                       Hon. John D. Tomlinson, P45917

___________________________________________________/

Alison Loy, In Pro Per                             Office of the SCC Public Guardian (Petitioner/Witness) David M. Loy, prior omitted IP/Witness (Attorney?/Other? for Deceased Jacqueline Gauvin)

4601 Jeddo Road                                                     201 McMorran Blvd., Room 3700

Burtchville, MI 48059                                             Port Huron, MI 48060 

(810) 327-0987                                                       (810) 985-2095                                             

Marc J. Chunko, prior omitted IP/Witness            Mark H. Davidson (P25427)

5904 Peck Road                                                    Lozen, Davidson & Kovar, P.C.

Lexington Twp., MI 48422                  Attorneys for Witnesses Bryan Chunko, IP Witness &

(810) 712-0972                                                       Valerie Hicks-Chunko, Witness

                                                                             511 Fort Street, Suite 402

                                                                               Port Huron, MI 48060

                                                                              (810) 987-3970

___________________________________________/

                                              PROOF OF SERVICE

                           STATE OF MICHIGAN    ss    COUNTY OF ST. CLAIR

Alison R. Loy hereby states that on May 5th, 2021 she served copies to St. Clair County Probate Court of Michigan and parties listed above by way of “United States Postal Service” with postage paid and/or by way of either electronic mail, fax &/or hand delivered on atty. Mark Davidson; Office of St. Clair County Public Guardian and omitted parties of Marc J. Chunko and David M. Loy and further understand by MCR that Court shall also perform such if necessary when a person has no attorney representing them in order to Contest Proceedings –as scheduled for Hearing on Wednesday, May 5th, 2021 @1:30 p.m.– Ordering my, Alison R. Loy’s  Appearance & Freeze Accounts along with Producuction of Privileged Information as Petitioned “Failure Enforce Settlement Agreement” and present the following Motions: A Voluntary or Involuntary Dismissal & Quash Proceedings as Malicious & Fails Demonstration of Merit; otherwise Affix Verification of Every Presentation by Oath/Affirmation 1st along with Adjudication of Probate Court Jurisdictional Appropriateness Over the Defendant, Alison & Matter Prior to Proceeding; Disqualify Judge Tomlinson on Grounds &  Stay Proceedings while Appeal & Move Venue to Place of Fairer Trial Preserving all Respondent/Defendant’s Rights, including the right to a Response & Call witnesses should the Vacate, Dismissal & Quash not be granted. 

                                                                ____________________________________

                                                                 Alison R. Loy (IP, Defendant/Respondent)

STATE OF MICHIGAN

IN THE PROBATE COURT FOR THE COUNTY OF ST. CLAIR

In the Matter of:                                                                            File No 16-11-0322-01 GA

Jacqueline Gauvin (Lii- deceased)                                Hon. John D. Tomlinson ( P45917)

___________________________________________________/

Alison Loy, In Pro Per                             Office of the SCC Public Guardian (Petitioner/Witness) David M. Loy, prior omitted IP/Witness   (Attorney?/Other? for Deceased Jacqueline Gauvin)

4601 Jeddo Road                                                      201 McMorran Blvd., Room 3700

Burtchville, MI 48059                                              Port Huron, MI 48060 

(810) 327-0987                                                         (810) 985-2095                                             

Marc J. Chunko, prior omitted IP/Witness            Mark H. Davidson (P25427)

5904 Peck Road                                                     Lozen, Davidson & Kovar, P.C.

Lexington Twp., MI 48422                   Attorneys for Witnesses Bryan Chunko, IP Witness & 

(810) 712-0972                                                       Valerie Hicks-Chunko, Witness

                                                                               511 Fort Street, Suite 402

                                                                               Port Huron, MI 48060

                                                                               (810) 987-3970

                                                                             __________________________________________/

OBJECTIONS OF & MOTIONS TO CONTEST IMPROPER/UNMERITED PROCEEDINGS OF CONTEMPT OF COURT ORDERS UPON FORMER REPORTER/WITNESS, NOW NAMED DEFENDANT, ALISON R. LOY AS SCHEDULED FOR WEDNESDAY, MAY 5TH, 2021 @ 1:30 PM ALONG WITH 2ND RESPONSE OF OBJECTIONS/DENIALS OF ALISON AS ST. CLAIR COUNTY PROBATE COURT’S JUDGE JOHN D. TOMLINSON DEMONSTRATED KNOWING OR SHOULD HAVE KNOWN FACTS AND REALIZED THE FAULTY PLAINTIFFS’ PETITIONS INCICTED TO COURT ON JULY 27, 2020 LACKED SUBSTANTIAL MERIT AND/OR GENERATED MALICIOUS AGAINST A KNOWN WITNESS/REPORTER (NOW DEFENDANT) AND REDUNDANTLY CONTINUED ON MARCH 17, 2020’S TYPICAL PRE-BIRTDAY SERVICE AND CONTINUING NOW TO REPEATEDLY INCITE CONTEMPT OF COURT ORDERS ON RESPONDANT/DEFENDANT, ALISON & THEREFORE OBJECTIONS & MOTIONS AS FOLLOWS:

EXHBT R1 WITH RECORDED OF COURT APPROVAL IN ALISON’S POSSESSION:  OBJECTION & REQUESTMOTION 1– THE IMPORTANCE OF COURT RECORD & PARTIES CORRECTED TO REFLECT ACCURATELY:IMPROPER STATEMENT CITED BY COURT ON MARCH 8, 2021’S EXPARTE’ ORDER FOR ALTERNATIVE SERVICE DUE TO #3(B) AS “CANNOT BE MADE BECAUSE WHEREABOUTS OF THIS PERSON HAVE NOT BEEN DETERMINED “AFTER REASONABLE EFFORTS”… ASCONTRARY OF FACTS PER AUTHORIZED RECORDING DEMONSTRATNG: ALISON NOTIFIED COURT IN NOVEMBER OF 2020 ALISON’S FAMILY WAS REQUIREDTO RELOCATE HORSES AND DRIVE TO COLORADO TO ASSIST PARKINSON’S FATHER AS ONLY FAMILY AVAILABLE AND DUE TO SNOW, COVID TRAVEL CONDITIONS WOULD LIKELY NEED TO REMAIN THE DISTANCE  BUT PRE-REGISTERED WITH SCCPROBATE COURT PERSONNEL: “2 DIFFENENT CELL #’S” (OFTEN MOUNTAINS DON’T RECEIVE); SOALISON ALSO PROVIDED AN ALTERNATE EMAIL ADDRESS & ATTY DAVIDSON/PARTIES HAD OTHER ALISON’S PRIMARY EMAIL ADDRESS –AND NOT ONLY USED IT OFTEN, BUT DEMONSTRATED USING IT TO INFORM ALISON BY SCCPG SEALS & DAVIDSON CONTACTED ALISON TO INFORM SEALS WAS IN POSSESSION OF $1,000 OF MOM, GAUVIN’S RESIDUAL FUNDS & WOULD PETITION IT FOR HEIR DIVISIONALONG WITH RECEIVED MAILED CHRISTMAS CARDS AS ALISON’S LEGAL ADDRESS DIDN’T CHANGE AND ALISON  EXERCISED GOOD PRE-DILIGENCE TO EVENREGISTER A TEMPORAY CHANGE OF ADDRESS WITH USPS TO COLORADO, SO STILL RECEIVING MAIL AS WELL. SO THEY EACH DEMONSTRATED EFFORT TO GET AHOLD OF ME FOR INCIDENTAL STUFF, BUT NO EFFORT FOR TOWARD THE HEARINGS THEY PRESSED FOR IS UNRATIONAL OF ACTION EXCEPT WHEN IT CAN BE ADVANTAGE OF IT.  SO IT WAS GOOD WE CAME HOME AS SOON AS SNOW STORMS WERE ALLEVIATED, THOUGH COVID WAS RAGING TO FIND A TAPED NOTICE IN OUR BUSHES BY 2 SMALL PIECES OF TAPE IN HIGH WIND SEASON IN APRIL THAT HAD BEEN ISSUED BACK IN MARCH 8TH.  BUT NOT HAVING AN APPROPRIATE CHANCE TO PREPARE THOUGH IT WAS NOTIFIED 2 X THAT WE WERE IN ANTICIPATION OF AN OUT-OF-STATE PARENTAL DEMISE THROUGH APRIL-MAY, BUT THEN ONLY ADJOURNED NOT EVEN 14 DAYS, BUT ONLY 4 DAYS AFTER FUNERAL THAT SEVERELY AGAIN ADVANTAGED WELL PREPARED, SEASONED PROFESSIONAS AGAINST A LAYPERSON ALREADY EXHAUSTED FROM ELDER CARE, TRAVEL & EXPECTED INTO FUNERALS SO NO RATIONAL TIME TO PREPARE EITHER THE RESPONSES SO COMPLEXE, AND EXTENSIVE THEY DEMANDED OF.  AGAIN, FAVORITISM TO THE PROFESSIONALS AND EVEN HARSHLY SPEAKING TO ME AN CUTTING OFF MY QUESTIONS DURING ZOOM THOUGH COURT IS REQUIRED TO BE FOR THE LITIGANTS AND UNBIASELY BUT I COULDN’T EVEN GET MY FINAL QUESTION ANSWERED LET ALONE CONSIDERED A MORE APPROPRIATE-DESERVING ADJOURNMENT WHEN THEY HAD RECEIVED MANY ON WHAT APPEARS TO OTHER EXPERTS AS AN UNRATIONALCLAIM GIVEN STATUTES & COMMON EQUITY.

THUS, SCCPROBATE & PARTIES WERE VERYINFORMED OF MULTIPLE WAYS TO GET AHOLD OF ALISON TO ATTEMPT A SCHEDULE OF PERSONAL OR ZOOM HEARING NOTIFICATIONS BUT DID NOT DEMONSTRATE EVEN RATIONAL, VERY MINIMALATTEMPTS TO INFORM ALISON OF PROCEEDINGS AND INSTEAD APPEAR TO HAVE INCITED THEIR CLIENT & COURT INAPPROPRIATELY OF GAUVIN’S 16-110322GA WHILE COURT PERSONNEL AGREED THERE WERE NO ITEMS SINCE JULY 27,’20 PENDING –EXCEPT AMENTION OF AN IMPROPER SERVICE IN SEPT. 20 WITHOUT BUT NO FURTHER ATTEMPTS MADE BY MID-NOV. 20. NOR WERE THERE ANY PROCEEDINGS, OR WARRANTS UPON ALISON OR EVEN OTHERS TO JUSTIFY CITIZENS-INCLUDING ALISON, EXPECTED TO PUT THIER FAMILIES & TASKS ON HOLD FOR ATTEMPT OF GUESS OTHER’S DESIRES, ESPECIALLY ALISONHAD ALREADY NOTIFIED COURT VIA WRITING ON 7/27/20 THAT DAVIDSON’S PETITION INCITING ACTIONS UPON ME/PARTIES, INCLUDING HIS OWN…SHOULD HAVE BEEN REALIZED WAS SUBSTANTIALLY UNMERITED/FAULTY OF FACTS ON ALISON, A KNOWN FORMER GA & SUSPECTED ELDER ABUSE REPORTERWITH COURT PERSONNEL VERIFYING THERE WERE NO FURTHER ACTIONS PENDING & WITH COVID BACKING UP COURT CASES & SLOWED & IF SUCH CAME –COURT PERSONNEL PROVIDED IT WOULD USE ALISON’S FORWARDING INFORMATION TO PRE-CONNECT HER AVAILABILITY SO PARTIES & COURT RESOURCES WOULDN’T BE WASTED FOR PERSONAL SERVICE ON A PERSON NOTIFIED TO BE TEMPORARILY OUT OF TOWN.

OBJECTION/DENIAL #2: On July 27, 2020 Hearing held on Atty. Davidson/Bryan Chunko Petition granted Motion violating MCL 566.1 to Enforce a Settlement Agreement as “unconsumated” that would have Change/Modified an actual Asset Transfer Agreement by even Davidson’s own exhbt #3 thus HE Failed by heavily deviating Terms as discussed on 10/30/18 which was never intended be only a one sided agreement, but part of Alison’s Stipulation of 1) voluntary resignation as GA & 2) voluntary exchange of priviledged Financial information If: 3) Marc Chunko as Lii’s PA; Now Court/Parties threaten my Constitutional 4th Amend to be secure in my Person, Papers, Housing & Effects, against unreasonable Searches & Seizures, Shall not be violated, AND NO WARRANTS SHALL ISSUE, but upon “probable” cause, supported by an Oath or Affirmation.

Yet, I am being Ordered repeatedly Ordered to Personally Appear in Court, including this Wed 5, 2021 @ 1:30 and give up my Privileged financial Information though there isn’t any qualified of Statute Settlement Agreement, Both Medicaid & Court has acknowledge their awareness that the information is of Assets that were titled into my ownership and as such would be Priviledged and No Oath or Affirmation has been issued to support a Warrant, but all being performed anyway based upon what would be readily be comprehended by the average rational person to have been very faulty accusations by the Plaintiffs March 17, 2020  Petition as was previously notified by Alison to court such as: 

Exhbt R-3-The Assets are repeatedly acknowledged as titled to Alison solely on Feb 7, 2018 by Court Order #C as on P2 of the Asset Transfer Agreement Line #12 this includes transfers to a Trust for Sole Benefit of the Child, now later being chronically attempted by petitioners she has some vis-à-vis fiduciary responsibility to others instead though other legal experts, including Judge opinion it was a Gift solely Ordered to Alison ownership and should know Medicaid don’t allow for recategorizing;

Exhbt R-4-Now, Petitioner Davidson brings in SCCPublic Guardian, who wasn’t even a part of either hearings as wasn’t appointed yet, but solely as a Petitioner to assist him to further provide UnOathed style, faulty Statements (his Exhb2) to disparage Alison’s character but in reality crafted by his own business partner, att Anna Kovar crafting an email attempting to plant false information of : a)Alison should remove restrictions-though having knowledge Alison was no longer the GA, b)Alison “dumped off a pile of Bills” -when it was actually the contents of Ward’s Minute Binder as required GA’s to keep & transfer for Ward when a New Appointment gets made of their ID, Inventories,  current banking information & statements, Health Histories & recent Medical Follow Ups and there was only 3 invoices as I recall: 1) Medilodge that had been prepaid for Nov and listed Patient Fund balance to contain approx. $180; 2) a erroneous pharmecuetical invoice I had been working to clear up; 3) Patient’s United HealthCare Insurance Coupon Book that also was pre-paid to give Public Guardian time to get up to speed .  

Exhbt R5– All of which I had provided email to the parties requesting their correction of  the libelous spread AND INFORMING THEM “I HAD supporting PICTURES” Yet here they are again…spreading it now to a court and I assume is why they now bring on the PG to assist libeling me as an unoathed petitioner instead of a properly oathed witness that could suffer the consequences of perjury for assisting, because they’ll say about anything as Mom, Gauvin’s MULTIPLE INJURIES OCCURRED UNDER THEM!

Exhbt R6– Davidson & now SCCPublic Guardian continue by placing statement after statement with exhbt after exhbt to attempt 1) so much burden on respondent pre-occupied to answer while sliding #17’s  another faulty accusation that on Feb 7, 2018 Alison signed the previous February (Feb 7, 2018 to be exact) AS “ CONSERVATOR” & adding (which she wasn’t) YET EVEN OTHER EXPERTS QUESTION HIM MAKING SUCH A CLAIM WHEN IT IS BLATANLY ESTABLISHED THE COURT ORDERED ME, AS CONSERVATOR TO TRANSFER WARD’S ASSETS TO ME AS THE DISABLED CHILD AND HOLDING THE AUHORITY TO AUTHORIZE SELF-DEALING TRANSFERS.  So I was definitely the conservator on that date -at least part of the day until I finished performing the court orders.  

Davidson’s own exhbt #10 even provides copy that it was performed under a Licensed attorney on that date, yet he isn’t claiming the attorney did anything incorrectly.

Exhbt R7 & R8– Davidson’s (now with SCCPublic Guardian) March 17, 2020 Petition demanding I produce my financial information of assets transferred to my ownership as based upon some 10/30/18 claim Settlement Agreement that properly exist under MCL 566.1, MCl 566.222 or any other statutes but attempts to be extremely 1 sided and presses court to violate my U.S. Constitutional 4thAmendment Rights under the color of law and which would break SOM Medicaid Statutes burdensome, substantially unmerited, riddled by false statements & legally jeopardizing me is very similar to the un-submitted Petition Davidson delivered upon me the previous year of March 5, 2019 coming after I filed a Police Report just two days earlier upon his client as print

Exhbt R9, R10,R11– Later, its discovered my former attorney Adair and Davidson are linked via 1981-87 Port Huron Law firm Davidson, Staiger, Adair, Hill, et al & Davidson email stating Adair told him, “Don’t worry I have all the money here in my firm’s Account.”  When Davidson back in 2019 was pressuring for Alison of her Privileged Financial info in what should have been known by a seasoned atty as 1) outside of court &2) any proceeding & 3) abusing MCL & MCR Discovery Statutes 2.302(B) attempting to claim it for “Discovery” when he would know as a license attorney it is wrong, including it only 2 day after learning Alison reported to police & SCCPG & Medilodge Unit Manager of his client had broke 7/23/18’s Order #6 “Family having inappropriate discussions with PI are Prohibited” & SOM “Visitors to Nursing Home Residents” to harass Mom at Medilodge & her Visitor, Alison via a purple folder labeled “Mom” stocked of derogatory items assembled against Alison & new PG, Seals so Bryan/Valerie tamper with Mom emotionally, then claimed he don’t subscribe to laws.

OBJECTION #3 (Exhbt R12 & R13)– Recently, it now discovered Judge Tomlinson (P45917) While Residing over all Loy/Gauvin of Davidson, Kovar & Adair cases HAD NEVER DISQUALIFIED HIMSELF THOUGH HE ALSO RESIDES ON COMMUNITY FOUNDATION OF ST. CLAIR’sDISCRETIONARY GRANT COMMITTEE WITH DAVIDSON/KOVAR’S BUSINESS PARTNER, TIM LOZEN, ATTY JOHN ADAIR’S BOSS (CHARLES KELLY) CONTROLING OVER $85 MILLION OF WHICH REGION’S BUSINESSES -LIKE MEDILODGE- WOULD GET PROJECT FUNDING (OR WOULDN’T) WITH OTHER WHO’SE WHO LIST, SUCH AS PROSECUTOR, MIKE WENDLING MEDILODGE ONLY MH PETITION OF MOM, AND ALISON’S JANUARY 9, 2019 AGAINST KOVAR & OCT. 30, 2018 DAVIDSON & KOVAR MEDILODGE PUSHING ALISON TO RESIGN & WHAT ENDED UP BEING A PUSH BY DAVIDSON & KOVAR FOR ALISON’S PRIVILEDGED FINANCIAL INFORMATION WHILE JUDGE SWINGING HIS TERMINOLOGY TO ALISON HAS SOME SORT OF MYSTERIOUS VIS-À-VIS FIDUCIARY RESPONSIBILITY TO OTHERS THOUGH IT WAS ACKNOWLEDGE A GIFT SOLELY TO ALISON AND NOW AGAIN FAVORING DAVIDSON& HIS BUSINESS PARTNER KOVAR OF AN AGAINST MCL 566.1 SOME SORT OF AGREEMENT simply because it had been discussed on record, though never consummated by party signatures AS IS REQUIRED IT BE TO WHEN AN AGREEMENT WOULD MODIFY/CHANGE TERMS OF ANOTHER AGREEMENT, SUCH AS IT WOULD DO TO BOTH “THE ASSET TRANSFER AGREEMENT”.

Additional facts (Exhbt #R14, R15, R16): It is appropriate to point out that every professional in these proceeding against Alison is substantially financially dependent on JudgeTomlinson & Judge Tomlinson to them including large potential investors they routinely handle along with SCCProsecutor, Mike Wendling & SCC Court’s Chief Justice & other judges; pluseven St. Clair County Office of Public Guardians, Seals & boss & Medilodge Administrators & Doctors who Lii, Mom suffered many injuries under though she had been found medically fit to discharge home with daughter Alison with her pet, Millie that got interrupted by 1) a heavily tampered of Petition submitted by Medilodge for a Change of Guardian against Alison Loy, now defendant that was originally scheduled for Sept, 2018 as an “Evidentiary Hearing for Supervised Visits” of Davidson’s clients Bryan and Valerie Chunko (Bryan’s mistress turned 3rdwife and a MIOSHA official that Bryan admits per e-mail they supplied Foot Cream to his Lii, mother Gauvin while knowing GA sister, Alison was out of town and it was actually by his own pictures, Hydrosol a “Physician Distributed Only” callus skin exfoliator while Lii, was under care of medical in Medilodge and the product had only been supplied to Medilodge Unit #3 nursing staff for proper lock up and its “Evidentiary Hearing of Davidson’s clients Bryan & Valerie Chunko at Medilodge gets adjourned to October 30, 2018’s Hearing and re-labeled a Guardianship Investigation against the original petitioner/reporter Alison now becomes the defendant and pressured for what should be her Privileged Financial information of Assets that had been appropriately under Medicaid statutes transferred into her sole ownership! 

Exhbt #17– Alison Loy & People of Michigan are requesting both Michigan Attorney General’s & Department of Justice to intervene Due to all the inappropriate relationships proceedingagainst Alison & Lii, Mother Gauvin which is documented chronically favoring Davidson, Kovar, Medilodge petitions that threaten Alison -a known reporter against their clients & regional investor, Medilodge, -now flipped into Alison being THEIR DEFENDANT and threatening a Contempt of Court Incarceration upon her as well as INCITED BY THEM for EXERCISING LAWS-  SUCH AS  MCL 566.1- AND NOT succumbing to that which would deprive of the privacy of her & others financially privileged documents that are to be guaranteed the right to privacy under her U.S. Constitutionally 4THAMENDMENT RIGHTS protected-therefore Privileged effects of being guaranteed security of her Person, Papers, Housing & Effects as Davidson has been chronically lodging petitions to get.

IT IS MORE THAN SUFFICIENT GROUNDS AND ALISON SO MOVES:

LOY EXHIBITS ATTACHED:R1-R17