STATE OF NEW MEXICO
COUNTY OF BERNALILLO
SECOND JUDICIAL DISTRICT COURT
KEVIN
Petitioner,
v.
ANGELA NICOLE MARIE MONTOYA,
Respondent.
Case No. D-202-DM-2020-02429
SUPPLEMENTAL STATEMENT REGARDING RESPONDENT’S OBSTRUCTION
COMES NOW, the Petitioner, Kevin Blystra, pro se, and submits this Supplemental Statement
Regarding Respondent’s Obstruction in response to the ongoing litigation in this matter. This
document highlights the Respondent’s continued and deliberate interference with the Petitioner’s
ability to fulfill his parental role, contrary to the children’s best interests and the principles of
fairness. Due to the Respondent’s ongoing obstruction and hostile conduct, the Petitioner
respectfully requests that the Court issue an order ensuring no direct or indirect contact between
the parties unless explicitly authorized by the Court.
I. Obstruction of Petitioner’s Parenting Time
1. Refusal to Facilitate Custodial Exchanges:
o The Respondent repeatedly obstructed the Petitioner’s court-ordered parenting
time, including the refusal to allow the Petitioner to pick up or drop off the children
at school. This obstruction extended to significant periods during which the
Respondent failed to facilitate any contact between the Petitioner and his children,
especially Emma, who the Petitioner has not seen or heard from since February 9,
2022.
2. Respondent’s Obstruction and Escalation of Custodial Exchanges
o On February 9, 2022, the Petitioner contacted law enforcement after the
Respondent obstructed his court-ordered custodial time. This refusal to comply
with the Stipulated Parenting Plan forced the Petitioner to seek assistance to
enforce his parental rights. The Respondent’s behavior not only escalated tensions
but also fostered unnecessary conflict, creating instability and emotional harm for
the children involved.
3. School Attendance Issues:
o Despite logistical challenges that could have been alleviated by the Petitioner’s
involvement, the Respondent refused his offers to assist with transportation, citing
control over the situation as her rationale. This refusal contributed to the children’s
excessive school absences and placed their education and stability at risk.
II. Exclusion of Petitioner from Key Decisions
1. Educational Matters:
o The Respondent unilaterally made decisions regarding the children’s education
without consulting or involving the Petitioner. This exclusion undermines the
Petitioner’s parental rights and disregards his capacity to contribute meaningfully to
his children’s academic and developmental needs.
2. Healthcare Decisions:
o The Respondent similarly excluded the Petitioner from decisions regarding the
children’s healthcare, violating the spirit of shared legal custody. This pattern of
exclusion is indicative of a deliberate effort to marginalize the Petitioner’s role as a
parent.
III. Enabling Third-Party Interference
1. Introduction of Unauthorized Individuals:
o The Respondent allowed Dennis Fredenburg, a registered sex offender, to have
contact with the children despite the court’s explicit orders prohibiting such
interactions. This decision not only endangered the children but also flagrantly
violated the court’s directives.
2. Minimizing Petitioner’s Concerns:
o When the Petitioner raised valid concerns about inappropriate influences on the
children, including Fredenburg’s involvement and other questionable decisions, the
Respondent dismissed these concerns as baseless. This approach not only
endangered the children but also eroded the Petitioner’s ability to advocate for their
well-being.
IV. Mischaracterization of Petitioner’s Actions
1. False Claims of “Interrogation”:
o The Respondent accused the Petitioner of “interrogating” the children, portraying
his protective actions as invasive or harmful. These claims were not substantiated
but were instead weaponized to paint the Petitioner in a negative light.
2. Undermining Positive Parental Efforts:
o The Respondent and the GAL repeatedly downplayed the Petitioner’s
accomplishments, including his efforts to address concerns responsibly and his
commitment to maintaining a healthy relationship with his children.
V. Financial Harassment Through Child Support Enforcement
1. Leveraging Custodial Disparities:
o By obstructing the Petitioner’s custodial access, the Respondent paved the way for
relentless enforcement actions by child support agencies. The lack of physical
contact with the children, directly resulting from the Respondent’s obstruction, has
placed the Petitioner in a perpetual cycle of litigation and financial strain.
2. Manipulation of Legal Systems:
o The Respondent’s deliberate actions to block the Petitioner’s access have created
ongoing court battles, diverting resources and attention away from resolving the
children’s best interests.
Conclusion and Requests
In light of the Respondent’s continuous obstruction, disregard for court orders, and hostile
conduct, the Petitioner respectfully requests the Court to:
1. Order the Respondent to cease all direct or indirect personal contact with the Petitioner
unless explicitly authorized by the Court.
2. Require all communication between the parties regarding the children’s upbringing,
including education, healthcare, and custodial exchanges, to occur through a mutually
agreed-upon designated third party, as authorized by the Court.
3. Order that all custodial exchanges between the Petitioner and Respondent take place at a
designated public location, such as a police or fire station, to ensure a neutral and safe
environment for both parties and the children.
4. Impose appropriate remedies to address the harm caused by the Respondent’s actions,
including restitution for legal and financial burdens created by her obstruction.
Respectfully submitted,
