Merchan Rocha v. Molano Florez

Filing 62

ORDER re 61 Motion for a Warrant to take physical custody of child, or in the alternative for Defendant to produce the minor child in Court. ORDERED that the Clerk of the Court shall issue a Warrant directing law enforcement to take physical custody of SOFIA and place her in Child Haven until FRANCISCO JOSE MERCHAN ROCHA arrives in Las Vegas and secures physical custody of SOFIA. Signed by Judge Robert C. Jones on 5/27/15. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:14-cv-00051-RCJ-VCF Document 61 Filed 05/26/15 Page 1 of 8

IN THE UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
FRANCISCO JOSE MERCHAN ROCHA, )
)
Plaintiff,
)
vs.
) Case No.: 2:14-cv-00051
)
VERONICA MOLANO FLOREZ, AKA
)
GABRIELLE VERONICA MOLANO
)
FLOREZ,
)
)
Defendant.
)
)
PLAINTIFF’S EMERGENCY MOTION FOR A WARRANT TO TAKE PHYSICAL
CUSTODY OF CHILD, OR IN THE ALTERNATIVE FOR DEFENDANT TO
PRODUCE THE MINOR CHILD IN COURT
I.
STATEMENT OF FACTS
On January 10, 2014, Plaintiff, Francisco Jose Merchan Rocha (“Francisco”), filed a
Verified Complaint and Petition for Return of Minor Child, pursuant to Convention on the Civil
Aspects of International Child Abduction (the “Hague Convention” or the “Convention”)1 and
the International Child Abduction Remedies Act (“ICARA”)2. On January 13, 2014, Francisco
filed a Motion under the Hague Convention for a Temporary Restraining Order or Preliminary
Injunction, for an Expedited Hearing and an Order to Show Cause a gainst Defendant, Veronica
Molano Florez (“Veronica”).
On February 12, 2014, this matter came before this Honorable Court for a trial on the
merits.

1

Oct. 25, 1980, T.I.A.S. No. 11,670 at 1,22514 U.N.T.S. at 98, reprinted in 51 Fed. Reg. 10494 (1986).

2

42 U.S.C. §§ 11601-11610 (2011).

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The Court ordered that Francisco’s Petition is granted but its effect shall be deferred for a
period of six (6) months from the date of February 12, 2014, with an additional six (6) month
deferment period available upon the application of the parties.
The Court further ordered the Court is staying the effect of its order for a period of six
month to allow Veronica to file an appeal and get a stay, and/or to modify custody in Colombia.
The Court further ordered that the method for applying for the additional six (6) month
extension to the stay of the Order shall be by Motion, setting forth adequate cause upon to issue
the extension.
On May 29, 2014, Veronica, through her counsel, filed a Notice of Appeal, with the
United States Court of Appeals for the Ninth Circuit. Briefing is still in process with Veronica
twice asking for extensions to file her opening brief.
As of August 11, 2014, the six month deferment period expired.
On November 26, at 10:00 a.m. this matter came on for a hearing on Plaintiff’s
Emergency Motion for an Order Directing Return of Minor Child.
The Court noted the purpose of the initial stay of the Order granting Plaintiff’s Petition
for an Order for Return of Minor Child was to allow Defendant to modify custody in Colombia.
The Court granted Francisco’s Motion for Order Directing Return of Child3.
The Court denied Veronica’s Motion for Extension of Stay of Order.
The Court further ordered the following:
‘NOW THEREFORE, TO ANY PEACE OFFICER IN THE STATE OF NEVADA AND
TO ANY FEDERAL OFFICER:

3

See Document 58 on file.

2

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YOU ARE HEREBY COMMANDED TO enforce the instant order allowing Francisco
Jose Merchan Rocha to remove the above-named minor from the United States of
America, and to allow him to accompany her to the country of Colombia giving said
Francisco Jose Merchan Rocha, the right, without interference, to have said child in his
lawful custody for the purposes described herein.’
Francisco was unable to enforce said Order because the Ninth Circuit Court of Appeals
stayed the Order.
On May 21, 2015, the Ninth Circuit Court of Appeals issued a Memorandum4 affirming
the District Court’s Order (Document 32).
Also on May 21, 2015, the undersigned inquired as to whether Sofia was in school, in
order to enforce the affirmed Order and retrieve her on behalf of Francisco. However, the school
refused to give any information. After further inquiry with Canarelli Middle School, the
undersigned discovered that Sofia no longer attended that school as of March 2015.
On May 22, 2015, the undersigned discovered that Veronica’s husband had sold the
residence where he, Veronica, and Sofia had been living since they arrived to the U.S.5 This is
still the mailing address on file for Veronica in this case despite the fact that it has been sold to a
third party.
Moreover, in an attempt to find the whereabouts of Sofia, the undersigned browsed
through Sam’s, Veronica’s, and Sofia’s Facebook accounts. Sam’s Facebook account showed a
posting from November 2014 saying the following6:
“Moving back to Los Angeles in December. Still love you though Vegas, there’s nothing
else like you, so I’ll be coming back to my Vegas holiday home regularly”

4

See Memorandum attached hereto as Exhibit 1.

5

See Grant, Bargain and Sale Deed attached hereto as Exhibit 2.

6

See Facebook posting as Exhibit 3.

3

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In addition, Sam’s Facebook account shows that he lives in Los Angeles, California.
Sofia’s Facebook account also states that she lives in Los Angeles, California7.
It is unknown whether this information is correct, but it certainly raises great concerns
because this Court’s Findings, Conclusions of Law and Order (Document 32), states the
following:
‘IT IS FURTHER ORDERED there is an injunction in place immediately,
prohibiting the removal of SMM from the State of Nevada, County of Clark, or
from changing SMM’s residence, without the Court’s permission or consent.’

II.
MEMORANDUM OF POINTS AND AUTHORITIES
A. Plaintiff is entitled to emergency relief.
LR 7-5. EX PARTE AND EMERGENCY MOTIONS.
(a) Ex Parte Definition.
An ex parte motion or application is a motion or application that is filed with the Court,
but is not served upon the opposing or other parties.
(b) All ex parte motions, applications or requests shall contain a statement showing good
cause why the matter was submitted to the Court without notice to all parties.
(c) Motions, applications or requests may be submitted ex parte only for compelling
reasons, and not for unopposed or emergency motions.
(d) Written requests for judicial assistance in resolving an emergency dispute shall be
entitled “Emergency Motion” and be accompanied by an affidavit setting forth:
(1) The nature of the emergency;
(2) The office addresses and telephone numbers of movant and all affected parties;
and,
(3) A statement of movant certifying that, after personal consultation and sincere
effort to do so, movant has been unable to resolve the matter without Court
action. The statement also must state when and how the other affected party
was notified of the motion or, if the other party was not notified, why it was not
practicable to do so. If the nature of the emergency precludes such
consultation with the other party, the statement shall include a detailed
description of the emergency, so that the Court can evaluate whether
consultation truly was precluded. It shall be within the sole discretion of the
Court to determine whether any such matter is, in fact, an emergency.

7

See Facebook posting as Exhibit 4.

4

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Francisco has not been allowed contact with his daughter and the longer this
process is, the more time he loses with his daughter. In addition, Veronica relocated Sofia’s
residence without informing Francisco. Moreover Veronica did not update her address with the
Court and there is suspicion that Veronica may have changed Sofia’s residence to the State of
California, which is against this Court’s Orders. Clearly, she is a flight risk and the longer
Francisco is unable to get Sofia, the longer Veronica will have to hide her now that the appeal
has been adjudicated. These circumstances warrant emergency relief.
B. The Court should Order Veronica to appear in Court with Sofia, or in the
alternative issue a Warrant to take physical custody of Sofia to place her in
Child Haven until Francisco can pick her up.
The Ninth Circuit Court of Appeals has affirmed this Court’s Order from the
February 12, 2014, trial. As such, Francisco can now enforce said Order. However, Veronica has
not only wrongfully retained Sofia in the United States, but concealed her in a way to prevent
Francisco from having contact with her or being able to retrieve her. In addition, it appears that
Sofia now resides in the State of California, and Francisco has very limited law enforcement
assistance to retrieve Sofia from Veronica. Therefore, he respectfully requests that the Court
order Veronica to produce the minor child and her valid passport in Court as soon as possible, so
Francisco can take her with him to Colombia.
In the alternative, he respectfully requests that the Court issue a Custody Warrant as the
language on the current Court Orders has proven to be ineffective. The Custody Warrant should
direct law enforcement agencies, including, but not limited to the Las Vegas Metropolitan Police
Department, the U.S. Marshall’s Office, and the State of Nevada Attorney General, to take
physical custody of Sofia anywhere in the United States. Said law enforcement agencies should

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be ordered to place Sofia in Child Haven immediately after retrieving her, where she will remain
until Francisco picks her up.
III.
CONCLUSION
Therefore, Plaintiff requests the following:
(a) An Order ordering Veronica to produce the minor child and the minor child’s
passport in Court;
(b) A Custody Warrant directing law enforcement to take physical custody of Sofia and
place her in Child Haven until Francisco arrives in Las Vegas to pick her up;
(c) Any such further relief as may be just and appropriate under the circumstances
of this case.
Respectfully submitted on this 26th day of May, 2015.
MCFARLING LAW GROUP
/s/Emily McFarling
Emily McFarling, Esq.
Nevada Bar Number 8567
6230 W. Desert Inn Rd.
Las Vegas, NV 89146
[phone] phone
[phone] fax
[e-mail]
Attorney for Plaintiff
Francisco Jose Merchan Rocha
///
///
ORDER
/// IS HEREBY ORDERED that the Clerk of the Court shall issue a Warrant directing law
IT
enforcement to take physical custody of SOFIA and place her in Child Haven until FRANCISCO
///
JOSE MERCHAN ROCHA arrives in Las Vegas and secures physical custody of SOFIA.
///
IT IS SO ORDERED this 27th day of May, 2015.

___________________________
ROBERT C. JONES

6

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AFFIDAVIT OF EMILY MCFARLING, IN SUPPORT OF PLAINTIFF’S EMERGENCY
MOTION FOR A WARRANT TO TAKE PHYSICAL CUSTODY OF CHILD, OR IN
THE ALTERNATIVE FOR DEFENDANT TO PRODUCE THE MINOR CHILD IN
COURT
I, Emily McFarling, Esq., declare under penalty of perjury under the law of the State of
Nevada that the foregoing is true and correct to the best of my knowledge and belief.
1. I am an attorney duly licensed to practice law in the State of Nevada; I am
employed by McFarling Law Group; I represent the Plaintiff.
2. I have read the preceding document, and the factual averments contained therein
are true and correct to the best of my knowledge, except those matters based on
information and belief, and as to those matters, I believe them to be true.
3. The factual averments contained in the preceding document are incorporated
herein as if set forth in full.
4. Movant has not been able to resolve this matter without Court intervention.
DATED this 26th day of May, 2015.
/s/Emily McFarling
Emily McFarling, Esq.
CERTIFICATE OF FONT AND POINT SELECTION
I hereby certify that the foregoing was prepared in Times New Roman font in 12 point
type in compliance with Local Rule 10-1.
DATED this 26th day of May, 2015.
/s/Emily McFarling
Emily McFarling, Esq.
///
///
///

7

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CERTIFICATE OF SERVICE
The undersigned, an employee of McFarling Law Group, hereby certifies that on the 26th
day of May, 2015.I served a true and correct copy of Plaintiff’s Motion, to the following:
__X___by United States mail in Las Vegas, Nevada, with First-Class postage prepaid and
addressed as follows:
Veronica Molano Florez
9143 W. Torino Avenue
Las Vegas, NV 89148
By:

/s/Maria Rios Landin
Maria Rios Landin

EXHIBIT INDEX
Exhibit 1 ……………………………………………………..Memorandum
Exhibit 2 ……………………………………………………. Grant, Bargain and Sale Deed
Exhibit 3 ……………………………………………………. Facebook postings by Sam
Exhibit 4……………………………………………………. Sofia’s Facebook timeline

8

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EXHIBIT 1

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FILED
NOT FOR PUBLICATION
UNITED STATES COURT OF APPEALS

MAY 21 2015
MOLLY C. DWYER, CLERK
U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

FRANCISCO MERCHAN ROCHA,
Petitioner - Appellee,

No. 14-16045
D.C. No. 2:14-cv-00051-RCJ-VCF

v.
MEMORANDUM*
VERONICA MOLANO FLOREZ, agent
of Veronica Gabrielle,
Respondent - Appellant.

Appeal from the United States District Court
for the District of Nevada
Robert Clive Jones, District Judge, Presiding
Argued and Submitted April 13, 2015
San Francisco, California
Before: SCHROEDER and N.R. SMITH, Circuit Judges, and BENITEZ, District
Judge.**
Respondent Veronica Gabrielle appeals from the district court’s grant of
Francisco Merchan Rocha’s petition under the International Child Abduction

*

This disposition is not appropriate for publication and is not precedent
except as provided by 9th Cir. R. 36-3.
**

The Honorable Roger T. Benitez, District Judge for the U.S. District Court
for the Southern District of California, sitting by designation.

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Remedies Act (“ICARA”), 22 U.S.C. § 9001 et seq., ordering the return of their
daughter (“SMM”) to Mr. Rocha’s custody in Colombia. We affirm.
1. SMM’s habitual residence was in Colombia. Giving the district court’s
findings great deference, Mozes v. Mozes, 239 F.3d 1067, 1077-78 (9th Cir. 2001),
the parents did not have a mutual settled intention to abandon Colombia as SMM’s
habitual residence.
2. Respondent concedes the Petition for Return was filed within one year of
the wrongful retention date. The “well settled” exception under Article 12 of the
Hague Convention on the Civil Aspects of International Child Abduction
(“Convention”), Oct. 24, 1980, T.I.A.S. No. 11,670, 1343 U.N.T.S. 89, is
inapplicable to this case.
3. Petitioner did not acquiesce to SMM’s retention in the United States.
While Petitioner allowed SMM to extend her stay in the United States to pursue
her permanent resident application, there is no evidence to unequivocally
demonstrate that Petitioner agreed to let SMM stay in this country indefinitely. See
Asvesta v. Petroutsas, 580 F.3d 1000, 1019 (9th Cir. 2009).
4. Respondent failed to show by clear and convincing evidence that SMM
would suffer psychological harm if she is returned to Colombia. See Cuellar v.
Joyce, 596 F.3d 505, 509 (9th Cir. 2010).
2

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5. The district court did not err by declining to apply the child preference
exception under Article 13 of the Convention. Application of the exception is
discretionary. See Convention, art. 13, ¶ 2. The record indicates that the district
court properly exercised its discretion.
AFFIRMED.

3

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United States Court of Appeals for the Ninth Circuit
Office of the Clerk
95 Seventh Street
San Francisco, CA 94103
Information Regarding Judgment and Post-Judgment Proceedings
Judgment
•

This Court has filed and entered the attached judgment in your case.
Fed. R. App. P. 36. Please note the filed date on the attached
decision because all of the dates described below run from that date,
not from the date you receive this notice.

Mandate (Fed. R. App. P. 41; 9th Cir. R. 41-1 & -2)
•
The mandate will issue 7 days after the expiration of the time for
filing a petition for rehearing or 7 days from the denial of a petition
for rehearing, unless the Court directs otherwise. To file a motion to
stay the mandate, file it electronically via the appellate ECF system
or, if you are a pro se litigant or an attorney with an exemption from
using appellate ECF, file one original motion on paper.
Petition for Panel Rehearing (Fed. R. App. P. 40; 9th Cir. R. 40-1)
Petition for Rehearing En Banc (Fed. R. App. P. 35; 9th Cir. R. 35-1 to -3)
(1)

A.
•

•

B.
•

Purpose (Panel Rehearing):
A party should seek panel rehearing only if one or more of the following
grounds exist:
►
A material point of fact or law was overlooked in the decision;
►
A change in the law occurred after the case was submitted which
appears to have been overlooked by the panel; or
►
An apparent conflict with another decision of the Court was not
addressed in the opinion.
Do not file a petition for panel rehearing merely to reargue the case.
Purpose (Rehearing En Banc)
A party should seek en banc rehearing only if one or more of the following
grounds exist:

Post Judgment Form - Rev. 08/2013

1

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►
►
►

Consideration by the full Court is necessary to secure or maintain
uniformity of the Court’s decisions; or
The proceeding involves a question of exceptional importance; or
The opinion directly conflicts with an existing opinion by another
court of appeals or the Supreme Court and substantially affects a
rule of national application in which there is an overriding need for
national uniformity.

(2)

Deadlines for Filing:
•
A petition for rehearing may be filed within 14 days after entry of
judgment. Fed. R. App. P. 40(a)(1).
•
If the United States or an agency or officer thereof is a party in a civil case,
the time for filing a petition for rehearing is 45 days after entry of judgment.
Fed. R. App. P. 40(a)(1).
•
If the mandate has issued, the petition for rehearing should be
accompanied by a motion to recall the mandate.
•
See Advisory Note to 9th Cir. R. 40-1 (petitions must be received on the
due date).
•
An order to publish a previously unpublished memorandum disposition
extends the time to file a petition for rehearing to 14 days after the date of
the order of publication or, in all civil cases in which the United States or an
agency or officer thereof is a party, 45 days after the date of the order of
publication. 9th Cir. R. 40-2.

(3)

Statement of Counsel
•
A petition should contain an introduction stating that, in counsel’s
judgment, one or more of the situations described in the “purpose” section
above exist. The points to be raised must be stated clearly.

(4)

Form & Number of Copies (9th Cir. R. 40-1; Fed. R. App. P. 32(c)(2))
•
The petition shall not exceed 15 pages unless it complies with the
alternative length limitations of 4,200 words or 390 lines of text.
•
The petition must be accompanied by a copy of the panel’s decision being
challenged.
•
An answer, when ordered by the Court, shall comply with the same length
limitations as the petition.
•
If a pro se litigant elects to file a form brief pursuant to Circuit Rule 28-1, a
petition for panel rehearing or for rehearing en banc need not comply with
Fed. R. App. P. 32.

Post Judgment Form - Rev. 08/2013

2

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•

•

The petition or answer must be accompanied by a Certificate of Compliance
found at Form 11, available on our website at www.ca9.uscourts.gov under
Forms.
You may file a petition electronically via the appellate ECF system. No paper copies are
required unless the Court orders otherwise. If you are a pro se litigant or an attorney
exempted from using the appellate ECF system, file one original petition on paper. No
additional paper copies are required unless the Court orders otherwise.

Bill of Costs (Fed. R. App. P. 39, 9th Cir. R. 39-1)
•
The Bill of Costs must be filed within 14 days after entry of judgment.
•
See Form 10 for additional information, available on our website at
www.ca9.uscourts.gov under Forms.
Attorneys Fees
•
Ninth Circuit Rule 39-1 describes the content and due dates for attorneys fees
applications.
•
All relevant forms are available on our website at www.ca9.uscourts.gov under Forms
or by telephoning [phone].
Petition for a Writ of Certiorari
•
Please refer to the Rules of the United States Supreme Court at
www.supremecourt.gov
Counsel Listing in Published Opinions
•
Please check counsel listing on the attached decision.
•
If there are any errors in a published opinion, please send a letter in writing
within 10 days to:
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and electronically file a copy of the letter via the appellate ECF system by using
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Post Judgment Form - Rev. 08/2013

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Form 10. Bill of Costs ................................................................................................................................(Rev. 12-1-09)

United States Court of Appeals for the Ninth Circuit
BILL OF COSTS
This form is available as a fillable version at:
http://cdn.ca9.uscourts.gov/datastore/uploads/forms/Form%2010%20-%20Bill%20of%20Costs.pdf .
Note: If you wish to file a bill of costs, it MUST be submitted on this form and filed, with the clerk, with proof of
service, within 14 days of the date of entry of judgment, and in accordance with 9th Circuit Rule 39-1. A
late bill of costs must be accompanied by a motion showing good cause. Please refer to FRAP 39, 28
U.S.C. § 1920, and 9th Circuit Rule 39-1 when preparing your bill of costs.
9th Cir. No.

v.
The Clerk is requested to tax the following costs against:

Cost Taxable
under FRAP 39,
28 U.S.C. § 1920,
9th Cir. R. 39-1

REQUESTED
(Each Column Must Be Completed)
No. of
Docs.

Pages per
Doc.

TOTAL
COST

Cost per
Page*

ALLOWED
(To Be Completed by the Clerk)
No. of
Docs.

Cost per
Page*

Pages per
Doc.

TOTAL
COST

Excerpt of Record

$

$

$

$

Opening Brief

$

$

$

$

Answering Brief

$

$

$

$

Reply Brief

$

$

$

$

Other**

$

$

$

$

TOTAL: $

TOTAL: $

* Costs per page: May not exceed .10 or actual cost, whichever is less. 9th Circuit Rule 39-1.
** Other: Any other requests must be accompanied by a statement explaining why the item(s) should be taxed
pursuant to 9th Circuit Rule 39-1. Additional items without such supporting statements will not be
considered.
Attorneys' fees cannot be requested on this form.
Continue to next page

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Form 10. Bill of Costs - Continued

I,

, swear under penalty of perjury that the services for which costs are taxed

were actually and necessarily performed, and that the requested costs were actually expended as listed.

Signature
("s/" plus attorney's name if submitted electronically)
Date
Name of Counsel:

Attorney for:

(To Be Completed by the Clerk)
Date

Costs are taxed in the amount of $
Clerk of Court
By:

, Deputy Clerk

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EXHIBIT 2

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EXHIBIT 3

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EXHIBIT 4

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