IN THE DISTRICT COURT OF RILEY COUNTY, KANSAS

TWENTY-FIRST JUDICIAL DISTRICT OF KANSAS

IN THE INTEREST OF )
DEVEN DWAYNE BACKMAN, ) Case No. 15 JC 29
YOB: 1999, A male )
)
CALEB CARL SCHWAB, ) Case No. 15 JC 30
YOB: 2003, A male )
)
ABE SCHWAB, ) Case No. 15 JC 31
YOB: 2005, A male )
)
ASHER SCHWAB, ) Case No. 15 JC 32
YOB: 2008, A male )
)
ELIANAH SCHWAB, ) Case No. 15 JC 33
YOB: 2010, A female )

MOTION TO PROHIBIT FURHTER VIOLATIONS OF COURT RULES

COMES NOW the State of Kansas, by and through Deputy Riley County Attorney, Bethany C. Fields,
and requests the Court order the parents and their designees, and/or people acting on their behalf, to cease and
desists from further violations of court rules and harassment of the parties and agency workers. In support of
this motion the Court is shown the following:
1) A motions hearing, in the above captioned cases was held on Tuesday, May 30, 2017. After the
hearing, a photograph of Laura Price, from St. Francis was taken and posted on social media,
originally by AlmaAnn Klaassen-Jones. See attached exhibits.

2) The post was then purposefully shared by one or both of the parents, Raymond and Amelia Schwab,
on their Facebook site, SeraphimAmelia Schwab. See attached exhibit.

3) In addition, the parents Facebook followers have made some inappropriate, harassing, and offensive
comments on the parents Facebook page, which they are choosing not delete. See attached exhibit.

4) Pursuant to Kansas Supreme Court Rule 1001, Media Coverage of Judicial Proceedings,
A person is prohibited from using a cell phone or any other electronic device in a court
facility to: (A) Take pictures S.C.R. 1001(d)(1)(A).

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 5) In addition, the parents, Raymond and Amelia Schwab, are planning a protest outside the courthouse
during the June 20, 2017 permanency hearing. See attached exhibit.

6) Further, the parents, Raymond and Amelia Schwab, have enlisted help to obtain photos graphs of the
parties in this case via both their Facebook page, SeraphimAmelia Schwab, and their website, Free
Our Children. See attached exhibits.

7) Finally, after the permanency hearing, the parents, Raymond and Amelia Schwab, plan to go to
Washington D.C. for a hunger strike and protest. Per their Facebook page, SeraphimAmelia
Schwab, they plan to do a daily Criminal of the day post, and they have specifically named
parties and workers in this CINC.

WHEREFORE, the State request the Court take this matter up on or before the June 20, 2017
permanency hearing, provide security to the parties and agency workers to prevent this harassment, and grant
other relief that is fair just and equitable.
Respectfully submitted,

/s/ Bethany C Fields #18190

Bethany C Fields #18190
Deputy Riley County Attorney
105 Courthouse Plaza
Manhattan, KS 66502
T: 785/ 537-6390 F: 785/ 537-6334
bfields@rileycountyks.gov

NOTICE OF HEARING

Please take notice and be advised that the above States Motion to Prohibit Further Violations of
Court Rules will come on for hearing on June 20, 2017 at 9:00 a.m., if not taken up before hand by the
Court, in the Riley County Courthouse, Division I, 100 Courthouse Plaza, Manhattan, Riley County,
Kansas.
/s/ Bethany C Fields #18190
Bethany C Fields #18190
Deputy Riley County Attorney
105 Courthouse Plaza
Manhattan, KS 66502
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 T: 785/ 537-6390 F: 785/ 537-6334
bfields@rileycountyks.gov

CERTIFICATE OF SERVICE

I hereby certify that on this 31st day of June, 2017, a true and correct copy of the above and
foregoing Motion to Renew Discovery Request and Notice of Hearing was filed via E-Flex to:
Jennifer Chaffee, Attorney for mother
Lora Ingels, Guardian ad Litem
Brenda Jordan, Attorney for Scott Backman

and the original was efiled with:

Clerk of the District Court, Riley County District Courthouse, Manhattan, KS

And a chamber copy was delivered to: Hon. John F. Bosch, District Court Judge, Division I

And a copy of this Motion and Notice of Hearing was emailed to raymond.r.schwab@gmail.com
&schwabstrong@gmail.com

And on the 1st day of June, 2017 a copy of this Motion Notice of Hearing was mailed via the
U.S. postal service to the following: Raymond Schwab 5232 Glade Road, Loveland, CO 80338

/s/ Bethany C Fields #18190

Bethany C Fields #18190
Deputy Riley County Attorney
105 Courthouse Plaza
Manhattan, KS 66502
T: 785/ 537-6390 F: 785/ 537-6334
bfields@rileycountyks.gov