Filed by Conrad · Case 26-104594-DO

12 Emergency Motion Preservation Spoliation 2026-05-13

Rockenhaus v. Rockenhaus (Divorce) · Wayne County Circuit Court (Third Judicial Circuit), Hon. Nicole N. Goodson · Filed 2026-05-13

Canonical record: rockenhaus.net. Disputed domains are indexed at /disputed-domains/ (not authoritative).

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STATE OF MICHIGAN

IN THE THIRD JUDICIAL CIRCUIT FOR THE COUNTY OF WAYNE
FAMILY DIVISION, DOMESTIC RELATIONS

ADRIENNE MARJORIE ROCKENHAUS, Case No. 26-104594-DO
Plaintiff/Counter-Defendant,
Hon. Nicole N. Goodson
v.

CONRAD ALAN ROCKENHAUS,
Defendant/Counter-Plaintiff.

DEFENDANT/COUNTER-PLAINTIFF'S EMERGENCY MOTION FOR PRESERVATION
ORDER AND ORDER PROHIBITING SPOLIATION OF EVIDENCE

NOW COMES Defendant/Counter-Plaintiff Conrad Alan Rockenhaus, appearing pro se, and respectfully
moves this Honorable Court on an emergency basis, pursuant to MCR 3.310, MCR 2.310, MCR 2.302, and
the Court's inherent equitable authority, for entry of a Preservation Order and an Order Prohibiting Spoliation
of Evidence directed to Plaintiff/Counter-Defendant Adrienne Marjorie Rockenhaus. In support,
Defendant/Counter-Plaintiff states as follows.

LCR 2.119(B) COMPLIANCE
1. The undersigned hereby certifies, pursuant to LCR 2.119(B)(1), that he has complied with all provisions
of LCR 2.119(B) on motion practice. Specifically, and pursuant to LCR 2.119(B)(2), undersigned
requested concurrence of counsel for Plaintiff/Counter-Defendant in the relief sought herein on May 12,
2026, by electronic transmission to Lisa Baker, Esq. (P82555), Aldrich Legal Services, PLLC. Given the
emergency nature of the relief sought, the time-sensitive predicate set forth in §III below, and the fact
that the underlying spoliation-risk conduct has been ongoing since at least May 9, 2026, concurrence
was requested on a shortened response window with a response cutoff of 1:00 PM EDT, Wednesday,
May 13, 2026. Concurrence was not received within the requested response window and is therefore
deemed denied for purposes of LCR 2.119(B)(2). It is therefore necessary to present this motion.

I. PROCEDURAL BACKGROUND
2. Plaintiff/Counter-Defendant Adrienne Marjorie Rockenhaus filed her Verified Complaint for Divorce in this
Court on April 9, 2026.
3. Defendant/Counter-Plaintiff Conrad Alan Rockenhaus filed and served his Answer to Verified Complaint
for Divorce, Affirmative Defenses, and Counterclaim ("Counterclaim") on April 15, 2026.
4. On May 12, 2026, the Clerk of this Court entered default of Plaintiff/Counter-Defendant on the
Counterclaim pursuant to MCR 2.603(A), on the predicate that Plaintiff/Counter-Defendant failed to plead
within the 21-day period prescribed by MCR 2.108(A)(4).
5. Defendant/Counter-Plaintiff filed a Motion for Default Judgment on Counterclaim under MCR 2.603(B)(3)
on May 12, 2026. The seven-day notice period under MCR 2.603(B)(1)(b) is running.
6. The factual averments of the Counterclaim are deemed admitted by operation of the rule. MCR 2.603(A).
Those averments include allegations of conversion of approximately $26,837.87 in diverted VA Disability
Compensation, fiduciary breach by Plaintiff/Counter-Defendant in her capacity as Defendant's Social
Security Administration Representative Payee, unauthorized access to Defendant's va.gov account
using Defendant's id.me credentials, retention of Defendant's personal property including computing
devices, and operation of online accounts used to harass Defendant and his witnesses.
7. The deemed-admitted record now in place gives Plaintiff/Counter-Defendant an affirmative incentive to
destroy, alter, conceal, or transfer the evidence on which the damages and equitable-relief calculations
in Defendant's Counterclaim depend. The conduct described in §III below indicates that destruction,
alteration, concealment, or transfer is not speculative but imminent.

II. THE RELIEF ALREADY PENDING AND THE NEED FOR A STANDALONE PRESERVATION
ORDER
8. The Court has before

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About this filing

12 Emergency Motion Preservation Spoliation 2026-05-13: filing by Conrad Alan Rockenhaus in Rockenhaus v. Rockenhaus (Divorce), Michigan Case No. 26-104594-DO, Wayne County Circuit Court. PDF and searchable text at rockenhaus.net (canonical court record). Disputed third-party domains: /disputed-domains/.