The motion to modify filed December 27 in Jasper County Circuit Court, alleges that Jayda's mother, Devyn Kyle misled the public with a "Prayers for Jayda" Facebook page that was created the night Jayda suffered the abusive head trauma that caused her death and kept telling the public there was hope for Jayda when she had already been told the girl was brain dead.
The document also describes how Devyn Kyle immediately told the public that Jayda's organs were being donated and included a photo of her holding Jayda's hand.
The documents allege Devyn Kyle "suffers from emotional issues, self esteem issues and the need for constant attention."
The filing was the latest in a bitter custody battle. Earlier in the month, Devyn Kyle's attorneys filed a motion to modify seeking to restrict Mac Kyle's access to their son, citing his previous run-ins with the law.
Mac Kyle's counter motion to modify described a situation in which the children's mother and her parents, Judd and Carmen McPherson, spoke badly about Mac Kyle, with Devyn encouraging the children to call Jalen Vaden, her live-in boyfriend "daddy."
Jalen Vaden, 22, was arrested December 6 on second degree murder and felony child abuse charges in connection with Jayda's death.
The documents attempt to portray Devyn Kyle as someone who used the Prayers for Jayda Facebook page to create a version of what was happening with the child that came nowhere near the truth.
"(She) led the public to believe that the child had been 'found non-responsive on the floor in her bedroom' and it was a possible aneurysm," at a time she and her family had already been told Jayda suffered abusive head trauma "and her eyes were fixed and she was brain dead."
The motion indicates that Devyn Kyle did not tell Jayda's father about his daughter's condition for an hour and a half, long after she had used social media to tell her friends and neighbors her version of what happened.
Mac Kyle ran into difficulty when he arrived at Children's Mercy Hospital where Jayda had been taken by Life Flight.
According to the documents, when Mac Kyle arrived in Kansas City, he discovered that the boyfriend Jalen Vaden to have the "father" bracelet "knowing that (he) was suspected of injuring the child." The motion claims that neither Devyn Kyle or Vaden were allowed to ride with Jayda to Children's Mercy Hospital "because she and her boyfriend were suspected of causing the physical injury."
The documents indicate Devyn Kyle continued to show concern for her boyfriend even after he was arrested for Jayda's murder.
She "continued to send text messages to the Vaden family exhibiting concern about the defendant and inquiring, 'How is he doing?' "
The motion repeats the allegations made in the Department of Social Services Children's Division report that Judd McPherson interfered with the investigation into Jayda's death.
It also notes that Devyn Kyle failed to appear at a juvenile court hearing, with McPherson saying it was because she was grieving.
The motion alleges that her grieving included appointments to have her hair and nails done and having dinner with her boyfriend and friends.
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Bond motion filed for accused killer of three-year-old Jayda Kyle
Jasper County Sheriff: We are still investigating Jayda Kyle's death
Children's Division documents: Grandfather attempting to manipulate Jayda Kyle murder investigation
Juvenile Office documents: Jayda Kyle suffered bleeding from brain, severely torn retina, probably already brain dead when she arrived in K. C.
Some thoughts on the Joplin Globe's article on the Jayda Kyle murder investigation
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Jayda Kyle obituary