Substantiated Abuse

I.                    The following facts entirely contradict the statments made by my dad's attorney Ron Wilkinson to the the Daily Herald on Friday, January 15, 2016: "Ron Wilkinson said the allegations are unsubstantiated claims made by his ex-wife Michelle to gain custody":

A.      ONE OF A COUPLE REFERENCES IN THE COURT RECORD AT 1768, is a 1.3.20 Letter from DCFS stating they substantiated a finding of child abuse against my dad in Case No.1252064.

A.      ON JANUARY 3, 2005 DCFS SUBSTANTIATED DOMESTIC RELATED CHILD ABUSE AND NEGLECT AGAINST MY DAD because among other things, we had witnessed him attempting to throw my mom down the stairs. That was only one out of uncountable acts of violence he committed against my mother, myself and my sisters.  My sisters and I never had the opportunity to tell DCFS about all of the physical abuse he frequently committed against us, because of the fact that abused children usually cannot instantly recall random, traumatic memories during very short interview(s) done by relative strangers. Especially when it is a stranger who they believe will report to their Dad, who will then perpetrate further severe brainwashing and alienating emotional abuse.  I have the DCFS document that proves the fact that DCFS clearly did support a finding of abuse against my Dad, and that DCFS documented both their conversation and their letter to my dad informing him they had substantiated abuse against him. I also have documentation showing that after his conversation with DCFS, my dad went down to the courthouse and filed a motion against my mom for supposedly making a false claim that DCFS had substantiated abuse, when he had been repeatedly informed by DCFS in conversation and by written notification that they had substantiated the abuse.

B.      IN THE COURT RECORD MY DAD’S ATTORNEY MR. WILKINSON, THE GUARDIAN AD LITEM AND THE SPECIAL MASTER HAD ALL RECEIVED COPIES OF THE DCFS SUBSTANTIATED ABUSE AGAINST MY DAD, yet Mr. Wilkinson still made the following statement to the Daily Herald:  “the allegations are unsubstantiated claims made by his ex-wife Michelle to gain custody".

C.      MY DAD SPENT HOURS OFTEN ON A DAILY BASIS OVER THE COURSE OF TEN (10) YEARS PERPETRATING THE KIND OF HORRIBLE BRAINWASHING, ALIENATING, EMOTIONAL ABUSE THAT CAUSED US TO DEVELOP SYMPTOMS OF STOCKHOLM SYNDROME. This constant state of shock caused by my father is evidenced by Custody Evaluator Dr. Blakelock’s contradictory reports that at the exact time we were very happy and enjoyed being around our father, we also had hostility and great confusion about him:

1. 5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKLEOCK BY MR. PETERSON:  R. at 2480, R. at 179:4-6, When the children are interacting with Mr. Wolferts, my observations were that they were very happy and they enjoyed being around him.

2. 5.5.10 TRANSCRIPT, DIRECT EXAMINATION OF DR. BLAKELOCK BY MR. WILKINSON:  R. at 2480, R. at 197:16  Q.  Okay.  Were they well adjusted with Mom?  (17) A.  I don’t think so.  (18-19) Q.  Okay. And what led you to form that conclusion?  (20-23) A. Partly because of their relationship or their, their hostility towards their father.  Partly because of the comments that the children made in testing towards their mother and father. 

B.      I BELIEVE THAT DCFS AND MOST PROFESSIONALS LACK THE ABILITY TO COMPREHEND THE KIND OF TORTURE THROUGHOUT THAT PAST TEN (10) YEARS THAT HAS NEVER BEEN PREVENTED OR STOPPED.

C.      CRIME VICTIM’S REPARATIONS PAID FOR MY THERAPY BECAUSE OF MY DAD’S ABUSE, Crime and I can provide copies of this evidence.

D.      5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKLEOCK BY MR. PETERSON:  R. at 2480, 206:2-6  MR. PETERSON: In the last paragraph you indicate that Brian admits to a secra---a sexual ---to a history of sexual contact with a child during his adolescence, for which he was neither investigated nor charged for a crime.

E.       DR. HAROLD BLAKELOCK’S CHILD CUSTODY SETTLEMENT CONFERENCE REPORT ON 2.11.10, 3:5:  “ In taking his second polygraph, Brian admits to a history of sexual contact with a child during his adolescence for which he was neither investigated nor charged with a crime.  During polygraph in question, Brian also admits that at the age of 23 he exposed himself to two young girls as he exited a shower, and that ‘years later’ he masturbated to thoughts of the older girl (11 or 12 at the time of the incident) by placing her in the position of the younger girl (6 or 7 at the time of the incident).  Ethical standards of the Association for the Treatment of Sex Abusers (ATSA) state “a client who has a history of sexual contact with children or who reports engaging in sexual fantasies about children should be restricted from having unsupervised visitation with Children" (Section 12.03, Ethical Standards). 

F.       AFTER DCFS SUBSTANTIATED ABUSE THE FIRST TIME, SEVERAL THERAPISTS AGAIN CONTACTED DCFS FOR A SECOND TIME, but by then my dad had of course made friends with the Guardian ad litem who in turn influenced someone to stop the investigations.  In addition, the GAL had never met with us, yet he reported to the court that he had met with us.  The first time I met the GAL was on the day he told me he was transferring custody to my horribly abusive father.

G.     AFTER MY SISTER SYDNEY WAS DIAGNOSED WITH CELIAC’S DISEASE THROUGH A BIOPSY DONE BY A WELL-KNOWN SPECIALIST referred by our pediatric doctor, my dad not only refused to allow Sydney the gluten free diet required to recover and stabilize her illness, but also constantly bought her favorite foods with gluten, put them in front of her, and compelled her to eat them.  As a 7 year old at the time, Sydney was very confused to have the Doctor talk with her and remind her not to eat gluten while my Dad kept telling her the Doctor had not been right and that she needed to eat the gluten that he gave her. There was a short time when he finally allowed her to eat some gluten free food, however right after custody was defaulted to my dad (through his successful efforts to wrongly have my mother sanctioned with contempt in order to strike all of her pleadings), he began telling us that Sydney’s specialist was basically a quack that didn’t know what she was talking about, and permanently stopped allowing Sydney to eat gluten free food.  Although my Dad would not allow Sydney to have the gluten free food and my mom unfailingly provided and encouraged her to follow the Dr.’s recommendation to strictly follow a gluten free diet, my Dad testified during a 2006 trial that my mom was the one offering Sydney the bad food instead of him.  My Dad’s attorney Mr. Wilkinson has had full access to the Court Record that details my sisters’ Celiac’s Disease.    

III.              THE FOLLOWING FACTS ENTIRELY CONTRADICT THE STATEMENTS MADE BY MY DAD’S ATTORNEY TO THE DAILY HERALD ON FRIDAY, JANUARY 15, 2016:  "These are the types of allegations that have been made against him for over a decade” Wilkinson said. “Each time, there have been expert evaluations, court hearings, and each time, through due process, it's determined that the children are not at risk in his care and abuse is not taking place":  

A.                  MY MOTHER WAS SEVERELY PREJUDICED AND DEPRIVED OF DUE PROCESS WHEN CUSTODY WAS AUTOMATICALLY DEFAULTED TO MY FATHER DURING A 8.20.09 & 10.6.09 DEFAULT CUSTODY HEARING PRIOR TO A 5.5.10 & 5.12.10 DEFAULT CUSTODY TRANSFER, AFTER MY SISTERS AND I HAD SPENT FIFTEEN (15) YEARS THRIVING, HAPPY AND WELL-ADJUSTED WITH MY MOTHER AS OUR PRIMARY CAREGIVER FROM BIRTH.

B.                  AFTER SEVERAL INVESTIGATIONS HAD BEEN COLLECTIVELY MADE OVER THE COURSE OF THREE YEARS THROUGH DCFS, THE FIRST GUARDIAN AD LITEM, AND A CUSTODY EVALUATION COMPLETED IN 2007, THE COURT FOUND THAT MY MOTHER SHOULD REMAIN THE CUSTODIAL PARENT:

1.                   11.5.04 TEMPORARY ORDERS (4 October 2004), R. at 40, 1:1  “RESPONDENT WILL BE GRANTED TEMPORARY PHYSICAL CUSTODY OF THE PARTIES’ MINOR CHILDREN UNTIL FURTHER ORDER OF THE COURT.” 

2.                   R. at 87-86 4.26.05 MINUTES, R. at 87, 1:2, MS. WHITE (first guardian ad Litem) RECOMMENDS THE RESPONDENT REMAIN TO BE THE CUSTODIAL PARENT.

C.                  R. at 575, DR. LOIS DETTENMAIER, CUSTODY SETTLEMENT CONFERENCE RULE 4903 CONSIDERATIONS IN GRANTING MOTHER CUSTODY ON 4.27.07:

1.                   General interest in continuing previously determined custody arrangement where the children are happy and well adjusted

2.                   Children’s preference

3.                   Benefit of keeping siblings together

4.                   Relative strength of the children’s bond with one or both of the prospective custodians

5.                   Factors related to the prospective custodians’ character or status or their capacity or willingness to function as parents

D.                  R. at 569, DETERMINATION OF MOTHER’S PARENTING SKILLS:

1.                   Provides structure and fairness

2.                   Provide opportunities for hands-on learning

3.                   Encourages her children to think about their thoughts

4.                   Assists her children in mastering social skills

5.                   Actively promotes her children in becoming a part of their peer group

6.                   Fosters enduring attachments with school, neighbors, friends, and religious institutions

7.                   Allows for healthy disagreements

8.                   Provides her children permission to appropriately express their opinions

9.                   Disciplines through natural consequences

10.               Provides consistent and reasonable family rules

11.               Engages the children in family activities

12.               Holds family discussions and make contracts for cooperation, responsibility and kindness

13.               Provides opportunities for family fun

E.                   R. at 569, AVAILABILITY:

1.                   Teaches piano within the home and is essentially able to provide full-time child care

F.                   R. at 569, MANNER IN WHICH THE PARENT’S SKILLS FIT THE CHILDREN’S NEEDS

1.                   Is perceived as the psychological parent by all three girls

2.                   Intelligent and able to support her daughters academic performance

3.                   Multi-talented and able to encourage and support her daughter’s musical and literary talents

4.                   Capable of maintaining good parent/child boundaries

5.                   Capable of minimizing/eliminating the extent to which the children are exposed to any conflict

6.                   Fosters enduring attachments with her own family members

7.                   Able to help her daughters learn through natural consequences

8.                   Provides consistent and reasonable family rules

9.                   Involved in her own experiences and discoveries

10.               Provides family activities that involve both fun and work

G.                 R. at 1745, MY MOTHER’S PSYCHOLOGICAL TESTING REPORT BY BRYAN MICHELSON:  “The results indicate that Michelle answered the responses honestly and accurately and therefore should be considered a valid administration of the MMPI-2.  She was non-defensive and open in her responding.  Michelle’s testing had no significant escalation on the eight clinical scales.  She did report considerable fatigue.  The results indicate exceptionally healthy psychological functioning…in conclusion, this report is short due to the extremely healthy nature of Michelle’s results.“

H.                  R. at 1746, 12.18.08 LETTER FROM CLINICAL PSYCHOLOGIST DR. RANDALL HYDE: After our conversation, I was surprised that people are making assumptions about your mental health. It makes me wonder where they are getting their information, and if that information is valid or just opinion?  Let me know if I can be of any further assistance.  Sincerely yours, Randy Hyde Ph.D., Licensed Clinical Psychologist”

I.                    R. at 448, 3.2.08 LETTER FROM MARK I. PAYNE, longtime home teacher of my mother, sisters and I who had also been Director of Utah State Division of Substance Abuse and Mental Health: “I have known Michelle Wolferts for the past two years or so.  I have had the opportunity of visiting in her home on a regular basis with her and her three girls, Brittany, Sydney and Danielle.  I have been impressed with the positive feeling that is in the home.  It is clear that this mother has the best interests of her daughters at the forefront of her mind.  The love of the girls for their mother is very evident.  The girls are very accomplished in the arts and enjoy many varied activities which include drawings, paintings, music, crafts, etc.  These girls have a wonderful sense of family and belonging and they are in a situation where they can grow and mature into fine young women who have a lot to give.  I have appreciated the opportunity to have a relationship with this family and involvement in their lives.  Mark  I. Payne”

J.                    R. at 444, 10.3.04 Letter from Kim McCollum:  “……I know Michelle from college, we studied piano under the same professor at Sam Houston State.  Michelle went on to teach piano, starting her own studio and building a committed following; she’s a very talented and gifted teacher!  For the past three years, she has supported three children and a husband from the income generated from her piano studio…Whenever I mention Michelle to someone who does not know her, I always make the comment that she has been my example of what “goodness” is for as long as I’ve known her, over 10 years now.  Her commitment to her family, her children, her personal convictions and her faith are stronger than anyone I know.  I went to Utah and visited Michelle in August of this year.  When I returned home, I told a friend about an incident where Michelle’s daughter Sydney was upset about some candy she didn’t get.  As all children do, it was over-dramatized and seemed like the end of the world to little Sydney. Michelle never lost her patience with little Sydney.  In fact, she went beyond the obvious candy problem and figured a lot of Sydney’s emotions were coming from having to recently move out of their home.  She knew what Sydney really needed was stability, reassurance and love, and that’s exactly what she gave her.  I’ve never had children of my own, but many of my friends have, which has given me the opportunity to observe and learn from all of their parenting skills.  I must say I admire Michelle’s the most and would certainly hope that I could be as nurturing, patient, stable, responsible, consistent, loving and true as Michelle.”  Sincerely, Kim McCollum, Words & Music Copyright Administration, Nashville, Tennessee. 

K.                  R. at 445, 10.4.04 Letter from Dustin Olson: “I have had numerous opportunities throughout my life to witness Michelle’s actions in numerous situations.  Michelle consistently considers her possible options and carefully reviews her action and the effect they will have upon others.  When faced with a trial or challenge Michelle will always base her decisions on what is morally right.  Michelle understands that a life without character and integrity is not a life worth living.  As a young child I spent many hours under Michelle’s watchful care.  I can say without hesitation that since childhood her character has had a great influence on my development.  I can also say without reservation that a good portion of the character and integrity that I must rely upon on a daily basis I learned from Michelle….Michelle’s personality can be best described by what she does best.  She is a wonderful mother and takes great pride in this tremendous responsibility.  I have witnessed on numerous occasions Michelle’s parenting style and I have tried to pattern my own parenting style after her……In conclusion, I would like to reaffirm that I hold Michelle Wolfert’s as a person and as a Mother in the highest regard.  I have great respect for her character and personality and I know from firsthand experience that she is a caring and compassionate individual and mother.    

L.                    R. at 447, 10.1.04, Letter from Dr. Matt Parsons:  “…I have personally known and been associated with Michelle Wolferts for the past seven years.  This letter is to confirm my knowledge of her character both personally and as a mother….Michelle has always demonstrated behavior consistent with a very stable emotional personality. Indeed, she has dealt with very significant personal and family stresses in a very calm and productive way.  She has worked hard to provide for her family and always demonstrated optimism and confidence to her girls.  She has always been kind and loving, not only to her own children, but also to their friends and other siblings.  I have never had any reason to doubt that Michelle is anything but the best of mothers.  In my view, she has raised her children in a very impressive and healthy manner.  Her personal integrity is without question.  I admire the way she has lived her life and dealt with life’s twists and turns.” 

M.                R. at 446, 9.30.04 Letter from Karen Parsons:  “I have known Michelle Wolferts for about seven years.  My association with her has been as a neighbor, church member, close personal friend and confidant…..she has always been tolerant, kind and understanding.  I have absolute respect and admiration for her….She is a devoted and loving mother.  She is extremely unselfish and her family has always been her top priority. I have completely trusted my children in her care.  I have seen her under numerous stressful situations including poor physical health, financial strain and six moves in seven years.  I have seen her face these challenges and uncertainties with extraordinary patience and courage.  She has always remained amazingly calm and stable through these times.  Her convictions and morals have remained strong.  She is a trusted and valued friend of mine.  I consider to be an unselfish, devoted and loving mother.”

N.                 Dr. Blakelock’s report of my Mother’s psychological health in the 5.5.10 Default Sanctions custody change hearing:  Cross Examination of Custody Evaluator Harold Blakelock by Mr. Peterson: R. at 2480, 219:22-25, 220:21-25  Q. (By Mr. Peterson), The psychological testing that you performed, did that---were there any elevated levels, for example in the MMPI, or any other---anything else in the psychological testing R. at 2480, 220:1-9 that you performed on anyone that was concerning to you?  A.  Um.  As far as Michelle Wolferts, her---the assessment results for both the PAI and the M---MMPI indicated that she fell within normal limits.  However, on the MMPI it suggested that she was pessimistic.  She had a negative self-image.  But nothing clinically significant.  Q. Was there anything else in the psychological testing that concerned you?   A.  There was really nothing in Michelle’s report.  She was quite normal.  Quite average.  And there were no indications that she had any pathology.

O.                 IN A DEFAULT CUSTODY SANCTIONS TRIAL, EVALUATOR DR. BLAKELOCK TESTIFIED: that mother does not have any mental health issues, is "quite normal", "quite average", and has no indications of any pathology (R. at 2480, 220:23-25), that her children were "independent" and "amazing"  "in a large part” because of mother's parenting (R. at 2480, 245:10-19), that the children get sad when they have to be with their dad for a longer time, that they are very afraid of being punished by dad (R. at 2480, 200:1-4), and that in Mother's custody the children were not depressed, were not anxious, were resilient, and were "quite amazing." He stated the children wanted to be in Mother's custody, acknowledged their reaction would be "one of loss" (R. at 2480, 246:22-25) and that it would be "difficult" for them if they were placed in Petitioner's custody.

II.                 MOTHER HAD NEVER ONCE ACCUSED MY FATHER OF SEXUAL ABUSE OR INFORMED MY SISTERS AND I ABOUT MY FATHER’S SEXUAL PROBLEMS, YET SHE WAS MALICIOUSLY ACCUSED OF INFLUENCING US TO BECOME HYPERVIGILANT ABOUT SEXUAL ABUSE:

A.                  IN ITS 3.23.11, FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER OF MODIFICATION THE COURT RULED:  R. at 2283, 26: The Court adopts Dr. Blakelock’s testimony on each of the 4-903 factors.  Dr. Blakelock testified as follows:  “The children are hyper-vigilant about the issue of sexual abuse due (R. at 2281) to the behavior of the Respondent.  It will be damaging to the children long term to continue to believe that the Petitioner will abuse them.”

B.                  AT THE SAME TIME DR. BLAKELOCK TESTIFIED THAT MY SISTERS AND I SHOULD BE TAKEN FROM MOTHER’S HOME BECAUSE OF AN UNSEEN AND UNREASONABLE SPECULATION THE CHILDREN WERE HYPERVIGILANT ABOUT SEXUAL ABUSE, HE STATED THAT HE WITNESSED THAT HE DID NOT SEE ANY WORRY:

1.                   5.5.10 TRANSCIPRT, CROSS EXAMINATION OF DR. BLAKELOCK BY MR. PETERSON, R. at 2480, R. at 218:16-19  A. The girls right now are hypervigilant.  They have been hypervigilant.  It cannot help a relationship between children and their father.  It’s not very healthy.

2.                   5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKELOCK BY MR. PETERON, 213:19-25  Q.  Are there good reasons in this case not to follow the ATSA guidelines?  A.  The reasons are---and I think I put them in the report---is that Brian’s demonstrated control over any deviant arousal he may have experienced.  The fact that other responsible adults have been informed of his sexual history, so they can monitor. (214:1-4) And the fact that his daughters are of such an age that they’re fully capable, and they’re hypervigilant to any sexually inappropriate behavior that he may engage in. 

3.                   5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKLEOCK BY MR. PETERSON:  R. at 2480, 198:21-25 A.  Basically they talked about, I worry about living with my dad.  And my observations with them on the visit, I didn’t see any worry.  I think that’s something that was instilled in them with the, you know, you’re a risk –you’re at risk of harm with (R. at 199:1-3) your dad.  You have to be supervised.  All those subtle kinds of things can be very damaging.

C.                  THERE IS AN ENORMOUS DIFFERENCE BETWEEN MY MOTHER’S REQUEST FOR MY FATHER TO COMPLETE HIS COURT ORDERED THERAPY WITH DR. ROBY, versus the malicious and harmful accusation that my Mother had accused my Father/Petitioner of sexual abuse or had involved my sisters and I in Petitioner’s sexual problems.

D.                  IT IS NOT AT ALL REASONABLE TO ASSUME THAT MY MOTHER WOULD SUDDENLY CHANGE HOW SHE ALWAYS PROTECTED MY SISTERS AND I FROM HEARING ABOUT COURT PROCEEDINGS ONLY BECAUSE OF DR. ROBY’S 3.27.08 RECOMMENDATION THAT MY FATHER/PETITIONER COMPLETE THE THERAPY PROGRAM.

E.                   MR. PETERSON ACCUSED: “WHY MY MOTHER THOUGHT PETITIONER WAS A RISK TO THE CHILDREN,” WHEN MY MOTHER HAD NEVER BEEN TOLD ANYTHING ABOUT THE FOLLOWING INFORMATION: 5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKLEOCK BY MR. PETERSON:  R. at 2480, 205:23-25  MR. PETERSON: Now, mother ---going back to page 2---excuse me, 3 of your report.  I want to get into now what Mom was all excited about.  Why she thought he was a risk (206:1-6) to the children.  In the last paragraph you indicate that Brian admits to a secra---a sexual ---to a history of sexual contact with a child during his adolescence, for which he was neither investigated nor charged for a crime…206:22-25, THE WITNESS:  I, I think it is, yeah.  I’m not actually certain, because I don’t have it in the report.  AND I HAVEN’T REVIEWED A LOT OF THIS INFORMATION.

1.                   DR. BLAKELOCK’S RESPONSE TO MR. PETERSON WAS THAT HE HAS NOT REVIEWED A LOT OF HIS OWN INFORMATION.

F.                   MY MOTHER’S POLYGRAPH TESTING REGARDING NUMEROUS WRONGFUL, UNREASONABLE, BIASED AND UNJUST ACCUSATIONS OF PARENTAL INTERFERENCE, ALIENATION, AND NON-COMPLIANCE AMONG OTHER WRONGFUL ACCUSATIONS: 

G.                 R. at 1159-1158, PART OF MOTHER’S JANUARY 1, 2009 POLYGRAPH #1,  REPORT OF POLYGRAPH EXAMINATION, POLYGRAPH CASE #2009-101: On January 1, 2009 a polygraph examination was given to Sonja Wolferts.  The purpose of the examination was to determine if the subject was truthful when giving the statement on the two affidavits dated December 11, 2008.  Prior to conducting the polygraph examination, the polygraph instrument was explained to the subject.  She appeared and acknowledged to understand and was cooperative.  He was informed that the examination was being recorded.  The technique used is referred to as the Zone Comparison Test and utilized control questions and relevant issue questions.

Ms. Wolferts stated that she is going through divorce proceedings with Brian Edgar Wolferts.  She made statements in two affidavits that were turned in to the courts and were dated 12-11-08.  I reviewed them with her and she confirmed the truthfulness of the statements.  R. at 1158, The aggregate score on the polygraph test for Sonja Michelle Wolferts indicates truthfulness.  It is the final opinion of the polygraph examiner that the subject is Truthful when she answers questions regarding the target area.  Scott M. Barnett, Certified Polygraph Examiner, Barnett and Associates.

H.                  R. at 851-847, 12.11.08, 61 PARAGRAPH SUPPLEMENTAL AFFIDAVIT IN RESPONSE TO PETITIONER’S ORDER TO SHOW CAUSE   (Also R. at 1157-1153, 12.11.08, 61 Paragraph Polygraph Results) R. at 1157, I, SONJA MICHELLE WOLFERTS, do hereby depose and state under oath, that the following is true and correct to the best of my knowledge, information and belief:

1.                   I have always enjoyed having peace in my life and relationships.

2.                   I have done everything possible to resolve this conflict with Petitioner.

3.                   I have not been unpleasant towards Petitioner throughout this divorce, and have only sought to maintain a safe and peaceful distance while trying to keep life as even as possible for the kids.

4.                   I’ve had offers to live for free with out of area relatives.

5.                   I have stayed here and financially struggled in order to keep the children’s lives going as smoothly as possible.

R. at 1156:

6.                   I believe these children are doing as well as they are because of the love and connections I have tried so hard to keep in their lives.

7.                   It has been a very long time since our separation and divorce (5 years).

8.                   It would be nice if there could be more resolve brought to this situation, I have tried very hard to make this happen.

DATED this 11^th day of December, 2008.

Sonja Michelle Wolferts

I.                    R. at 1159-1158, PART OF MOTHER’S JANUARY 1, 2009 POLYGRAPH #1,  REPORT OF POLYGRAPH EXAMINATION, POLYGRAPH CASE #2009-101: R. at 846-845, 12.11.08, 11 PARAGRAPH SUPPLEMENTAL AFFIDAVIT IN RESPONSE TO PETITIONER’S ORDER TO SHOW CAUSE:  (Also R. at 1152-1151, 12.11.08, 11 Paragraph Polygraph Results)

R. at 1152:

1.                   I have always been very pleasant and accommodating with Petitioner’s visits throughout these 5 years.

2.                   I have been extremely accommodating with Petitioner’s schedule change requests.

3.                   Petitioner was gone for his parent time during several weekends during this last year and I was happy to rearrange the weekends necessary to make this work.

4.                   During one of my scheduled weekends my friends had planned a Baptism and I realized I had overlooked this.

R. at 1151:

5.                   I apologized to Petitioner for forgetting about the Baptism and asked if I might be able to take the kids to this and the luncheon.

6.                   It seems Petitioner may have become angry about me asking for this.  I would not have asked if I would have known he was going to get upset and he did not have to allow the children to attend the Baptism.

7.                   Petitioner has often asked what my plans are first and then seemed to plan events during a few of some of our family Holidays or Reunions, etc.

8.                   I did get stressed after I cancelled 2 trips to see out of state family but I’ve always quickly changed things around and been fine with the new arrangements.

9.                   I asked Petitioner if it would be possible for us to plan on the kids having a certain blocked amount of time with him in the summer for several reasons:

a.                   To avoid past scheduling problems

b.                  To offer us all a time we could plan on every summer

c.                   Allow the kids to have a set summer time with Petitioner and his family

d.                  Allow me to make the necessary plans for a summer income

10.               Petitioner has made repeated complaints over the years that I am doing things I’m not such as giving him problems with phone calls, visits, etc.

11.               I have no reason to do those kinds of things.

DATED this 11^th day of December, 2008.

Sonja Michelle Wolferts

J.                    MY MOTHER’S POLYGRAPH #2 WAS ONLY ONE OF NUMEROUS EXAMPLES INDICATING THE FACT THAT IT WAS NOT MY MOTHERS, BUT MY FATHER’S BEHAVIORS AND INAPPROPRIATE CONVERSATIONS WITH MY SISTERS AND I THAT CAUSED US TO BECOME HYPERVIGILANT OVER THE ISSUE OF SEXUAL ABUSE:

1.                   SEE: MY MOTHER’S JANUARY 1, 2009 POLYGRAPH #2 (R. at 1150-1149),

a.                   # 9:  “I have never told anyone that Brian has inappropriately touched our daughters,” and 

b.                  #10:  “The children came home from their Dec. 27, 2008 visit very upset saying Brian and his wife Angie were both crying and telling them that I was telling people that Brian was touching them in places he is not supposed to.”

K.                  R. at 1148, PART OF MY MOTHER’S JANUARY 1, 2009 POLYGRAPH #2, (R. at 1150-1149), REPORT OF POLYGRAPH EXAMINATION, POLYGRAPH CASE #2009-102: On January 1, 2009 a polygraph examination was given to Sonja Wolferts.  The purpose of the examination was to determine if the subject was truthful when giving the statement on the 20 statement dated 01-01-09.  Prior to conducting the polygraph examination, the polygraph instrument was explained to the subject.  She appeared and acknowledged to understand and was cooperative.  He was informed that the examination was being recorded.  The technique used is referred to as the Zone Comparison Test and utilized control questions and relevant issue questions.

Ms. Wolferts stated that she is going through divorce proceedings with Brian Edgar Wolferts.  She had wrote 20 statements and dated them 01-01-09.  I reviewed them with her and she confirmed the truthfulness of the statements.  R. at 1149, The aggregate score on the polygraph test for Sonja Michelle Wolferts indicates truthfulness.  It is the final opinion of the polygraph examiner that the subject is Truthful when she answers questions regarding the target area.  Scott M. Barnett, Certified Polygraph Examiner, Barnett and Associates:

1.  I am being open and honest with the judges, GAL, Special Master, custody evaluators, ACAFS, attorneys, counselors, DCFS, church leaders and my family.

2.  When one of our children was 3 months old I heard her screaming and ran to the room to see what was wrong.  Brian appeared to be in a rage and was holding her upside down by a foot.  I tried to coax him into giving her to me, then he threw her.

3.  I have never attempted to alienate our children from Brian.

4.  I have never been physically or emotionally abusive to mine or anyone else’s children.

5.  I have not abruptly told the children to get off the phone with Brian nor have I in any way interfered in their phone conversations with him.

6.  Brian has been the only person who has been interfering with the children’s phone conversations.  It appears that he says it am doing the things he is doing, to confuse people.

7.  I have only wanted to give the right people enough information to help others help Brian.  It seems I have been accused and blamed for things I have never intended.

8.  The legal harassment has caused great stress and prevented me from becoming more financially stable.

9.  I have never told anyone that Brian has inappropriately touched our daughters.

10.  The children came home from their Dec. 27, 2008 visit very upset saying Brian and his wife Angie were both crying and telling them that I was telling people that Brian was touching them in places he is not supposed to.

L.                   IT IS A FACT THAT MY SISTERS AND I WERE “HYPERVIGILANT ABOUT THE ISSUE OF SEXUAL ABUSE” WITHOUT MY MOTHER EVER IMPLYING TO US THAT MY FATHER COULD BE A RISK, AND IT IS ALSO A FACT THAT IF THE MY SISTERS AND I WERE HYPERVIGILANT ABOUT THE ISSUE OF SEXUAL ABUSE ONLY BECAUSE OF MY FATHER’S BEHAVIOR WITH US.

M.                AT THE SAME TIME DR. BLAKELOCK STATED THAT HE WITNESSED ME AND MY SISTERS  RELATIONSHIP WITH PETITIONER TO BE “POSITIVE”, “RESPECTFUL”, “GOOD”, “WORRY-FREE”, AND “VERY HAPPY”; HE TESTIFIED THAT WE SHOULD BE REMOVED FROM MY MOTHER BECAUSE OF HIS UNSEEN AND UNREASONABLE SPECULATION THAT MY MOTHER HAD ALIENATED AND CAUSED US TO BE “MALADJUSTED” AND “HOSTILE”, WHEN IT WAS MY FATHER’S SEVERE BRAINWASHING, ALIENATING AND STOCKHOLM SYNDROME THAT CAUSED OUR  GREAT CONFUSION AND HESITANCY AROUND HIM:

1.                   DR. BLAKELOCK DID NOT TESTIFY ABOUT THE FACT THAT WE WOULD FACE HORRIBLE PUNISHMENTS IF WE DID NOT ALWAYS PRETEND TO BE HAPPY AROUND MY FATHER.  5.5.10 TRANSCRIPT, DIRECT EXAMINATION OF DR. BLAKELOCK BY MR. WILKINSON:  R. at 2480, 185:10-25  Q.  (By Mr. Wilkinson)  Did you have an opportunity to observe the children with their stepmother? A.  I did.  Q.  And how would you describe that relationship?  Q.  Affectionate, loving, respectful. (16-17) Q. And you also had the opportunity to observe the children’s interaction with their father?  (18) A.  I did.  (19) Q.  And how would you describe that?  (20-21)  A. More reserved, but respectful.  They seemed to enjoy being in his home.  There was---I used the, the NIMH’s checklist, which is a checklist they use (23-25) to---that I use during an observation.  And it looks at parent-child interaction, child-parent interactions.  186:1-3 And there was sufficient parent-child, child-parent interactions that were positive that everything was, was good.

2.                   THE EFFECTS OF OUR BRAINWASHING, ALIENATING, STOCKHOLM SYNDROME CONFUSION CAUSED BY MY DAD WAS CLEARLY EVIDENT THROUGH DR. BLAKELOCK’S TESTIMONY THAT AT THE SAME TIME MY SISTERS AND I WERE VERY HAPPY AND ENJOYED BEING AROUND OUR FATHER, WE WERE ALSO HOSTILE AND UNHAPPY WITH OUR FATHER, 5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKLEOCK BY MR. PETERSON:  R. at 2480, R. at 179:4-6, When the children are interacting with Mr. Wolferts, my observations were that they were very happy and they enjoyed being around him.

3.                   5.5.10 TRANSCRIPT, DIRECT EXAMINATION OF DR. BLAKELOCK BY MR. WILKINSON:  R. at 2480, R. at 197:16  Q.  Okay.  Were they well adjusted with Mom?  (17) A.  I don’t think so.  (18-19) Q.  Okay. And what led you to form that conclusion?  (20-23) A. Partly because of their relationship or their, their hostility towards their father.  Partly because of the comments that the children made in testing towards their mother and father. 

4.                   5.12.10 TRIAL TRANSCRIPT, R. at 2481, 353:1-9, THE COURT:  Ms. Howard?  MS. HOWARD:  It’s shocking that he testified to that.  There is a basis for her concerns.  There’s also evidence, though, that the children are doing well.  Kadene took the stand.  She stated that the children have a relationship with both parties.   She stated the children are happy.  That they are hesitant to go with their Father.  Why is it implied that it’s Michelle’s fault?  Has anyone stopped to think that it might have (10-13) something to do with Brian’s actions?  Perhaps---this is a wild guess, but perhaps the DCFS finding of abuse against my client in front of the children, had something to do with their concern about their Dad (14-16) But it’s all blamed on Michelle.  It’s her fault.  Oh, no basis.  No basis.

N.                 IN ADDITION, DR. BLAKELOCK:

1.                   Never witnessed my mother causing us to have any of the emotions he stated his testing represented.

2.                   Unreasonably assumed that my dad would abuse my sisters and I while being observed by Dr. Blakelock.

III.              IT WOULD HAVE BEEN FAR MORE REASONABLE FOR DR. BLAKELOCK TO HAVE ASSUMED TRUE AND OBVIOUS FACTS REGARDING HIS TESTING OF MY SISTERS AND I, RATHER THAN STRIVE TO PRESENT EXTREMELY UNREASONABLE AND UNJUSTIFIED ASSUMPTIONS:

A.                  THE FACT THAT DR. BLAKELOCK STATED AN INABILITY TO RECALL THE DCFS FINDINGS OF ABUSE AGAINST PETITIONER IS HIGHLY SUSPICIOUS, AND DR. BLAKELOCK DID NOT APPEAR TO BE EFFECTIVELY TRAINED TO UNDERSTAND THE BRAINWASHING, ALIENATING, STOCKHOLM SYNDROME PERPETRATED BY MY FATHER.

B.                  DR. BLAKELOCK ASKED MY SISTERS AND I TO DRAW PICTURES OF EMOTIONS WE WITNESSED IN OUR FATHER/PETITIONER, then blamed the emotions that we had directly witnessed in our Father and drew pictures about on to our mother; without ever witnessing our mother to be the cause of any of these emotions.

C.                  DR. BLAKELOCK TESTIFIED THAT ACCORDING TO HIS PSYCHOLOGICAL TESTING my sisters and I were very confused about about my father/Petitioners personality, emotions and relationship with us.  In order to reach this conclusion, he administered projective drawings in what he described as attempts to get us to express emotions that we saw in our Father :

1.                  DIRECT EXAMINATION OF DR. BLAKELOCK BY MR. WILKINSON:  5.5.10 TRANSCRIPT, R. at 2480, 180:2-7  The testing show that the children were very confused as well.  As part of the testing I, I administered some projective drawings.  And the result of the projective drawings ---which were basically an attempt to get the girls to express emotions that they see in individuals that they draw these pictures of.  (8-11)  And they drew pictures of Brian with multi-colors.  They were very confused about, about his personality, his emotions.  His relationship with them.

D.                 DR. BLAKELOCK TESTIFIED THAT HIS SENTENCE COMPLETION TEST INDICATED MY SISTERS AND I RESPONDED POSITIVELY ABOUT OUR MOTHER AND NEGATIVELY ABOUT OUR FATHER, wherein he wrongly claimed we were ‘maladjusted’ because our mother caused us to be ‘hostile’, when no one had ever witnessed our Mother causing us to become ‘hostile’, because of the fact that our Mother did not cause us to become hostile towards our Father:

1.                  5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKLEOCK BY MR. PETERSON:  R. at 2480, 198:13-20, Q. (By Mr. Peterson) You mentioned specific examples of things that the children had mentioned in the sen---I believe it was the sentence completion test, or, or some other testing that---A.  This is part of the sentence completion test, yeah. Q. That illustrated the maladjustment of the children with Mom.  

2.                  5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKLEOCK BY MR. PETERSON:  R. at 2480, 193:12-17  A.  As well as, as well as in the assessment I, I administered a sentence completion test.  Which asked questions about the parents.  And the questions were responded to in a positive way when it came to Mrs. Wolferts, and a negative way when it came to Mr. Wolferts.  R. at 2480, R. at 197:16  Q.  Okay.  Were they well adjusted with Mom?  (17) A.  I don’t think so.  (18-19) Q.  Okay. And what led you to form that conclusion?  (20-23) A. Partly because of their relationship or their, their hostility towards their father.  Partly because of the comments that the children made in testing towards their mother and father.

3.                  DR. BLAKELOCK WAS EXTREMELY UNREASONABLE TO BLAME THE EMOTIONAL CONFUSION MY SISTERS AND I EXPERIENCED FROM OUR FATHER’S SEVERE AND CONSTANT TORTURE ON TO OUR MOTHER:  5.5.10 TRANSCRIPT, DIRECT EXAMINATION OF DR. BLAKLEOCK BY MR. WILKINSON:  R. at 2480, R. at 178:19-23   Q.  And the statement’s been made, Michelle’s negative feelings were transparent to the children, and were reflected in the confusion the girl’s expressed related to their negative attachment toward their father.  Are you aware of that statement?  (24) A.  Yes.  (25) Q.  And is that a statement that you made?  (179: 1)  A:  It’s in the settlement conference report. 

E.                  IT WOULD HAVE OBVIOUSLY BEEN FAR MORE REASONABLE FOR DR. BLAKELOCK TO HAVE ASSUMED THE TRUE FACTS THAT:

1.                   We were positive about our mother due to the fact that our mother was consistently positive throughout her interactions with us;

2.                  We were negative about our Father/Petitioner due to the fact that he was consistently negative in his interactions with us;

3.                  Our Father’s constant negativity and bad behaviors throughout his interactions with us were the sole cause of our fears, psychological damage, and worry about living with him.

A.                  THE FACT THAT DR. BLAKELOCK INDICATES A NEED TO MONITOR MY FATHER IN ORDER TO CONTROL RISK, COMPLETELY CONTRADICTS HIS STATEMENT THAT HE BELIEVES THERE IS ZERO RISK.

B.                  DR. BLAKELOCK INDICATES THAT THE FACT THAT OTHER RESPONSIBLE ADULTS HAVE BEEN INFORMED of my Dad’s sexual history was his reason that my Dad was not a risk and reason he did not need to follow ATSA guidelines that would otherwise require my Dad to be supervised around all children. 

IV.              VARIOUS FINDINGS OF RISK FROM DCFS AND THREE INDEPENDENT EXPERT DOCTORS, HAD CLEARLY ESTABLISHED A BASIS FOR ANY REASONABLE PERSON TO BELIEVE THERE COULD BE RISK:

A.      DCFS AND THREE (3) EXPERT DOCTORS HAD ALL INDICATED ON VARIOUS LEVELS THAT MY SISTERS AND I WERE AT RISK WITH MY DAD:

B.      R. at 1768, DCFS SUBSTANTIATED FINDING OF CHILD ABUSE AGAINST MY DAD FOR CASE NO. 1252064, submitted on 5.3.10 Supplemental Exhibit Regarding DCFS Findings of Domestic Related Child Abuse Against the Petitioner in Support of Respondent’s Conflict of Interest Motion; and Response to Petitioner’s Motion to Strike the Respondent’s Motion to Continue:

C.      MR. PETERSON HAD BEEN APPOINTED ON 3.13.06 (R. at 140) DUE TO THE RECENT DCFS FINDING OF ABUSE AGAINST MY DAD (THE PETITIONER):

1.       MR. PETERSON’S ENTRY OF APPEARANCE:  R. at 140-139, 3.13.06, SUBSTITUTION OF COUNSEL, Case No. 044401904, Commissioner Thomas Patton

2.       MR. PETERSON AGAIN REVIEWED THE ABUSE FINDING in his Billing on 5.4.10:  R. at 1787, Reviewed Supplemental Exhibit Regarding DCFS Findings of Domestic Related Child Abuse Against the Petitioner in Support of Respondent’s Conflict of Interest Motion; and Response to Petitioner’s Motion to Strike the Respondent’s Motion to Continue

D.      1. DIRECTOR OVER PETITIONER’S THERAPY PROGRAM FOR FIFTEEN (15) MONTHS, EXPERT DR. C.Y. ROBY:  R. at 464-459, 3.26.08 AFFIDAVIT OF DR. C.Y. ROBY, filed with the Court on 3.27.08 (R. at 490) and 5.20.08 (R. at 564):

1. I, Dr. C.Y. Roby do hereby depose and state, under oath, that the following is true and correct to the best of my knowledge, information and belief:

2. I was asked by the Respondent's attorney to state whether or not it is appropriate for Mr. Wolferts, the Petitioner in this matter, to participate in filial therapy with his children, as previously ordered by the Court, if he has not completed his sex therapy. My professional opinion is that he needs to complete the sex therapy before he participates in any type of filial therapy with the children.

3. The children could be at great risk.

4.  If Mr. Wolferts has a letter from my former associate Mike Cox stating that Mr. Wolferts has completed his therapy, the letter is unauthorized without my signature. I have not signed any such document stating that Mr. Wolferts has completed the program.

5. Mr. Wolferts has not completed the program.

E.       2.  EXPERT DR. JONATHAN RIRIE who spoke with Ms. Dredge numerous times, saw my Dad a few times, and administered my Dad’s Psychosexual Exam.  After testing was completed, Dr. Ririe recommended Supervised visitation with no overnight visitation, which he would not have done without a professional determination of some kind of risk:

1.       11.14.08, AFFIDAVIT OF SANDRA N DREDGE SPECIAL MASTER, R. at 717, ¶ 52. Additionally, I consulted with Dr. Ririe regarding the level of risk Mr. Wolferts is to his children and the impact restricting his contact may have on their long term relationship. Dr. Ririe made recommendations that have been implemented in the ORDER OF THE SPECIAL MASTER DATED NOVEMBER 13, 2008 and attached as exhibit C.

2.       ORDER OF THE SPECIAL MASTER DATED NOVEMBER 13, 2008, R. at 689, 1:1 Dear Brian and Michelle, as you both know Dr. Ririe has completed Mr. Wolferts psycho-sexual evaluation and provided the Special Master with written recommendations.  Therefore, the following is an Order of the Special Master.  Third party supervised visitation:

                                                                         a.      Mr. Wolferts is to have third party day visitation starting November 15, 2008

                                                                        b.      Mr. Wolferts may exercise third party supervised visitation as outlined in the statutory visitation guidelines.  However, no overnight visitation is to take place at this time.

F.       3. EXPERT DR. BLAKELOCK BROUGHT INTO THE CASE BY MR. WILKINSON: DR. BLAKELOCK TESTIFIED THAT THE ATSA STANDARDS (ASSOCIATION FOR TREATMENT OF SEXUAL ABUSERS) that he was required to adhere to indicated that my Dad should be supervised around us (R. at 2480, 212:10-14), while he also testified that he did not believe my Dad needed to abide by the standards:

1.       REASONING BEHIND WHY DR. BLAKELOCK DETERMINED TO MAKE AN EXCEPTION TO HIS ETHICAL GUIDELINES WHEN IT CAME TO MY FATHER.  5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKELOCK BY MR. PETERSON:  R. at 2480, 212:10-22  Q. And---but the ATSA guidelines would nevertheless indicate that he, that he should have---shouldn’t have unsupervised visitation;  is that correct?  A.  Right.  Q.  And what is---what do the AT---why do the ATSA guidelines state that?  A.  Those are default guidelines, and they’re just guidelines to guide clinical judgment.  And each clinician has to make their own judgments.  I can give you an example.  Psychologists aren’t allowed to be naked with their clients.  That’s in the APA ethics.  Can’t do it.

2.       2.11.10 DR. HAROLD BLAKELOCK’S CHILD CUSTODY SETTLEMENT CONFERENCE REPORT, 3:5:  “ In taking his second polygraph, Brian admits to a history of sexual contact with a child during his adolescence for which he was neither investigated nor charged with a crime.  During polygraph in question, Brian also admits that at the age of 23 he exposed himself to two young girls as he exited a shower, and that ‘years later’ he masturbated to thoughts of the older girl (11 or 12 at the time of the incident) by placing her in the position of the younger girl (6 or 7 at the time of the incident).  Ethical standards of the Association for the Treatment of Sex Abusers (ATSA) state “a client who has a history of sexual contact with children or who reports engaging in sexual fantasies about children should be restricted from having unsupervised visitation with Children (Section 12.03, Ethical Standards).   Given a) the significant length of time since Brian’s sexual contact with a child, b) Brian’s demonstrated control over any deviant arousal he may have experienced; c) the fact that other responsible adults have been informed of his sexual history; d) and that his daughters are of such an age where they are fully capable of reporting any inappropriate sexual behaviors on the part of Brian should they occur, this evaluator’s opinion is that Brian poses little or no threat to sexually assault his daughters.  

3.       DR. BLAKELOCK TESTIFIED THAT HIS INDEPENDENT OPINION PRIOR TO SPEAKING WITH OTHERS WHO WERE MUCH LESS INFORMED, HAD BEEN ONE OF CONCERN: 5.5.10 TRANSCRIPT, DIRECT EXAMINATION OF DR. BLAKELOCK BY MR. WILKINSON, R. at 2480, 180:22-25, Q. And did you have any concern that Brian posed any legitimate serious threat to assault his children or abuse his children in any way?  A. When I first started it I kind of reviewed (R. at 2480, 181: 1-5) Some of the material and I was concerned.  But after talking with Dr. Ryrie, reviewing the psychosexual that Dr. Ryrie had completed, and talking with Dr. Dettenmaier, Dr. Dettenmaier showed no, no risk at all.

                                                                         a.      Dr. Lois Dettenmaier was the first custody evaluator in 2007 who recommended that my mother have custody. 

                                                                        b.      Dr. Blakelock allegedly contacted and influenced Dr. Dettenmaier three (3) years later after her 2007 custody report that did not reference anything even close to what Dr. Blakelock represented about Dr. Dettenmaeir’s alleged opinion.

                                                                         c.      There is no evidence that Dr. Blakelock, who I believe was an extremely biased, non-neutral and incompetent evaluator who did not follow Rule 4-903; would have given the appropriate information to Dr. Dettenmaier.

                                                                        d.      Dr. Blakelock indicated that three (3) years after Dr. Dettenmaier’s evaluation and after he spoke with and influenced Dr. Dettenmaier, that she completely changed her opinion about my mother.

                                                                        e.      Dr. Blakelock then indicated that he was the one who had been influenced by Dr. Dettenmaier’s suddenly changed and extremely negative opinion of my mother that he alleges had been formed through his discussions with Dr. Dettenmaier.

                                                                          f.      In addition, Dr. Roby’s report had not been available at the time of Dr. Dettenmaier’s evaluation, and Dr. Dettenmaier did not speak with my mother’s therapist, Dr. Ririe, Dr. Roby or other important collateral individuals and professionals possibly unavailable at the time of Dr. Dettenmaier’s evaluation.

4.       In her 4.27.07 CHILD CUSTODY SETTLEMENT CONFERENCE REPORT (R. at 575), Dr. Lois Dettenmiaer did not report the same information that Dr. Blakelock reported in his custody conference report and in the 5.5.10 Default Custody Sanctions hearing.

5.       DR. BLAKELOCK’S OPINION REGARDING MY DAD/PETITIONER COMPLETELY CONTRADICTED DR. LOIS DETTENMAIER’S OPINION, R. at 575, 1469;  PETITIONER: 

a.       “Appears unable to keep the children outside the parental conflict”

b.      “Appears unable to convincingly encourage positive interactions between his daughters and their mother”

c.       “Appears to experience some difficulty effectively communicating with this children’s mother, without involving the children themselves”

d.      “Perceived as unwilling to support the other parent’s childrearing techniques”

e.       “Fails to accept Michelle as an appropriate Mother to his children”

G.     MR. WILKINSON ENTIRELY MISREPRENTED MATERIAL FACTS REGARDING DR. BLAKELOCK’S TESTIMONY IN MR. WILKINSON’S SELF-IMPOSED VERSION OF THE JUDGE’S FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER OF MODIFICATION:

 

1.       IN ITS 3.23.11 FINDINGS OF FACT MR. WILKINSON ALTERED THE COURT’S RULING TO STATE THAT:  R. at 2108, 36: R. at 2110-2109, 2283, 26: “The Court adopts Dr. Blakelock’s testimony on each of the 4-903 factors.  Dr. Blakelock testified as follows: R. at 2282, M:  “The Division of Child and Family Services supported finding of abuse against the Petitioner occurred at the time of divorce over five (5) years ago and did not involve direct abuse of the children, but domestic violence in the presence of the children.  Due to the time lapse, Dr. Blakelock did not find this supported finding relevant.”

2.       MR. WILKINSON MISCONSTRUED THE MATERIAL FACTS HE WROTE INTO JUDGE JOHNSON’S ORDER TO STATE THAT:

                                                                        a.      Dr. Blakelock testified that the DCFS finding of abuse against my father/Petitioner occurred at the time of the Divorce over five (5) years ago.

                                                                        b.      The DCFS finding of abuse against Petitioner did not involve direct abuse of the children, but domestic violence in the presence of the children.

                                                                         c.      Due to the time lapse, Dr. Blakelock did not find this supported finding relevant.

3.       HOWEVER, DR. BLAKELOCKS ACTUAL TESTIMONY STATES INSTEAD THAT:

                                                                        a.      Dr. Blakelock did not remember when the child abuse had occurred.

                                                                        b.      Dr. Blakelock did not know if the children were present when father committed the abuse substantiated by DCFS or if the abuse occurred.

4.       DR. BLAKELOCK’S TESTIMONY:

                                                                        a.      5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKELOCK BY MS. HOWARD: R. at 2480, 247:10-11  Q. (By Ms. Howard) Were you aware of the report of the DCFS finding of abuse?  (12) Yes, I was.  (13) Q. And do you remember when that occurred?  (14)  No. (20) Q. And did you contact DCFS?  (21) I did not contact them.  I read the report.  (22-23) Q.  All right.  But you didn’t talk with anyone at DCFS?  (24)  No, I did not.  (25) Q.  Even though they had substantiated abuse?  (248:1)  A.  I did not.  (2-4) Q. And do you know if the children were present when Brian committed such alleged abuse that was substantiated by DCFS?  (5) A. I do not.  (6)  Q.  Okay.  (7) MS. HOWARD:  That’s all I have, your Honor.  (8) THE COURT:  Redirect?  MR. WILKINSON:  Thank you your Honor.

                                                                        b.      RECROSS EXAMINATION OF DR. BLAKELOCK BY MR. PETERSON:  5.5.10 TRANSCRIPT, 249: 23-25, Q. The DCFS report that Ms. Howard referred to, that was for domestic violence in front of, in front of a child; is that correct?  250:1  A. I can’t be specific about that.  (2)  Q.  Okay, And--- (3) MR. PETERSON:  That’s it.  (4) MS. HOWARD:  I have nothing more, your Honor.  (5) MR. PETERSON:  Office of Guardian ad Litem rests, your Honor.  (7)  THE COURT:  All right.  

5.       IN MR. WILKINSON’S SELF-IMPOSED VERSION OF THE JUDGE’S FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER OF MODIFICATION; MR. WILKINSON INCLUDED THAT DR. BLAKELOCK TESTIFIED:  “Due to the time lapse, Dr. Blakelock did not find this supported finding relevant.”

                                                                         a.      TO THE CONTRARY, DR. BLAKELOCK HAD TESTIFIED THAT HE DID NOT KNOW WHEN THE DCFS FINDING OF ABUSE OCCURRED: 5.5.10 TRANSCRIPT, R. at 2480, 247:10-11  Q. (By Ms. Howard) Were you aware of the report of the DCFS finding of abuse?  (12) Yes, I was.  (13) Q. And do you remember when that occurred?  (14)  No.

A.      DUE TO THE FACT THAT THE CHILDREN HAD NEVER ONCE TALKED WITH THE GUARDIAN AD LITEM OR SPECIAL MASTER AND NOT REPORTED ABUSE AND A REPORT OF ABUSE HAS TO TAKE PLACE IN ORDER FOR THE POSSILBITY OF “COACHING” TO EVEN EXIST; IT WAS NOT POSSIBLE FOR THE CHILDREN TO HAVE BEEN “COACHED.”

B.      THE FOLLOWING IS KAYDENE JENSEN’S TESTIMONY AND THE ONLY “EVIDENCE” EVER OFFERED REGARDING MOTHER’S ALLEGED “COACHING” THROUGHOUT THE ENTIRE PROCEEDINGS: 5.5.10 TRANSCRIPT, DIRECT EXAMINATION OF KADENE JENSEN BY MR. WILKINSON:  R. at 2480, 145:1-14 Q.  Did you ever develop an opinion that the children were coached?  A.  Yeah.  I think that there was, again as I reviewed these, that there was a period of time where there was a lot of that going on.  Where the kids were talking about reasons why they didn’t want to go on the visits.  And it would relate to the things that Mom had planned with them, or things that they would be doing.  There were times that they would report, though, that they didn’t like it because they thought Dad might be – wouldn’t let them do their homework.  And they were afraid.  And that they were supposed to get their homework done.

C.      DR. BLAKELOCK DISCREDITED OUR FEARS THROUGH CLAIMING THAT (IN HIS BRIEF, APPROXIMATE TWO (2) HOURS OF OBSERVATION) HE DID NOT DIRECTLY WITNESS THE CAUSE OF OUR FEARS:

1. 5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKLEOCK BY MR. PETERSON:  R. at 2480, R. at 200:1-4  A.  I get sad when I have to be with my dad for a longer time.  I’d like to change the divorce.  The worst time I remember is Dad yelling at Mom.   I get very afraid of being punished by my dad.

2. 5.5.10 TRANSCRIPT, CROSS EXAMINATION OF DR. BLAKLEOCK BY MR. PETERSON:  R. at 2480, 198:13-20, Q. (By Mr. Peterson) You mentioned specific examples of things that the children had mentioned in the sen---I believe it was the sentence completion test, or, or some other testing that---A.  This is part of the sentence completion test, yeah. Q. That illustrated the maladjustment of the children with Mom.  (21-25) A.  Basically they talked about, I worry about living with my dad.  And my observations with them on the visit, I didn’t see any worry.  I think that’s something that was instilled in them with the, you know, you’re a risk –you’re at risk of harm with (R. at 199:1) your dad.