Supplement: Timeline leading to the isolation of XXXXXX XXXXXXX from her mother, XXXXX XXXXXXX by Respondent, XXXXX XXXXXXX

I, XXXXX XXXXXXX, declare that I am the Petitioner and moving party herein and I further declare as follows:

1. The events leading to the estrangement of my daughter from me had absolutely nothing to do with my daughter or our relationship. The events leading to my daughter’s complete isolation from her family and me are directly aligned with two events: (1) Respondent getting caught with a child porn subscription and (2) my daughter asking to live with me.

2. In February, 2013, I caught Respondent with yet another paid account to an online posting board known for child pornography (pre-pubescent children). Refer to Exhibit XX for receipts from his personal AMEX to the website portal,, and Respondent’s personal declaration on being a sex addict. Within the last 20 years I have provided for and raised my children despite Respondent losing jobs, breaching work agreements, and failed relationships as a direct result of the severity of his sex addiction. It is unknown whether his job loss at Logitech a year ago was related to his addiction though I have documentation that the pornography account was run through his Logitech email.

Respondent has a long and deep-seated history with child pornography. A year earlier I advised Respondent that if he was caught, yet, again with such material, it would result in our divorce. In fact, his inability to control this addiction is the sole reason I divorced him. While this single issue is monumental, there were no other significant problems in our marriage or with our daughter.

After finding this latest illicit material, I wrote him a letter confirming that I would file for divorce since he continued to secretly act out on his sexual addiction, and was apparently unable to manage it. See Exhibit XX for this letter. I then moved to another bedroom in the house and contacted an attorney to begin divorce proceedings.

Respondent’s response was to shut down all communication with me, become increasingly threatening, and to begin privately communicating with my daughter primarly through text. Refer to Exhibit XX for the phone bills from my daughter’s phone showing over 500-plus texts to my daughter.

I have since uncovered Respondent’s old cell phone and found a number of text exchanges that verbally disparaged me to my daughter in a most paranoid tone. To my shock, beginning at the time he was caught with the porn account, he had begun a campaign of disenfranchising my daughter from me. Refer to Exhibit XX of an example of this dialogue. In this particular example, my daughter and I were getting our nails done. Respondent texted my daughter inquiring where she was. When she responded that she was with me, he advised her not to believe anything I said because I was a liar and went into some elaborate tale about me selling my wedding ring. This was not only out of context, even paranoid; it was nothing to share with a 16-year-old except to perhaps build a wedge between my daughter and me.

Unfortunately for all involved, I did not know this campaign had been waged against me until I found the phone and exorbitant number of text messages months later.

Precipitated by the porn, then divorce proceedings, the lynch pin to the abrupt separation of my daughter and me can be pinpointed to a single event: my daughter advising her father she wanted to live with me.

One afternoon after school my daughter came into my home office to talk, catch up on the day and do her homework as she did every day. She advised me that she wanted to live with me and visit her father. I told her that she needed to tell her father, and of course, that this arrangement sounded fine to me. I left it at that. It sounded as though she had thought it through and her plan sounded rational to me.

When her father came home that night, she immediately ran to her room and locked her door as she did every night he came home. Later after discerning his mood, she came out to eat dinner and to tell him that she wanted to live with me and visit him. Several rooms away I could hear him slamming doors culminating in his storming out of the house and screeching away in his car.

She came back to my office and reported, “That didn’t go well. He was mad,” then went to her room.

Shortly thereafter in June of 2013, Respondent dropped off his personal computers and hard drives to the recycling station in Martinez and proceeded to the courthouse to file a TRO. There is an ongoing FBI investigation on Respondent’s connection with child pornography. Because Sue Mayo, our mediator was unable or unwilling to confirm this investigation, I am including specific contact information for the court’s convenience: XXXX XXXX is the special investigator on the case (415-553-7400). I have provided my permission for him to confirm to the court that we are in communication on this matter though I have been advised that their protocol is to not discuss open cases.

When Respondent’s TRO was rejected in criminal court, he proceeded to family court where his TRO was granted and he was given immediately and unabated control over my daughter for the next 9 weeks.

The night I was removed from my home, XXXXXX refused to go with her father.

She went to stay with her brother (my son) and his family. The following day, Respondent showed up twice, “wound tighter than a top,” by my son’s account and insistent, bordering on threatening, that XXXXXX should come with him immediately.

After seeing her mother removed from her home, after seeing her father gain full control over her when she said she wanted to live with her mother, after being forced to leave her brother’s house, she and her father then went to our home where she helped him empty the contents into a moving van and moved it all into a rental behind a security gate in Blackhawk.

My daughter, my family and my life was completely and inalterably changed by a falsified TRO. Within the TRO documentation, Respondent declared under perjury that he visited his medical doctor (Jeffrey Riopelle’s office) for injuries resulting from an altercation from me. The TRO was filed a week and a half after the alleged assault and the day after my daughter told him she wanted to live with me. The stated date of his visit to the doctor directly corresponds with a bill I received at the house treating the Respondent for a “sinus infection.” No mention or subsequent investigation of domestic violence ever ensued after that doctor’s visit. No subsequent report by the medical doctor was filed.

The fact that the Respondent emptied the contents of my home at will as a result of the TRO is unfair, but nowhere near as overwhelming as the fact that this maneuver allowed him unabated control over my daughter.

During this time, my daughter stopped taking my calls altogether, and eventually stopped communicating with the rest of her family with whom she was raised (not to be confused with Respondent’s first family who he abandoned decades ago in Virginia).

8. I know nothing of my daughter’s plans for college, grades, health or otherwise. I am left to hear shreds of information from concerned friends who tell me about Respondent’s indulgent trips to Disney, multiple Billy Joel concerts, out of state and otherwise. Most importantly, when I do attempt to contact my daughter in any way there are unbridled threats at retaliation.

9. Respondent has gone to extremes to maintain zero communication about my daughter, including when my daughter was in a car accident earlier this year.

At the beginning of February, a friend serendipitously advised me that he was in an car accident. As his story unfolded, I realized the other party was my daughter.

He was extremely kind when he realized that I had been cruelly alienated from my daughter, and deeply disturbed by how such a thing could happen. He went on to relay every detail of the accident, and told me that it had taken two hours to separate the cars. Refer to Exhibit XX for photos of the accident scene and an email sent to me after I told Mr. Whitten of my exhusband’s campaign to keep me from my daughter. The story was extremely upsetting to Mr. Whitten who has continued to suffer from his injuries.

To this day, I have not been advised of this accident by Respondent, the condition of XXXXX or any other details. That I found out in this way is unconscionable, but follows a pattern of cruel intent on the part of Respondent.

9. On January 12 of this year I wrote XXXXX a brief email. See Exhibit XX. On January 17, I received word from Respondent’s attorney misrepresenting my email as a “farewell letter to my daughter” and advising us that XXXXX was “devastated.”

I immediately contacted her school telling them I wanted to see my daughter. I was told that she had been out of school since Wednesday (this was Friday). When my attorney continued to press Respondent’s counsel as to where my daughter was, she would only say that she was on a “college hunting trip.” I contacted the Blackhawk P.D. to advise them that I hadn’t seen my daughter in months and that she was now out of the state. When Lt. Daniel Hoffman contacted Respondent, Respondent fraudulently advised him that he had full custody of my daughter and that there was an order in place keeping me away from both my daughter and Respondent.

I advised Lt. Hoffman that that was incorrect and I took the Order to the police station for his review. While I was sitting in front of Lt. Hoffman, both Respondent and his attorney called Lt. Hoffman several times while I was sitting there. Each was speaking so loudly I could hear them telling Lt. Hoffman that I was “crazy and needed to be kept away from Respondent and my daughter and that the Order said as much.” Lt. Hoffman told me that the Order I presented to him did support the Respondent’s interpretation and if I wanted to see my daughter, I needed to “go back to court.”

While Respondent couldn’t share the location of my daughter, anything about her well-being, but did think enough to start a campaign of “gas lighting” me by relaying that my daughter was devastated before leaving the state on a recreational trip the week before finals, removing my daughter from school for several days.

And while it’s impossible to unequivocally prove they were at a Billy Joel concert in Tampa as she told her friends, she did not apply to any Florida colleges. It is anyone’s guess where they were, especially her mother.

How does life go from “I want to live with my mother” to complete and absolute estrangement? I had my daughter as a single mother and raised her and my sons for many years on my own before Respondent re-entered her life. Refer to the court file XX-XXXXX.

Respondent did not contribute in any way to the first years of my daughter’s life. Nor did he respond to the court’s requests to do so all those years ago. Still it was I who facilitated his re-entering my daughter’s life years later as I know how important both parents are to a child.

How ironic is it that he would be so instrumental in isolating me from my daughter? If nothing else, it speaks to a most vindictive soul.

I ask that as the Respondent continues to “run the clock” toward my daughter’s 18thbirthday next January with obfuscation, misrepresentations and plans to move to the East Coast, that the court pierces the veil of these tactics to provide my daughter a true chance at reunification with her family and me, away from threats of retaliation.

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