Respondent OSC Companion Matter - Fixfamilycourtnow.org

PETITIONER:RESPONDENT:Petitioner1. I CHILD CUSTODY1CASE NUMBER:GINNY L. CALDWELLED 047912-EPKMICHAEL J. CALDWELLAPPLICATION FOR ORDER AND SUPPORTING DECLARATIONXa. Child (name, age)—THIS IS NOT AN ORDER—Respondent Claimant requests the following orders:To be ordered pending the hearingb. Legal custody to c. Physical custody to(person who makes decisions(person with whom child lives.)about health, education, etc.) (name)(name)FL -310r IModify existing order(1) filed on (date):(2) ordering (specify):I 1 As requested in form FL-311 I FL-312 FL-341(C) FL-341(D) I FL-341(E)2. Pi CHILD VISITATION [ 1 To be ordered pending the hearinga. As requested in: (1) I I Attachment 2a (2) Form FL-311 (3)Other (specify):b. Modify existing order(1) filed on (date):(2) ordering (specify):c. One or more domestic violence restraining/protective orders are now in effect. (Attach a copy of the orders if youhave one.) The orders are from the following court or courts (specify county and state):(1) r---1 Criminal: County/state: (3) i I Juvenile: County/state:Case No. (if known):Case No. (if known):(2) - Family: County/state: (4) Other: County/state:Case No. (if known):Case No. (if known):3. —I CHILD SUPPORT (An earnings assignment order may be issued.)a. Child (name, age) b. Monthly amount (if not by guideline)c. I Modify existing order(1) filed on (date):(2) ordering (specify):4. , SPOUSAL OR PARTNER SUPPORT (An earnings assignment order may be issued.)a. L Amount requested (monthly): $ c. flModify existing orderb. L 1 Terminate existing order (1) filed on (date):(1) filed on (date): (2) ordering (specify):(2) ordering (specify):5. -7 ATTORNEY FEES AND COSTS a. Fees: $ b. 1 Costs: $NOTE: To obtain domestic violence restraining orders, you must use the forms Request for Order(Domestic Violence Prevention) (form DV-100) and Temporary Restraining Order and Notice of Hearing(Domestic Violence Prevention) (form DV-110).Form Adopted for Mandatory UseJudicial Council of CaliforniaFL-310 [Rev. January 1. 2007jPage 1 of 2APPLICATION FOR ORDER AND SUPPORTING DECLARATIONFamil y Code, §§2045, 6224, 6226,ai6320-6326, 6380-6383SOrtanSr-Z1Phis

NEIL G. RIMER, Ph.D.Clinical PsychologistCA. LIC. # PSY5767September 21, 2010Carole Baldwin, Esq.BALDWIN & BALDWIN9171 Towne Centre Drive, Suite 440San Diego, CA 92122RE: CaldwellFee for professional services from February — September, 2010:Meeting with Attorneys 1.5 hours @ $200Phone Meeting with Ms. Edmunds 1 hourPhone Meeting with Mr. Caldwell 1 hourReview of Documents/emails1 hourReview of Phone Messages fromTherapistsY2 hourDiscussions with Attorneys and Dr.Bruns re: Procedural Issues 1 hour$300$200$200$200$100$200Total$1200Thank you.N. Ribner, PhD10455 Pomerado Road San Diego, CA 92131Tel: 858.635.4554 Fax: 858.635.4585 email: nribner@alliant.eduEXHIBITA

ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address):CAROLE D. BALDWIN, CFLS, SBN 213310_BALDWIN & BALDWIN9171 TOWNE CENTRE DRIVE, SUITE 440SAN DIEGO, CA 921220 0 2 12EF a.Cot./Ri. Li 0 4 ONLY ‘7 inp,,,,,k.,,im-i-y ,., i t....-- ;,:i: -14 ,_..4 3: 002g10 SEP 2 1r,1 1' r 7FL-320TELEPHONE NO.: 858/452-2898 FAX NO.:ATTORNEY FOR (Name): MICHAEL J. CALDWELLSUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGOSTREET ADDRESS: 250 EAST MAIN STREETMAILING ADDRESS: SAMECITY AND ZIP CODE: EL CAJON, CA 92020BRANCH NAME: EAST COUNTY BRANCHPETITIONER/PLAINTIFF: GINNY L. CALDWELL"' E.N\ '-- t , iti iijuila ,-, -, -Ul'\ :•1144 DiEGO 0...kiillY..RESPONDENT/DEFENDANT:MICHAEL J. CALDWELLRESPONSIVE DECLARATION TO ORDER TO SHOW CAUSEOR NOTICE OF MOTIONHEARING DATE: TIME: DEPARTMENT OR ROOM:OCTOBER 7, 2010 1:45 P.M. 6CASE NUMBER:ED 047912-EPK1. Ir -1 CHILD CUSTODYa. I consent to the order requested.— —b. _J I do not consent to the order requested but I consent to the following order:2. CHILD VISITATIONa. EJ I consent to the order requested.b. _ I do not consent to the order requested but I consent to the following order:3. r CHILD SUPPORTa. I consent to the order requested.b. I I consent to guideline support.c. I do not consent to the order requested, but I consent to the following order:(1) 77, Guideline(2) Other (specify):4. SPOUSAL SUPPORTa. I I consent to the order requested.Ib. j I do not consent to the order requested.c. I consent to the following order:5. ATTORNEY FEES AND COSTSa. I l I consent to the order requested.b I I do not consent to the order requested.c i I I consent to the following order:Form Adopted for Mandatory UseJudicial Council of CaliforniaFL-320 [Rev. January 1. 20031RESPONSIVE DECLARATION TO ORDER TO SHOW CAUSEOR NOTICE OF MOTION_,e galSo uticw-isPlusPage 1 of 2

•••■MalrIt•MICIN ■ It..r..w.A.P.uguolimerwii.neRammaNATintalt■I■ e171!09/22/2010 15:58 6197493666 CSIDENT I TY PAGE 01/0100213PETITIONER/PLAINTIFF: GINNY L. CALDWELLRESPONDENT/DEFENDANT: MICHAEL J. CALDWELLCASE NUMBER:ED 047912-EPK6 ET PROPERTY RESTRAINTa. I I I consent to the order requested.b. I I I do not consent to the order requested.c. I I I consent to the following order.7 I I PROPERTY CONTROLa. I I I consent to the order requested.b I I I do not consent to the order requested.c i I I consent to the following order:3 I x I OTHER RELIEFa. I I I consent to the order requested.b. 1_4 I I do not consent to the order requested.c. I X I I consent to the following order THAT NEIL RIBNER, PH.D., REMAIN AS THE COURT-APPOINTED EVALUATOR AND CASE MANAGER IN THIS CASE.9. 5;7 SUPPORTING INFORMATION[13 contained In the attached declaration,NOTE! To respond to a request for domestic violence restraining orders requested in the Request for Order (Domestic ViolencePrevention) (form DV-100) you must use the Answer to Temporary Restraining Order (Domestic Violence Prevention) (formDV-120).I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.Date:MICHAEL CALDWELLrypE OR PRINTFL-320 (Rev .1*Auaiy 1 20031(SIGNATURE Of DECLARANT)SIGNATURE BY FAXRESPONSIVE DECLARATION TO ORDER TO SHOW CAUSEOR NOTICE OF MOTION

1IN RE MARRIAGE OF CALDWELL — ED0479120021 142ATTACHMENT TO RESPONSIVE DECLARATION TO ORDER TO SHOW CAUSE345678910111213141516171819202122232425262728RELIEF REQUESTEDI ask that the court deny Petitioner's ("Ginny's") request to appoint a new CaseManager. I ask that Neil Ribner, Ph.D., remain in his capacity as Case Manager and730 evaluator.I also request that all custody issues be submitted to Dr. Ribner for his reviewand recommendations, and that we not attend the appointment scheduled at FamilyCourt Services in October.BACKGROUNDOn September 4, 2009, Dr. Ribner was appointed to perform a 730 evaluation.(See Findings and Order After Hearing filed with the court on September 25, 2009.) Itwas Ginny's former attorney who suggested we use Dr. Ribner, and my attorney and Iagreed. He began his evaluation in October and his report was completed onDecember 30, 2009. His initial report was 31 pages long. His addendum, datedJanuary 5, 2010, was one page.Dr. Ribner interviewed me and Ginny separately. He also conductedpsychological testing on both of us. He met with all four of our children, Kasey, nowage 18, Cody, age 16, Kira, age 14, and Kessa, age 10. He met with the childrenseparately, as a group, and separately with me and Ginny.He also interviewed my parents, Ginny's parents, and my former girlfriend eventhough we were no longer together at the time. Ginny married within months of Dr.Ribner completing his report, but her husband, Dave Edmunds, was not mentioned as asignificant other and he was not interviewed in that role.In addition to these family members, Dr. Ribner made numerous collateralcontacts. At Ginny's request he contacted friends: Penny Nagel, Joanne Nagel, DaveEdmunds, Tracey Brunetto and Miguel Lopez. Only Mr. Lopez was noted as a former1

0021512345678910111213141516171819202122232425262728significant other for Ginny.My personal references contacted by Dr. Ribner were Melissa Mason, DesireeDutra, Harold Gottschalk, and Tina Caldwell.Most importantly, Dr. Ribner made numerous professional collateral contacts.These included teachers and personnel from the girls' schools in San Diego (UniversityCity) and Ramona, Dr. Aiello, Dr. Handwerger, Dr. Grayson and Dr. Jackson as well asthe girls' dentist. Dr. Grayson is their pediatrician and Dr. Jackson is Kira's headachespecialist. Dr. Aiello is an Osteopath (D.O.) and Dr. Handwerger is a Naturopath (N.D.).Ginny selected Dr. Aiello and Dr. Handwerger without my input or consent, and she isthe only one who took Kira to see them.Dr. Ribner also tried to get a hold of CPS but they did not return his calls. Dr.Ribner had to rely on minors' counsel's report on her contacts with CPS. Dr. Ribnerreviewed records and a summary report from the therapists at Psycare, and hereviewed Kira's records from Aurora Behavioral Health.Commissioner McKenzie made her orders regarding custody and Dr. Ribner'srole as Case Manager on February 3, 2010. It is my recollection that Ginny objected tominors' counsel being the one we reported to, as originally recommended by Dr.Ribner, and her attorney suggested Dr. Ribner serve as Case Manager. I did notobject. It made sense to me to report to Dr. Ribner because he knew our family welland already had made so many collateral contacts.After Commissioner McKenzie made her orders on February 3, 2010, I did nothave much interaction with Dr. Ribner until the end of April/early May when I providedhim with updates on the girls' behavior and school performance. I was supposed tosend him monthly reports, but it took some time before agreements could be reachedas to how information was to be provided to Dr. Ribner and copied to everyone.Prior to the meeting between Dr. Ribner and the attorneys on June 28, I spokedirectly with Dr. Ribner by telephone. I understand that Ginny had the sameopportunity. In my conversation with Dr. Ribner I gave him my observations of Kira's2

12345678910110021band Kessa's behavior, their school progress, and I gave him an update on my owncounseling and parenting class participation.It was agreed through our attorneys that Ginny and I would not be present whenDr. Ribner met with the attorneys to give his recommendations. Ginny did not makeany objections to Dr. Ribner's role as the Case Manager prior to this meeting. In fact,Ginny did not make any objections to Dr. Ribner as the Case Manager all summer. Sheonly made her objections after she obtained her new attorney, her third attorney sincethis litigation began in 2008, and she filed this motion.Ginny has tried to remove anyone who disagrees with her and who does notsupport her position. She has criticized Commissioner McKenzie, accusing me ofhaving paid her off, Kessa's teacher at Curie Elementary, and my attorney, of course.12She has actively sought to have Lee Lawless removed as minors' counsel, and Ihave13141516171819202122232425262728no doubt that she encouraged Kira in her ex parte motion to have Ms. Lawless taken offthe case. Now she wants to remove Dr. Ribner.At the meeting with the attorneys, Dr. Ribner did not support a change of custodyback to Ginny. He did suggest that we have Kira evaluated further by a psychiatrist, Dr.Bruns, to determine if she needed medication or possibly residential treatment. Kirahas seen Dr. Bruns several times now, including an appointment that involved Ginny.We have not received a report or recommendations from Dr. Bruns yet.Ginny appeared ex parte at the end of the summer attempting to have custodychanged back to her right before school started. This clearly was not an emergencyand she could have set a hearing much earlier in the summer. Her request was denied.Ginny is very upset that custody has not been returned to her, and now Kira isrefusing to return to my care. Ginny is making numerous allegations that I have, at theleast, neglected Kira, and, at the worst, sexually abused her. Attached as Exhibit Aare e-mails dated September 15, 17, and 20 between Ginny and Randy Culver of CPSwhere she makes these allegations against me.The court did not order Ginny and I to take part in a "Parenting Coordination"3

002111234567891011121314151617181920212223242526program. As Dr. Ribner recommended, we were ordered to report to a Case Managerso that person could determine whether the goals set out by Dr. Ribner were being met.The court decided, with input from Ginny's attorney at the hearing, that person shouldbe Dr. Ribner. Commissioner McKenzie noted that Dr. Ribner had testified that hecould act in that role and use his interns as well. (See page 7, lines 5-7 of the OrdersOnly transcript provided by Ginny as Exhibit 2 to her motion.)The "Guidelines for Parenting Coordination" provided by Ginny as Exhibit 3 toher motion also do not state that an evaluator like Dr. Ribner "shall not" act as aparenting coordinator. Again, Dr. Ribner was not called a "parenting coordinator," buteven these guidelines only say that an evaluator "shall be cautious about becoming aPC in the same case..." (Page 6 of Exhibit 3 from Ginny)Unfortunately our case has been very difficult and only seems to be getting morecomplicated. Dr. Ribner is very familiar with everyone involved. It does not makesense to start over with a new evaluator or case manager just because Ginny does notagree with Dr. Ribner's recommendations. It would be very expensive and a waste oftime to bring in someone new.I am also requesting that all issues and requests related to custody be submittedto Dr. Ribner rather than going to Family Court Services. Again, Dr. Ribner is the mostfamiliar with this case, and I do not see how Family Court Services will be able to giveour case the attention it needs. There are even more doctors that will need to becontacted based on appointments that Ginny set for Kira this summer and during thefirst few weeks of school, in addition to the treating physicians and therapists that Dr.Ribner already contacted or from whom he received information as part of his originalevaluation. He should also be given the opportunity to interview Dave Edmunds asGinny's new husband, and to interview anyone else he considers important to this case.END OF DECLARATION27284

Baldwin & Baldwin00218From: "Michael Caldwell" To: "'Baldwin & Baldwin"' Sent: Monday, September 20, 2010 2:05 PMSubject: FW: Ex parteFyi.From: Culver, Randy A [mailto:Randy.Culver@sdcounty.ca.gov]Sent: Monday, September 20, 2010 10:31 AMTo: Culver, Randy A; Ginny - Ecobaby & Pure-Rest Organics; Michael CaldwellSubject: RE: Ex parteI just spoke with the father and he told me the plan was for Kira to go to Cool Beds for a couple weeks. If both ofyou are in agreement, my supervisor stated the meeting I talked about below would not be necessary. Ginny,please confirm about the Cool Beds program. Are you ok with this?RandyFrom: Culver, Randy ASent: MOnday, September 20, 2010 10:14 AMTo: 'Ginny - Ecobaby & Pure-Rest Organics'; 'Michael Caldwell'Subject: RE: Ex parteSince Kira is refusing to go to the father's and has been staying with friends, this agency would like to do a familymeeting to discuss short term placement issues. We would like to come up with a short term plan to keep her safewhile the case goes through Family Court. We would like everybody to be involved, including the friend she isstaying with and her parents, the person that took her to court the other day, and any other relatives in the area.Please email me your answer as soon as you can and then try to get me whatever names and numbers of peoplewho could possibly attend the meeting. Thank you very much.Randy Culver, PSWFrom: Ginny - Ecobaby & Pure-Rest Organics [mailto:Ginny@ecobaby.com]Sent: Friday, September 17, 2010 12:24 PMTo: Culver, Randy ASubject: RE: Ex parteShe told him the second day of school August 31st. He had her for the next 11 days. This is serious.Not an email, she told him. He cannot now as she is scared. Someone needs to take her for her safety.On another note. I have talked with an attorney and they say that if CPS ignores the fact that Kira isreporting these things, especially the touching of her tummy, thighs and pressing up against her backagainst her will, that they need to know that CPS was indeed informed. So I am making this clear. Iknow Kira also told you about this. She says it feels wrong but she is innocent and does not understandwhat ramifications of this kind of unwanted touching may be.From: Culver, Randy A [mailto:Randy.Culver@sdcounty.ca.gov]Sent: Friday, September 17, 2010 12:09 PMTo: Ginny - Ecobaby & Pure-Rest OrganicsSubject: RE: Ex parteEXHIBIT{ 9/22/2010

t'age 2 of 3Are you sure the dad knows about the ear infection? Do you have an email where you or Kira told himOit2How can he take her to the doctor if she refuses to see him?qFrom: Ginny - Ecobaby & Pure-Rest Organics [mailto:Ginny@ecobaby.corn]Sent: Friday, September 17, 2010 11:35 AMTo: Culver, Randy ASubject: RE: Ex parteWhy does CPS keep ignoring that her father, in anger, damaged her arm and she has been in pain forthe last 11 months due to this?That she is being touched now, this is recent only.That she is not getting her medical needs met.Who is going to take her to doc for her ear infection before she becomes deaf?You must have some care for this child.From: Culver, Randy A [mailto:Randy.Culver@sdcounty.ca.gov]Sent: Friday, September 17, 2010 11:04 AMTo: Ginny - Ecobaby & Pure-Rest OrganicsSubject: RE: Ex parteI am not going to mandate that she stay anywhere. If she wants to go to a neutral place, she can call StorefrontTeen Center at (619) 325-3527.http://www.sdyouthservices.org/site/PageServer?pagename=storefrontFrom: Ginny - Ecobaby & Pure-Rest Organics [mailto:Ginny@ecobaby.com]Sent: Friday, September 17, 2010 9:54 AMTo: Culver, Randy ASubject: RE: Ex parteSince when does CPS not care that her father permanently damaged her arm in his anger?That her father touches her against her will, hugging her with his body pressed from behind, touchingher thighs, touching her stomach. This is ridiculous and I have got to get this lack of response out there.I need to speak to a supervisor before she protects herself with a knife and someone gets killed. Shehas pepper spray for her protection right now.Kira was basically on her own last night. She found a friend to stay with. What does she do?From: Culver, Randy A [mailto:Randy.Culver@sdcounty.ca.gov]Sent: Wednesday, September 15, 2010 6:43 PMTo: Ginny - Ecobaby & Pure-Rest OrganicsSubject: RE: Ex parteGinny,Just wanted to let you know that I'm not ignoring you but I still need a couple more things before I'm done here. Atthis point, there is nothing that would allow our agency to intervene. I have talked to several people so far andhave one more to talk to before I interview the father. I read all the documents you sent me. One question for you:After Kiera met with Dr. Grayson, she recommended she see an orthopedic specialist. I see that she saw Dr.Stricker on 8/10/10. Did the dad take her or make this appt. for her?Thanks,Randy9/22/2010

Page 3 o13From: Ginny - Ecobaby & Pure-Rest Organics [mailto:Ginny@ecobaby.com]Sent: Wednesday, September 15, 2010 4:43 PMTo: Culver, Randy ASubject: FW: Ex parteGinny:The judge denied the temporary restraining order but per Kira's request a hearing has been set for 3pm on October 6 on theissue of a permanent restraining order.I will call soon.MyraTomorrow morning the father and his attorney are trying to get the court to order Kim to go to her fathers house.This means that Kira may have to go to her dads or somewhere for 3 weeks where the judge will thenlater determine if she is abused enough for her to get a permanent restraining order against him. Who isbearing responsibility when Kira runs away or gets hurt due to this? CPS is acting quite slow in avolatile situation. Kira wants to know if CPS can take her to a safe place for 3 weeks unless someonewill permit her to stay with any of her relatives here in San Diego. She has a lot.Ginny9/22/2010

1234567CAROLE D. BALDWIN, CFLS, SBN 213310BALDWIN & BALDWIN9171 Towne Centre Drive, Suite 440San Diego, CA 92122Telephone: (858) 452-2898Attorney for Respondent,MICHAEL J. CALDWELLu214 Ft'CLERC-S1.)SPN DEG( COUNT. Y:8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGO910 In Re the Marriage of: Case Number ED 047912-EPK11121314Petitioner: GINNY L. CALDWELLandRespondent: MICHAEL J. CALDWELLNOTICE OF INTENTTO LODGEDate: October 7, 2010Time: 1:45 p.m.Dept: 61516171819202122232425On behalf of the Respondent, MICHAEL J. CALDWELL, the followingdocuments will be lodged with the Court:EXHIBIT A: Request for Production of Documents and Other TangibleThings Set: Three propounded by Petitioner to Respondent, dated 03/19/2010.EXHIBIT B: Respondent's Response to Petitioner's Demand forProduction and Inspection of Documents — Set One (1), dated 08/15/2008.EXHIBIT C: Respondent's Response to Petitioner's Request forProduction of Documents and Other Tangible Things — Set Two, dated 07/14/2009.EXHIBIT D: Letter from Carole D. Baldwin to Garrison Klueck dated06/24/2010 in response to Mr. Klueck's "meet and confer" letter dated 06/09/2010.Respectfully submitted,2627 DATE: ;c6t I/0 (7-a7tde.28NOTICE OF INTENT TO LODGECAROLE D. BALDWIN,Attorney for Respondent1

ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address):CAROLE D. BALDWIN, CFLS, SBN 213310--BALDWIN & BALDWIN9171 TOWNE CENTRE DRIVE, SUITE 440SAN DIEGO, CA 921220 ? 0 f__, 1 FOR COURT USE ONLY*- r■ nip FM 3: 0 1Sy 4 iillt tFL-320TELEPHONE NO.: 858/452-2898 FAX NO.:ATTORNEY FOR (Name): MICHAEL J. CALDWELLSUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGOSTREET ADDRESS: 250 EAST MAIN STREETMAILING ADDRESS: SAMECITY AND ZIP CODE: EL CAJON, CA 92020BRANCH NAME: EAST COUNTY BRANCHPETITIONER/PLAINTIFF: GINNY L. CALDWELL=-. ...' ''T,,_i iil I1:itsly t..:,-RESPONDENT/DEFENDANT:MICHAEL J. CALDWELLRESPONSIVE DECLARATION TO ORDER TO SHOW CAUSEOR NOTICE OF MOTIONHEARING DATE: TIME: DEPARTMENT OR ROOM:OCTOBER 7, 2010 1 :45 P.M. 6CASE NUMBER:ED 047912-EPK1. CHILD CUSTODYa. .2 I consent to the order requested.b. I__ I do not consent to the order requested but I consent to the following order:I2. CHILD VISITATIONa. I I consent to the order requested.b. I do not consent to the order requested but I consent to the following order:II3. CHILD SUPPORTa. I I consent to the order requested.b. i I consent to guideline support.c. u I do not consent to the order requested, but I consent to the following order:(1) ■ Guideline(2) I Other (specify):4. SPOUSAL SUPPORTa. I consent to the order requested.b. I I do not consent to the order requested.c. n I consent to the following order:. ATTORNEY FEES AND COSTSa. r I consent to the order requested.b. I do not consent to the order requested.c. I consent to the following order:Form Adopted for Mandatory UseJudicial Council of CaliforniaFL-32C ;Rev. January 1, 2003;RESPONSIVE DECLARATION TO ORDER TO SHOW CAUSEOR NOTICE OF MOTIONLegalSolutrgns-4;L PlusPaget of 2

INEMC1 7L:141ZOIIIII■11111•111 1111r4ILEWINIMMIZIME3 11.09/23/2010 13:19 6197493666 CSIDENTI TY PAGE 02/02PETITIONER/PLAINTIFF: GINNY L. CALDWELLCASE NUMBER.RESPONDENT/DEFENDANT: MICHAEL J. CALDWELL ED 047912-EPK6 I I PROPERTY RESTRAINTa I consent to the order requested.b I I I do not consent to the order requested.C. I I I consent to the following Order.7. I I PROPERTY CONTROLa. El I consent to the order requested.I do not consent to the order requested.c. I I I consent to the following order:8 L.JSJ OTHER RELIEFa. 0 I consent to the order requested.b. DO I do not consent to the order requested.c. EN I consent to the following order: COURT DENY PETITIONER'S MOTION TO COMPEL FURTHERRESPONSE AND IMPOSE SANCTIONS AGAINST PETITIONER FOR FILING THISUNJUSTIFIED MOTION.9. I X 1 SUPPORTING INFORMATION11) contained in the attached declaration.NOTE: To respond to a request for domestic violence restraining orders requested in the Request for Order (Domestic ViolencePrevention) (form DV- 100) you must use the Answer to Temporary Restraining Order (Domestic Violence Prevention) (formDv-120).I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.Date: Ct/3//MICHAEL CALDWELL(TYPE OR PRINT NAME)(S4ONAToRE Of DECLARANT)SIGNATURE BY FAXF L420 (Rev. Jemmy 1, 20031 RESPONSIVE DECLARATION TO ORDER TO SHOW CAUSE PaG•tot 2OR NOTICE OF MOTION

1 when I responded to the request propounded by Mr. Mason on Ginny's behalf the2 summer before. I referred them to my previous response provided to Mr. Mason.3 Ginny did not file a motion to compel after I responded to this second set of document4 requests.5 Redacted Information:6 In my most recent response to Ginny's request for production of documents, my7 attorney blacked out a few transactions on my checking account statements and credit8 card statements. The attorney/client privilege was asserted on my behalf because9 these transactions were payments made to professionals advising me in my legal case.10 The dates and the amounts of the transactions were not blacked out. Only the11 names of the recipients were redacted. When I received the meet and confer letter12 from Mr. Klueck, I once again reiterated my response that this was privileged13 information and they were informed that these payments were made to the14 professionals assisting me with my case. Lodged as Exhibit D is a copy of my15 response to their meet and confer letter. I went into significant detail to provide them16 with answers to their questions about various documents and transactions. I have been17 cooperative and forthcoming in all of my responses to Ginny's requests for discovery.18 The redacted portions of my bank and credit card statements do not interfere with her19 ability to ascertain how much money I maintain in my accounts and how much I spent20 during the period in question.21 Sanctions:22 This motion was completely unwarranted and is just an attempt to disparage me23 in the eyes of the court. I am requesting that the court order sanctions against Ginny24 for at least $1,000. My attorney's hourly rate is $300, and she spent approximately one25 hour of her time preparing this response plus her staff's time which is billed at $110 an26 hour. i anticipate that I will be billed another two hours of my attorney's time to appear27 in court and argue against this motion.28 IEND OF DECLARATIONI2