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123456CAROLE D. BALDWIN, CFLS, SBN 213310Baldwin & Baldwin9171 Towne Centre Drive, Suite 440San Diego, CA 92122Telephone: (858) 452-2898At<strong>to</strong>rney for <strong>Respondent</strong>,MICHAEL J. CALDWELLRECEIV E DClerk of the Superior CourtMAR 1 7 2009By: K. SHAFFER, DeputyEAST COUNTY DIVISION78SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGO910111213141516171819In Re the Marriage of: Case Number ED 047912Petitioner: GINNY L. CALDWELLand<strong>Respondent</strong>: MICHAEL J. CALDWELLLODGMENTDATE: 3/18/09TIME: 9:00 AMDEPT: 6On behalf of the <strong>Respondent</strong>, MICHAEL J. CALDWELL, the followingdocuments have been lodged with the Court:EXHIBIT A: Court Transcript from December 16, 2008 HearingEXHIBIT B: E-mail from Petitioner dated November 24, 2003EXHIBIT C: Ecobaby Paystub for period of 7/30/2003-8/12/200320212223DATE: 3h7/09'0a)--K4 661,a0E-,CAROLE D. BALDWIN, At<strong>to</strong>rney for <strong>Respondent</strong>2425262728LODGMENT1


IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIAIN AND FOR THE COUNTY OF SAN DIEGOEAST COUNTY DIVISIONDEPARTMENT 6HON. CHRISTINE K. GOLDSMITH, JUDGE)JENNY CALDWELL, ))PETITIONER, )VS.)) CASE NO.)MICHAEL CALDWELL, ))RESPONDENT )COPYED47912)REPORTER'S TRANSCRIPTDECEMBER 16, 2008PAGES 1 THROUGH 10APPEARANCES:FOR THE PETITIONER:FOR THE RESPONDENT:JOSH MASONATTORNEY AT LAWCAROL BALDWINATTORNEY AT LAWCINDA L. TEMMER, CSRCSR CERTIFICATE NO. 11021OFFICIAL REPORTER250 EAST MAIN STREETEL CAJON, CALIFORNIAEXHIBIT ACINDA L. TEMMER, CSR NO. 11021


I 112EL CAJON, CALIFORNIA, DECEMBER 16, 2008PROCEEDINGS345678910111213141516171819202122232425262728THE COURT: JENNY CALDWELL AND MICHAELCALDWELL, ED 47912.MR. MASON: GOOD AFTERNOON, YOUR HONOR.JOSH MASON APPEARING FOR THE PETITIONER WHO IS NOTPRESENT.MS. BALDWIN: GOOD AFTERNOON, YOUR HONOR.CAROL BALDWIN ON BEHALF OF THE RESPONDENT, MICHAELCALDWELL, WHO IS PRESENT IN COURT.YOUR HONOR, THIS IS OUR MOTION TO HAVE THEMARITAL SETTLEMENT AGREEMENT SIGNED BY THE PARTIESIN NOVEMBER OF 2003, ENTERED AS A JUDGMENT OF THECOURT. THE MFA CLEARLY STATES ON PAGE 1 AND LINE 1,THAT IT WAS EFFECTIVE THE DATE IT WAS SIGNED.PROVISION 60 ON PAGE 28 OF THE AGREEMENT STATES VERYCLEARLY THAT, QUOTE, THE AGREEMENT IS NOTCONDITIONAL UPON ITS INCORPORATION, MERGER ORFILING.THE PARTIES INITIALED EVERY PAGE ANDSIGNED THE DOCUMENT BEFORE A NOTARY. MS . CALDWELLSIGNED IT BEFORE A NOTARY FIRST AND THEN MR.CALDWELL SIGNED IT BEFORE A DIFFERENT NOTARYTHIRTEEN DAYS LATER.THE MSA STATES THAT NEITHER PARTY WILL PAYCHILD SUPPORT TO THE OTHER AND THEY BOTH WAIVESPOUSAL SUPPORT, AMONG OTHER PROVISIONS, YOUR HONOR.14:04:2614:04:4214:04:5714:05:1614:05:26CINDA L. TEMMER, CSR NO. 11021


2123456710111213141516171819202122232425262728MS. CALDWELL ACKNOWLEDGES IN HER RESPONSETO OUR MOTION THAT THE AGREEMENT LOOKS TO BE SIGNEDBY HER AND SHE RECALLS SIGNING AN AGREEMENT TO MOVEWITH THE CHILDREN TO CANADA. SHE ACCUSES MR.CALDWELL OF TAKING THE SIGNED PAGES FROM A DIFFERENTAGREEMENT AND INSERTING THEM INTO THIS AGREEMENT.SHE DOES NOT PROVIDE A COPY OF THIS OTHER ALLEGEDAGREEMENT. SHE DOESN'T EVEN GIVE US THE NAME OFTHIS OTHER AGREEMENT.NOW, WE HAVE PROVIDED THE COURT WITHCOPIES OF TRANSMITTAL LETTERS SENT IN 2003 TO BETHSAMPLE AND TO MS. CALDWELL THAT INDICATE A MARITALSETTLEMENT AGREEMENT WAS SENT TO THEM FOR THEIRREVIEW. THOSE TRANSMITTAL LETTERS DID NOT SAY ANAGREEMENT ABOUT A RELOCATION. THERE WAS NO OTHERAGREEMENT SIGNED BY THE PARTIES, YOUR HONOR.NOW, SHE DOES NOT EVEN QUESTION HERINITIALS THAT ARE ON EVERY SINGLE PAGE, INCLUDINGTHE PAGES ABOUT THE WAIVERS OF SPOUSAL SUPPORT ANDCHILD SUPPORT. SHE MAKES AN ISSUE OF THE FONT SIZEON THE LAST FEW PAGES OF THE AGREEMENT, BUT THEPROVISIONS REGARDING SUPPORT ARE MUCH EARLIER IN THEDOCUMENT AND AGAIN INITIALED BY HER.WE ASKED FOR HER COOPERATION, YOUR HONOR,TO SUBMIT HER HANDWRITING SAMPLES TO AN EXPERT; WEDID NOT GET A RESPONSE. IF MR. CALDWELL TAMPEREDWITH THIS DOCUMENT AS SHE APPEARS TO ALLEGE, HE HADTO DO IT OVER FOUR YEARS AGO, YOUR HONOR, BECAUSE14:05:5114:06:0414:06:2014:06:3814:06:53CINDA L. TEMMER, CSR NO. 11021


312345678910111213141516171819202122232425262728THIS DOCUMENT HAS BEEN IN MY FILE IN MY OFFICE FOROVER FOUR YEARS. BOTH OF THESE PARTIES HAD ANOBLIGATION TO SEE THAT THIS AGREEMENT WAS FILED. ITWAS NOT MR. CALDWELL'S SOLE RESPONSIBILITY AND ATTHE TIME THAT THEY BOTH SIGNED IT, NEITHER ONE OFTHEM REALLY HAD AN ATTORNEY INVOLVED AT THAT POINT.THEY SIGNED AND MS. CALDWELL MOVED TO CANADA. THATDID NOT WORK OUT AND SHE MOVED BACK IN 2004.IF WE ALSO LOOK AT HER OTHER BEHAVIORAFTER THE MSA WAS SIGNED, SHE NEVER REQUESTEDSUPPORT FROM MR. CALDWELL. SHE DID FILE A MOTION INNOVEMBER OF 2004, BUT IT DID NOT MENTION ANYTHINGABOUT ARREARS. AND WHY FILE IT AT ALL IF SHE WASUNDER THE IMPRESSION SHE ALREADY HAD SUPPORT ORDERS.SHE DROPPED THAT MOTION, DROPPED IT AFTER MR.CALDWELL REQUESTED DISCOVERY FROM HER INCLUDINGREQUESTS FOR HER INCOME INFORMATION AND CORPORATETAX RETURNS FOR THE COMPANY SHE RUNS CALLED ECOBABY. SHE NEVER RESPONDED TO THOSE DISCOVERYREQUESTS AND WAS SANCTIONED FOR THAT CONDUCT.AFTER SHE BROUGHT THAT MOTION, THEREWASN'T A WORD ABOUT SUPPORT, YOUR HONOR, NOT ALETTER, NOT A PHONE CALL, NOT AN E-MAIL, NOT FROMHER OR AN ATTORNEY ACTING ON HER BEHALF. THERE HASBEEN NO INVOLVEMENT WITH D.C.S.S., NO REQUEST FOR ATRIAL TO ADDRESS THE ASSETS THAT SHE NOW CLAIMSSHE'S ENTITLED TO.SHE DID NOTHING UNTIL FIVE YEARS LATER,14:07:2114:07:3914:07:5414:08:0814:08:23CINDA L. TEMMER, CSR NO. 11021


4123456789101112131415161718192021222324252627282008, WHEN SHE FILED HER MOTION FOR ARREARS CLAIMINGTHAT MR. CALDWELL OWES HER OVER $200,000 AS OFAPRIL. IN HER ARREARS MOTION, SHE NOTES THAT SHE ISNOT REQUESTING SUPPORT FOR THE PERIOD THAT THEYRECONCILED BETWEEN 2000 AND 2003.IN HER RESPONSE TO OUR MOTION FOR THEENTRY OF JUDGMENT, SHE CLAIMED THAT SHE NEVER WOULDHAVE WAIVED SPOUSAL SUPPORT OR CHILD SUPPORT, BUTTHE WAIVER OF SPOUSAL SUPPORT ACTUALLY PROTECTEDHER. MR . CALDWELL HAD NO INCOME TO REALLY SPEAK OFAT THE TIME OF THEIR SEPARATION. HE HAD TO DECLAREA LOSS FOR HIS BUSINESS, MJC ENTERPRISES IN 2003,AND THE WORK HE WAS DOING THROUGH THAT BUSINESS WASJUST FOR THE BENEFIT OF ECO BABY WEB HOSTINGSERVICES. SO HE HAD NO REAL INCOME OF HIS OWN.AFTER THEY RECONCILED IN 2000, HE WAS TAKING CARE OFTHE CHILDREN WHILE SHE WORKED ON HIS BUSINESS.AS FOR WAIVING CHILD SUPPORT, SHE WANTEDTO MOVE, YOUR HONOR. SHE WANTED TO MAKE ASIGNIFICANT MOVE ALL THE WAY TO CANADA. AND, AGAIN,SHE KNEW THAT HE DID NOT HAVE INCOME AT THAT TIME.NOW SHE WANTS TO BENEFIT FROM ORDERS MADEBACK IN 2000 BEFORE THEY RECONCILED THAT SAME YEARAND WANTS OVER 200,000 FROM MR. CALDWELL.NOW SHE'D ALSO LIKE THE COURT TO BELIEVETHAT HE'S SOME KIND OF DEADBEAT DAD WHO DOESN'T DOANYTHING FOR HIS CHILDREN AND, IN HER WORDS, IS"LIVING HIGH ON THE HOG."14:08:5214:09:0514:09:2314:09:3714:09:54CINDA L. TEMMER, CSR NO. 11021


512345678910111213141516171819202122232425262728MR. CALDWELL PAID OFF SIGNIFICANTCOMMUNITY DEBTS WITH NO CONTRIBUTION FROMMS. CALDWELL; HE PAID OFF THE LOAN THAT WAS ASSIGNEDTO HER UNDER THE MSA BECAUSE HE NEEDED TO PROTECTHIS OWN CREDIT, THE LOAN WAS IN BOTH OF THEIR NAMES.BUT IT SHOULD BE NOTED THAT THAT LOAN WAS TAKEN OUTFOR THE SAKE OF ECO BABY AND IT WAS ANTICIPATED ATTHE SIGNING OF THIS AGREEMENT THAT IT WAS GOING TOBE ECO BABY THAT WAS GOING TO REPAY THAT LOAN; THEBURDEN WASN'T SOLELY ON MS. CALDWELL ALONE, IT WASTHE BUSINESS. BUT THAT BUSINESS NEVER PAID IT OFF,HE DID.MR. CALDWELL HAS PROVIDED HEALTH ANDDENTAL INSURANCE FOR THE CHILDREN AND PAID MEDICALAND DENTAL BILLS WITH NO REIMBURSEMENT FROM MS.CALDWELL. HE HAS PURCHASED BASIC TOILETRIES,CLOTHING, AND OTHER THINGS THE KIDS NEEDED OVER THEYEARS. SHE'S CLAIMED THAT SHE HAS RAISED THESECHILDREN BY HERSELF AND DOESN'T EVEN ACKNOWLEDGE THETIME THAT HE DOES SPEND WITH THEM, THE PURCHASES HEMAKES, OR THE FACT THAT HER OLDEST SON HAS NOT LIVEDWITH HER SINCE 2004. WE BELIEVE HER OWN PARENTSCLAIM HIM ON THEIR TAX RETURN. SHE DID NOT CLAIMHIM ON HER TAX RETURN IN '04, AND WE DON'T HAVE ANYOTHER TAX RETURNS FOR HER SINCE THAT TIME, YOURHONOR.THE SECOND OLDEST CHILD IS ALSO NOW LIVINGPRIMARILY WITH THE GRANDPARENTS. SHE LIVES IN AN14:10:1614:10:5214:11:14CINDA L. TEMMER, CSR NO. 11021


612345678910111213141516171819202122232425262728AFFLUENT NEIGHBORHOOD, DRIVES A NEW CAR, BUT WANTSTHE COURT TO BELIEVE SHE'S BARELY EVEN GETTING BY.BY NOT ENTERING THIS AGREEMENT, WHICHSTATES SPECIFICALLY THAT IT'S EFFECTIVE AS OF THELAST DATED SIGNATURE OF THE PARTIES, WHICH WASNOVEMBER 26, 2003, MS. CALDWELL WILL ABSOLUTELY BEUNJUSTLY ENRICHED AND THIS WOULD BE AN INJUSTICEWHICH SHOULD BE CORRECTED BY ENTERING THE MSA. ANDTHE COURT CAN DO SO NUNC PRO TUNC IN ORDER TO AVOIDSUCH AN INJUSTICE.NOW, WE HAVE LODGED THE COPY, NOT THECOPY, THE ORIGINAL MSA WITH THE COURT, YOUR HONOR.DOES THE COURT HAVE ANY QUESTIONS FOR ME?THE COURT: NO, THANK YOU.MR. MASON?MR. MASON: THANK YOU, YOUR HONOR.YOUR HONOR, IT IS MS. CALDWELL'S POSITIONTHAT THERE ARE AT LEAST THREE REASONS WHY THISAGREEMENT SHOULD NOT BE ENTERED TODAY.THE FIRST ONE IS THE AUTHENTICATION ISSUESTHAT SHE HAS RAISED. IF YOU LOOK AT THISAGREEMENT -- AND I'M ASSUMING THE ONE THAT THE COURTHAS IS THE SAME ONE THAT I HAVE -- ON PAGE 37, THESIGNATURE PAGE IS A COMPLETELY DIFFERENT SIZE ANDFONT THAN THE REST OF THE AGREEMENT. PAGE 38 ISMISSING. PAGE 39 AND 40 GO BACK TO THE ORIGINALSIZE OF THE REGULAR AGREEMENT. PAGES 41 TO 44,WHICH ARE THE PAGES THAT DIVIDE A COUPLE OF THE14:11:3314:11:,4514:12:0014:12:1314:12:29CINDA L. TEMMER, CSR NO. 11021


712345678910111213141516171819202122232425262728MARITAL ASSETS, GO BACK TO THE SMALLER FONT SIZETHAT'S THE SAME AS THE SIGNATURE PAGE. THEN PAGES45 TO 49 ARE MISSING AND THEN PAGE 50, THE NOTARYPAGE, GOES BACK TO THAT SMALL FRONT THAT'S THE SAMEAS THE SIGNATURE PAGES.ALL OF THOSE THINGS CALL INTO QUESTION THEAUTHENTICITY OF THIS AGREEMENT AND WITH THAT BEINGTHE CASE, WE CAN'T ENTER THAT THING INTO JUDGMENTTODAY WITH PAGES MISSING, DIFFERENT FONT SIZES ONDIFFERENT PAGES; IT'S JUST TOO FISHY TO ME.THE SECOND REASON IS BECAUSE OF ALL THEASSETS THAT ARE NOT TAKEN CARE OF IN THAT AGREEMENT.THE AGREEMENT OMITTED THE MARITAL RESIDENCE. ITOMITTED RESPONDENT'S BUSINESS, A VEHICLE, DUNEBUGGY, AND A TRAILER, AND RESPONDENT'S RETIREMENTAND 401-K. IF WE ENTER THAT JUDGMENT TODAY, WESTILL HAVE TO DEAL WITH ALL OF THOSE ISSUES.AND, FINALLY, THE ENTRY OF THAT JUDGMENTTODAY REALLY IS NOT GOING TO DECREASE THE LITIGATIONTHAT'S GOING TO HAVE TO HAPPEN IN THIS MATTER. YOUKNOW, HONESTLY IF IT'S ENTERED TODAY, THEN WE'REGOING TO HAVE TO FILE A MOTION TO MODIFY THE SUPPORTAND DIVIDE ALL THE ADMITTED ASSETS. IF IT'S NOTENTERED TODAY, THEN THEY'RE PROBABLY GOING TO HAVETO FILE A MOTION TO MODIFY THE SUPPORT FROM BACK IN2000. SO ENTRY OF THIS THING IS REALLY NOT GOING TODO ANY GOOD. AND WITH THE FACT THAT ALL THOSE PAGESARE MISSING, IT'S JUST TOO FISHY TO BE ENTERED AS AN14:13:0014:13:1714:13:3814:13:5314:14:09CINDA L. TEMMER, CSR NO. 11021


812345678910111213141516171819202122232425262728AGREEMENT TODAY.IN REGARDS TO INCOME ISSUES THAT -RESPONDENT STATED HIS BUSINESS WASN'T MAKING ANYMONEY AND THAT SHE KNEW HE WASN'T MAKING ANY MONEY,EXCEPT BACK WHEN THIS ORDER WAS MADE IN 2000, HE WASIMPUTED INCOME AT 9,000 A MONTH. THAT WAS AN ORDERFROM THIS COURT.AND THEN WE GET A PROFIT AND LOSS DATEDAUGUST 1, '07 TO JULY 30, '08, SAYING THAT HISBUSINESS HAS GROSSED A LITTLE OVER $18,000. YET,HIS BANK STATEMENTS FROM THAT SAME BUSINESS SHOWDEPOSITS OF OVER $57,000; THAT'S A DIFFERENCE OFOVER $40,000 IN WHAT HE'S SAYING HE MADE AND WHAT'SGOING THROUGH HIS BANK ACCOUNTS. SO THEM SAYINGTHAT HE WAS MAKING NO MONEY AT THE TIME AND THESUPPORT WAIVER TO SUPPORT HER JUST DOESN'T HOLDWATER.SO, OUR POSITION IS THAT FOR THOSE REASONSTHEIR MOTION BE DENIED TODAY. ALTERNATIVELY, WEWOULD REQUEST THAT WE DON'T DECIDE THIS ISSUE TODAYAND THAT WE BIFURCATE AND HAVE A TRIAL ON THEVALIDITY OF THIS AGREEMENT THROUGH TESTIMONY OF THEPARTIES, THE NOTARIES, MAYBE EVEN THE PRIORATTORNEYS AT THAT TIME TO FIND OUT WHAT THISAGREEMENT WAS SUPPOSED TO BE, AND IF THIS AGREEMENTIS IN EFFECT, WHAT IT WAS SUPPOSED TO BE. WITH THEISSUE THAT IT'S GOING TO DECIDE TODAY, IT'SPOTENTIALLY HUNDREDS OF THOUSANDS OF DOLLARS IN14:14:3714:14:5314:15:1114:15:2814:15:45CINDA L. TEMMER, CSR NO. 11021


912345678910111213141516171819202122232425262728ARREARS AND THAT SHOULD PROBABLY BE SOMETHING THATSHOULD BE DECIDED THROUGH TRIAL.THANKS.THE COURT: THANK YOU.OKAY. I'VE LOOKED THROUGH THE LODGEDDOCUMENTS AND THE MOVING PAPERS AND IT IS TRUE THATTHERE IS SOME DIFFERENCE IN FONTS ON SOME OF THESEPAGES, YET, INTERESTINGLY ENOUGH IN THE LODGEDDOCUMENTS, THE PAGES ALL SEEM TO BE OF THE SAMEPAPER AND THE SAME PAGE, THE SAME AMOUNT OFYELLOWING. ALL OF THE INITIALS APPEAR TO LOOK THESAME ON EACH SUCCESSIVE PAGE. I'M SATISFIED THIS ISAN AGREEMENT THAT WAS SIGNED BY THE PARTIES WHENINDICATED IN NOVEMBER OF '03.SO THE MOTION TO ENFORCE THIS MARITALSETTLEMENT AGREEMENT IS GRANTED EFFECTIVE THE DATEOF 11-26 OF '03, AND I AM FULLY COGNIZANT YOU ARECORRECT, MR. MASON, THAT YOU WILL HAVE TO FILE AMOTION NOW REGARDING MISSED ASSETS BECAUSE THEREWERE MISSED ASSETS I [SIC] WANT TO PROCEED ON.THANK YOU.MR. MASON: THANK YOU, YOUR HONOR.MS. BALDWIN: YOUR HONOR, I PREPARED SOMEDRAFT JUDGMENTS, SHOULD I GO AHEAD AND SUBMIT THOSETO YOUR CLERK AS WELL AS THE NOTICE OF ENTRY OFJUDGMENT. I BROUGHT THEM WITH ME TODAY.THE COURT: MR. MASON?MS. BALDWIN: IT'S THE SAME AS THE LODGED14:16:0314:16:2014:16:3514:16:5414:17:05CINDA L. TEMMER, CSR NO. 11021


1012345678910111213DOCUMENT, YOUR HONOR.MR. MASON: AND THEN A COPY OF THEJUDGMENT PAPERWORK, YEAH, THAT WAS LODGED.THE COURT: OKAY. AS LONG AS IT'S THESAME AS THAT, THAT'S FINE.THANK YOU.YOU'VE GOT ANOTHER OSC COMING UP, CORRECT?MS. BALDWIN: THAT IS ON MS. CALDWELL'SMOTION FOR ARREARS, YOUR HONOR.THE COURT: DO YOU WANT THAT STILL TO BEHEARD OR NOT?MR. MASON: UH, WELL, PROBABLY NOT.ACTUALLY, NOT IN LIGHT OF TODAY'S RULING.14:17:1314:17:3314THE COURT:ALL RIGHT. I'LL TAKE IT OFF15CALENDAR.14:17:421617THANK YOU.MS. BALDWIN:YOUR HONOR, IS IT NECESSARY1819202122232425262728TO PREPARE A FINDINGS AND ORDER AFTER HEARING FORTHIS IN ADDITION TO THE JUDGMENT; DO YOU WANT THEMBOTH?THE COURT: I WOULD SUGGEST THAT YOU DOBOTH IN AN ABUNDANCE OF CAUTION.MS. BALDWIN: I'LL PREPARE THAT.THANK YOU, YOUR HONOR.THE COURT: ALL RIGHT.14:17:5014:18:00CINDA L. TEMMER, CSR NO. 11021


STATE OF CALIFORNIA) SSCOUNTY OF SAN DIEGOJENNY CALDWELL VS. MICHAEL CALDWELL, CASE NO.ED47912I, CINDA L. TEMMER, CSR NO. 11021, ANOFFICIAL REPORTER OF THE SUPERIOR COURT OF THESTATE OF CALIFORNIA, IN AND FOR THE COUNTY OF SANDIEGO, HEREBY CERTIFY THAT I REPORTED IN MACHINESHORTHAND THE PROCEEDINGS HAD IN THE ABOVE-ENTITLEDCAUSE, AND THAT THE FOREGOING TRANSCRIPT,CONSISTING OF PAGES NUMBERED 1 THROUGH 10,INCLUSIVE, IS A FULL, TRUE, AND CORRECT TRANSCRIPTOF THE SAID PROCEEDINGS HELD ON DECEMBER 16, 2008.DATED AT EL CAJON, CALIFORNIA, FEBRUARY 5,2009.CINDA L. TEMMERCSR NO. 11021GOVT. CODE 69954 (D): ANY COURT, PARTY, OR PERSONWHO HAS PURCHASED A TRANSCRIPT MAY, WITHOUT PAYINGA FURTHER FEE TO THE REPORTER, REPRODUCE A COPY ORPORTION THEREOF AS AN EXHIBIT PURSUANT TO THE COURTORDER OR RULE, OR FOR INTERNAL USE, BUT SHALL NOTOTHERWISE PROVIDE OR SELL A COPY OR COPIES TO ANYOTHER PARTY OR PERSON.CINDA L. TEMMER, CSR NO. 11021


<strong>Page</strong> 1 of 1Law Offices of Laury M. BaldwinFrom: "Ecobaby-Ginny" To: Sent: Monday, November 24, 2003 7:04 AMSubject: ?You <strong>to</strong>ld my mom i invited you <strong>to</strong> come out here with kids? What is up? I do NOT want you <strong>to</strong> come out here. Ithink it is a way <strong>to</strong> make trouble, and definitely not necessary.Also, you made a big deal about me signing the divorce doc. then you still haven't signed it. I need a copy of itsigned by Dec. 8th, or The kids will not be able <strong>to</strong> start school here on time. They need 30 days. That document isproof they are allowed <strong>to</strong> attend school. Please don't screw this up, I really don't want <strong>to</strong> home school.Ginny Turner-PresidentEcobaby Organics, Inc.Pure-Rest Bedding613-327-8236 cellgin nyAecobaby.comEXHIBIT B3/4/2009


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