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12345678910111213141516171819202122232425262728responses to my discovery requests, and I have a financial expert reviewing herinformation. I expect to have a preliminary report within the next two weeks. I alsoexpect that it will be necessary to take Ginny's deposition in order to obtain clarificationabout the documents she provided and about her income and expenses.Based on the information that has been provided so far, however, it is clear thatGinny's income is well beyond the $1,500 per month she claimed she was making as ofApril 13, 2009 when she signed the most recent Income and Expense Declaration("IED") I have for her. According to that document, she earns $1,000 a month in W-2wages and $500 a month in "business draw." Ginny has submitted two IEDs so far thisyear, and one last year in April. In the IED signed on January 19, 2009, she claimedshe was making $3,000 a month. She did not disclose any business draws. In the IEDsigned on April 23, 2008, and filed on May 7, 2008, she claimed her income was $2,500a month. Again, she did not mention any business draws in that IED.According to the April 2009 IED Ginny's monthly expenses were $4,650 a monthwith $3,500 of the expenses being "paid by others." In the January IED, she claimedher monthly expenses were $6,690 with only $200 being paid by others. In April 2008her expenses were $7,058 and all of the expenses were paid by her parents. I have nodoubt that Ginny receives considerable support from her parents, and the amount isprobably at least $3,500 a month. Ginny may claim that her parents only assist herfinancially because she does not receive child support from me, but her parents havebeen helping for years. She has had many opportunities over the years to seek childsupport from me. The one time she filed a child support motion, she abandoned it afterI requested discovery from her about her income.A review of the bank statements and credit statements provided by Ginny, alsoshows that the business, Ecobaby, pays for all of her expenses. Lodged as Exhibit Bare Ginny's personal checking account statements from Chase/WAMU for the period ofDecember 12, 2007 through June 17, 2009. This is the only personal bank accountdisclosed by Ginny during this time period. A review of the statements shows that mostRESPONDENT'S SUPPLEMENTAL DECLARATION AND RESPONSE TO OSC RE SCHOOL ENROLLMENT4
12345678910of the activity on the account are PayPal charges and transfers and some withdrawalsand deposits. There are also several ATM withdrawals and one payroll deposit. Thebalance on the account never got higher than $4,262. Most months the balance waswell below $1,000. There are no charges for businesses like grocery stores orrestaurants, and there are no checks being written on the account.According to my review of the 2006, 2007 and 2008 credit card statementsprovided for Capital One Visa Business Card Account ending 7780, which is held in thename of Ecobaby with attention to Ginny Caldwell, Ginny averaged at least $1,000 amonth in purchases to places like Henry's, Vons, Blockbuster Video, Sport Chalet,Chevron, Limited Too, BT Basketball, Oceans 11 Casino, Petco, etc. (Lodged Exhibit11 C)12131415161718192021222324252627Lodged as Exhibit D are copies of the Union Bank of California bankstatements for Ecobaby, and in Ginny's name, for January 2009 through May 2009.There are significant ATM withdrawals ranging from the lowest at $1,900 in May to ahigh of $3,500 in April. The average for these five months was over $3,000 a month inwithdrawals.According to the detailed check registry provided for the company, Ginny's rentfor her house, paid to Tom Wu, is also paid by the business. This monthly paymentranged between $2,050 and $2,100 a month. The check register will be made availableat the time of the hearing. Ginny's car payment of $678.68 is also paid by the business.Although Ginny may claim that her mother, an employee of Ecobaby who is paidapproximately $6,000 a month by the company, made many of the charges on thebusiness credit card accounts, it does not really matter if Dottie made a lot of thecharges. What is clear is that Ginny's monthly expenses are being paid by someoneother than Ginny because there is no activity on her own personal bank account.When we total the expenses paid by the business, $2,100 a month for rent,$678.68 a month for her car, at least $1,000 for miscellaneous credit card purchases,28 ///RESPONDENT'S SUPPLEMENTAL DECLARATION AND RESPONSE TO OSC RE SCHOOL ENROLLMENT5
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