Edward R. Weinstein, Esq.Edward R. Weinstein, Esq.

What Does A Custody/Parenting Time Expert Report Look Like?

As a New Jersey child custody lawyer, I have engaged many custody experts as witnesses on behalf of my client. When two parents are in a high conflict custody case, a judge of a New Jersey Family Court shall appoint a custody expert to conduct a detailed evaluation. After a comprehensive investigation, the custody expert shall provide to the court and the respective attorneys a written report. This report is extremely detailed and typically has a conclusion with the expert’s recommendations as to custody and parenting time. Below, please find a sample, hypothetical custody/parenting time report:

CONFIDENTIAL BEST INTERESTS
CUSTODY/PARENTING TIME REPORT
Name of Children: John Jones (d.o.b. 06/03/01)
Jane Jones (d.o.b. 06/03/01)
Name of Parents: James Jones, Plaintiff father (d.o.b. 07/10/66)
Mary Williams, Defendant mother (d.o.b. 11/16/59)
Docket Number: FM-10-0000-00
Judge: Hon. Robert S. Smith, JSC
Date of Report: June 26, 2013
Examiner: Wayne Roberts, Ed.D., D.F.C.

ABSTRACT : Based upon my review of all pertinent provided materials, clinical interviews, observations of the parties both individually and with John and Jane interviews/observations with John and Jane, objective psychometric testing, research, collateral contacts, and my clinical experience, it is my professional opinion that:

  1. Both Mr. Jones, the Plaintiff father, and Ms. Williams, the Defendant mother:
    1. Were extremely polite and cordial. They went out of their way to actively participate in this evaluation. Moreover, during their respective presentations, they did not appear to “bash” or speak in overly negative tone about the other party. Rather, the parties appeared to provide information/concerns based upon their perceptions including the best interests of the children. Thus, their style of their presentation appeared somewhat less hostile as compared to other litigants.
    2. Have extremely different personalities, approaches to life, and view parenting much differently. Mr. Jones appears to have a rather “laissez faire” attitude and approach; Ms. Williams is extremely detailed oriented. The differences are so great that it only adds to ongoing frustration and difficulties with co-parenting.

Have demonstrated some history of communication and cooperation. For example,

  1. They appear to have resolved some issues through parenting coordination such as coming to agreement about responding to emails.
  2. They have a history of providing the other parent an email summary prior and post to the children’s visitation which fosters continuity.
  3. They have successfully addressed John’s special education needs. Specifically, it appears that Ms. Williams (the primary caretaker) took the lead and Mr. Jones largely supported the planned educational intervention.

Generally support the involvement of the other parent.

  1. Mr. Jones, the Plaintiff father:

A. Did not present clinical symptoms and/or data indicative of:

  1. Unaddressed psychopathic or an untreated psychological disorder (Ex. Schizophrenia, bipolar disorder, etc.) which might impact his ability to participate in this evaluation, reflect a “fitness” consideration, impact his ability to parent, and/or affect the current custody/parenting time arrangements.
  2. Any underlying personality disorder (Ex. Antisocial personality disorder, borderline personality disorder, etc.) which might impact his ability to parent or the current custody/parenting time arrangements.
  3. Current “addictive” or other compulsive behaviors (Ex. Internet addiction, drug/alcohol abuse, gambling, etc.) which might impact his ability to parent or the current custody/parenting time arrangements.
  4. Work issues which might impact custody/parenting time schedule such as extended overnight travel away from home.
  5. Promoting purposeful estrangement, alignment, or enmeshment.
  6. Being the verified victim or perpetrator of domestic violence or harassment on an objective basis.

B. Presented consistent clinical data indicating that he:

  1. Believes there has been a substantial change in circumstances based upon both parties’ remarriages and moves to new homes which are a considerable distance from each other.
  2. Has a prior history of depression and anxiety which required psychiatric hospitalization. Mr. Jones remains under treatment for the same and appears to be responding well.
  3. Is generally bonded and acts in John and Jane’s best interests as parent of alternate residence by providing food, supervision, clothing, shelter, education, transportation, affection, recreational needs, etc.
  4. Generally supports the ongoing relationship between John, Jane and Ms. Williams.
  5. Is concerned about:
    1. Ms. Williams’ ability to communicate and cooperate.
    2. Ms. Williams’ ongoing allegations that he smokes marijuana.
    3. The number and timing of “transitions” the children must experience under the current parenting plan. For example, Mr. Jones does not support the notion that the children should return to Ms. Williams’ residence to spend Sunday night only to return to his care the following day.
    4. Ms. Williams’ limited acceptance of his new wife, Lisa Jones, in a caregiver role.

C. Produced objective psychometric testing which appears to indicate (Butcher; Green) that Mr. Jones:

1. Responded to the items:

  1. In a highly cooperative fashion which is not typical with litigants who are involved in custody disputes. Moreover, his testing suggests a general cooperation with the entire evaluation.
  2. In a fashion as to create a statistically valid profile. Thus, the profile appears to be an accurate reflection of his current personality functioning. Moreover, his profile was consistent with other data revealed lending higher concurrent validity.
  3. As to suggest a “normal” clinical profile and that Mr. Jones is within the normal range. However, he reported some characteristics such as low self-confidence that are likely to make him vulnerable to symptoms of depression and anxiety under stressful conditions.

2. Is similar to those individuals who:

  1. a. Are shy and inhibited in social situations.
  2. b. Are quiet, submissive, and often lack self-confidence.
  3. c. Experience a degree of negativism and views relationships as threatening.
  4. d. Experience low motivation and harbors many negative work attitudes

3. Is not similar to those individuals who:

  1. Engage in a pervasive pattern of behavior with the intent of abuse, control, or harassment.
  2. Have an elevated level of anger, hostility, or poor impulse control which might predispose them to domestic violence or intimate partner violence.
  3. Have an underlying personality disorder which might predispose them to acting out in an aggressive or violent fashion.
  4. Have an underlying substance abuse or alcohol problem.

D. Stated that in terms of the future custody and parenting plans, he:

  1. Supports the children’s ongoing enrollment and after school care at Oratory Preparatory School.
  2. Would like to reduce “switching” between the parties.
  3. Would like Ms. Williams to support Ms. Jones role and involvement with respect to Ms. Jones’ involvement with the children.

III. Ms. Williams, the Defendant mother;

A. Did not present clinical symptoms and/or data indicative of:

  1. Significant, unaddressed psychopathic or an untreated psychological disorder (Ex. Schizophrenia, bipolar disorder, etc.) which might impact her ability to participate in this evaluation, impact her ability to parent, and/or affect the current custody/parenting time arrangements.
  2. Any underlying personality disorder (Ex. antisocial personality disorder, borderline personality disorder, etc.) which might impact her ability to parent or the current custody/parenting time arrangements.
  3. Work issues which might impact custody/parenting time schedule such as extended overnight travel away from home.
  4. Promoting purposeful estrangement, alignment, or enmeshment.
  5. Being the objectively verified victim or perpetrator of domestic violence or harassment despite her claims in regards to the same.

B. Presented consistent data indicating that she:

  1. Believes there has been a substantial change in circumstances based upon both parties’ remarriages and moves to new homes which are a considerable distance from each other.
  2. Is well bonded and has a documented history of consistently discharging her responsibilities as parent of primary residence. She provides transportation, food, shelter, clothes, emotional comfort, recreational activities, etc. For example, she has an extensive, demonstrated history of making sure that John’s special education needs were addressed.
  3. Generally supports the ongoing relationship between John, Jane and Mr. Jones.
  4. Gives limited support to the relationship between Jane, John and Ms. Jones. Ms. Williams repeatedly indicated that she finds it hard to support Ms. Jones because she has often inserted herself into parenting role. For example, Ms. Williams is upset that Ms. Jones will respond to emails which pertain to the children and are addressed to Mr. Jones. Likewise she is upset that Ms. Jones purchased Jane’s first bra instead of leaving this important rite of passage to her, Jane’s mother.
  5. 5. Is concerned about:
  1. Mr. Jones’ ability to follow through on school assignments.
  2. Mr. Jones’ alleged history of failing to respond to emails concerning school and parenting time issues in a timely fashion.
  3. Mr. Jones’ mental health history including allegations that Mr. Jones continues to suffer from a bipolar disorder and has acted in an “angry” and “abusive” fashion.
  4. Mr. Jones’ alleged ongoing use of marijuana.
  5. Scheduling issues including:
    1. An inadequate vacation/holiday schedule.
    2. Which impact the children’s completion of homework.
    1. f. The ongoing use of parenting coordinator.

C. Produced objective psychometric testing which appears to indicate (Butcher; Green) that Ms. Williams:

  1. Respond to test items:
    1. In a highly cooperative fashion which is not typical with litigants who are involved in custody disputes. Moreover, her testing suggests a general cooperation with the entire evaluation.
    2. In a fashion as to create a statistically valid profile. Thus the profile also appears to be an accurate reflection of her current personality functioning. Moreover, her profile was also consistent with other data revealed lending higher concurrent validity.
    3. As to suggest Ms. Williams is not within the normal range. Specifically, item responses suggest a significant degree of heightened interpersonal sensitivity. Importantly, research indicates that Ms. Williams’ heightened degree of interpersonal sensitivity cannot be solely attributed to the current litigation. Likewise, research indicates that Ms. Williams’ underlying personality may predispose her to oversensitivity and mistrust in regards to co-parenting.

2. Is similar to those individuals who appear to:

  1. Be extremely sensitive and rigid. They can over think, hold grudges, are guarded, and appear to experience a lack of trust.
  2. Have difficulty compromising and find it difficult to “forgive and forget”.

3. Is not similar to those individuals who:

  1. Engage in a pervasive pattern of abuse, control, harassment, or domestic violence.
  2. Experience post-traumatic stress disorder which is often found in victims of abuse.
  3. Have a substance abuse or addiction problem.

D. Stated that in terms of the future custody and parenting plans, she:

  1. Would like to remain the parent of primary residence.
  2. Supports the children’s ongoing enrollment and after school care at Oratory Preparatory School.
  3. Make minor modification to the parenting time plan so that there are less transitions and that she can continue to assist the children with their school work.
  4. Would like Mr. Jones to be more involved with the children’s school work and respond in a more timely fashion to emails.
  5. Does not want Ms. Jones’ direct involvement in parenting time issues.
  6. Would like s more stabilized vacation and holiday plan.
  7. Would not like to continue to use parenting coordinator.

IV. Jane:

  1. Appears to be affectionate and bonded to both of her parents. She looks to them for age appropriate instructions, reassurance, love, etc. Similarly, Jane is:
    1. Emotionally bonded with her step-parents and appears to enjoy engaging in activities with them.
    2. Emotionally bonded to her half-sisters, Wendy and Marie.
  2. Does not appear to have any “special needs” which might impact the custody/parenting time plan.
  3. Has not been overly exposed or impacted by either party regarding the current litigation. However, Jane is rapidly developing greater social awareness. As a result, both parties should be clearly advised that research convincingly and overwhelmingly indicates that the current level of animosity and conflict (both passive and active, regardless of the cause), will directly and adversely affect Jane’s long term psychological development. (Carter, Deutch; Kelly; Kuenhle).
  4. Given the absence of other significant factors, would benefit by continued contact with both parents on a frequent and consistent basis in order to facilitate ongoing psychological needs, facilitate ongoing bonding, and to decrease the potential for estrangement (Carter; Kuenhle, Baker).
  5. Appears to be reaching developmental milestones at anticipated intervals.

V. John:

  1. Appears to also be affectionate with both of his parents. Similar to his sister, he looks to them for age appropriate instructions, reassurance, love etc. Likewise, John is:
    1. Emotionally bonded with his step-parents and appears to enjoy engaging in activities with them.
    2. Emotionally bonded to his half-sisters, Wendy and Marie.
  2. Has a history of special education needs. However, these needs have been largely addressed through extensive after school tutoring, and IEP through Oratory Preparatory School, and the active involvement of Ms. Williams.
  3. Has not been overly exposed or impacted by either party regarding the current litigation. However, similar to his sister, John is rapidly developing greater social awareness. As a result, both parties should be clearly advised that research convincingly and overwhelmingly indicates that the current level of animosity and conflict (both passive and active, regardless of the cause), will directly and adversely affect John’s long term psychological development. (Carter, Deutch; Kelly; Kuenhle).
  4. Indicated that the schedule was too irregular and he would prefer a set schedule for each day of the week. Given the form of John’s answer, it did not appear coached by either party.
  5. Given the absence of other significant factors, would benefit by continued contact with both parents on a frequent and consistent basis in order to facilitate ongoing psychological needs, facilitate ongoing bonding, and to decrease the potential for estrangement (Carter; Kuenhle, Baker).

VI. In terms of future custody/parenting time arrangements:

  1. Both parties presented data suggesting a significant change in circumstances (i.e. remarriage and moving a substantial distance from each other) since the initial custody/parenting time arrangements were developed. Thus, both parties indicated a new parenting plan is required.
  2. No other significant, verified factors such as emotional abuse, neglect, unaddressed special needs, Final Restraining Orders, etc. were identified.
  3. A highly structured parenting plan should be used due to parties’ apparent differences in parenting styles and difficulties regarding communications and cooperation. The plan must utilize the parties’ strengths while addressing their respective need for further development of communications and parenting skills. In terms of general parameters: (Note: See Recommendations section for specifics regarding the custody/parenting time schedule). It is in Jane’s and John’s best interests for the parenting plan to include:
    1. Joint legal and extensive parenting time with both parties because:
      1. As noted above, research consistently indicates that absent of any current or ongoing significant factor children of Jane’s and John’s age benefit by continued contact with both parents in order to establish and maintain bonding and prevent the potential for estrangement.
      2. Extensive time with both parties will foster ongoing bonding with their half-siblings.
    2. Ongoing use of structured parenting plan with minimal contact between the parties because it reduces the potential for ongoing conflict. The structured parenting plan should have slight modifications to the current schedule based upon both parties representation that there are too many exchanges.
    3. A more effective means of communication between Mr. Jones and Ms. Williams needs to be developed.

VII. Therapy and parenting coordination.

  1. Therapy for Jane or John was not indicated at this time. If either child demonstrates a need for therapy after the current litigation has concluded, the parties should seek a psychological evaluation before commencing any form of therapy.
  2. Both parties should engage the services of a licensed psychologist to act as a parenting coach to help them deal with historical factors and enhance their ability to deal with the other party. The therapy should be:
    1. Provided only by licensed psychologist or social worker because a professional counselor or any attorney does not have the formal training or education to provide services based upon the needs of this case.
    2. Not be provided by an advocacy group or professional who is employed by an advocacy group due to the increased potential for the exacerbation of conflict. (Note: In no way does this statement reflect upon advocacy groups. Rather it reflects upon the particular, unique needs of this case in which no advocacy appears required).
    3. Provided after the psychologist or social worker has had an opportunity to review this report or consultation with me based upon a Court order which allows the same.
  3. The ongoing use of a parenting coordinator is questionable. Although it is clear that the parties have been able to resolve minor parenting issues through the use of a parenting coordinator, Ms. Williams is opposed to the continued use. She indicated that she believes the process takes too long and stated that she is more in favor of a parenting coach (See VII.B. above).
  4. The parties should continue with their current therapy on a voluntary basis (including medication, if needed) given their history, stated benefit, and general compliance. However, would likely be of benefit if the parties’ current treating professional contacted me in order to provide additional information given a release from both parties, or an Order by the Court.
  5. The parties should refrain from all alcohol consumption during their parenting time. Likewise, random drug testing of both parties and their current spouses should be implemented in order to alleviate any concerns regarding current drug abuse.

HISTORY OF THE EVALUATION INCLUDING REASON FOR REFERRAL, PRODUCTION, and LIMITATIONS:

Referral to this office for a custody/parenting time evaluation was made by the Court based upon a request from both parties. Specifically, the Order filed on February 25, 2012 and signed by Judge Spencer indicates:

“At the request of the parties, the Court has selected Dr. Wayne Roberts as an independent joint custody expert…(who will) provide the Court with a report as to the best interests of the parties’ children Jane and John both born on June 8, 2001, in terms of parenting time, effective co-parenting, the role of step-parents in the lives of the children, a recommendation as to the possibility of the children attending individualized therapy, and any other issue Dr. Roberts shall bring to the Court’s of the parties’ attention…”

By way of background, the referral for this best interest evaluation was made post judgment. Specifically, the parties previously reached a Matrimonial Settlement Agreement on April 12, 2008 specifying:

“The parties shall exercise joint legal custody of the two (2) minor children of the marriage. Wife shall exercise primary residential custody of the two (2) children. The parties agree to share in custodial responsibilities as they currently do, with the following basic parameters…Primary custody of Jane and John shall be shared on altering weekends, subject to any changes the parties may make, divorced and after the parties reached an initial agreement as to custody/parenting time. Wife shall have primary custody for all Catholic holidays and Husband shall have primary custody for all Jewish holidays, and the parties agree to allow each other to be involved to the extent practical in each other’s holiday with the children. Otherwise, the parties agree to work together to divide all remaining holidays in a fair and equitable manner…”

Subsequent to the MSA, most custody/parenting time issues were resolved by the parties and/or addressed through the repeated use of a parenting coordinator.

For example, the parties agreed upon a parenting time schedule whereby Mr. Jones had parenting time on 1) Monday and Thursday from after school until return to school the next day, and 2) alternate weekends from Friday through return to Ms. Williams’ residence on Sunday evening. Likewise, the parties developed various formal agreements including use of the “48 hour rule”, a schedule for July 4th, a schedule for “religious holidays”, the continued use of Susan Petrick, etc. These agreements were memorialized in numerous letters from Ms. Shirley Mason, the parenting coordinator.

However, despite the apparent resolution of various issues, both parties indicated additional unresolved parenting time issues remained. As a result, they sought this evaluation in an attempt to address the same. Specifically, Mr. Jones indicated that custody arrangements needed to address, in part: 1) Ms. Williams’ relocation to a more distant residence and resulting issues regarding geographic proximity, 2) the additional commuting time the children had to endure as a result of Ms. Williams’ move, 3) number and timing of transitions between parties’ home under the current schedule, and 4) the holiday schedule.

In contrast, Ms. Williams indicated that unresolved custody issues needed to be formally addressed including Mr. Jones’ 1) ongoing mental health status which impacted his ability to focus on the children’s best interests including his possible, ongoing use of marijuana, 2) remarriage and the over-involvement of his new wife, Ms. Lisa Jones, and 3) “inability to follow through” on homework and other issues which impact the children’s best interests. Ms. Williams also indicated that she was concerned about: 1) the parenting time schedule including the number of transitions between the parties and the impact of the schedule upon the children’s schooling, 2) parent coordination was not an efficient use of the time or the parties’ resources, and 3) issues regarding the holiday schedule unresolved.

With respect to the production of this evaluation, the parties were unusually cooperative despite their differences, and the evaluation generally proceeded as anticipated.

In terms of general limitations, the conclusions and recommendations contained in this evaluation are based upon statements by the parties, objective psychometric testing, collateral contacts, observation and interviews with John and Jane, home visits, and provided documentation. As such, it was not always possible to verify the accuracy of each party’s statements or related data.

With respect to the specific limitations, Mr. Jones did not provide his hospitalization records. If and when these records are provided, an addendum to this evaluation can be issued. However, it should also be noted that due to the age of the records, clinical presentation, the consistency of data revealed by both parties over the course of this evaluation and the parties’ objective psychometric testing, it is likely that the clinical records would have virtually no additional probative value.

With respect to other specific limitations including the number of sessions with each party, both parties were informed at the beginning of the evaluation that they could request additional session(s) to ensure my complete understanding of the case, provide additional information, ask questions, etc.

Similarly, at the end of the final interview, both parties were specifically asked if they believed I had a sufficient understanding of their case. Both parties responded in the affirmative.

With respect to other limitations, not all collateral sources identified by the parties were contacted. This is because some of the collateral sources were determined to have a high potential for bias and/or provide little probative value. (Note: This standard was made clear to both parties during their first session with me).

Finally, the conclusions and recommendations were: 1) based solely on the “best Interests” of John and Jane, and 2) developed pursuant to relevant Guidelines, and the N.J.A.C. (See Procedures Used/Material Reviewed section, below).

Thus, the findings and recommendations contained in this Evaluation reflect an acceptable and reasonable degree of psychological probability based upon the entirety of the data presented.

PROCEDURES USED/MATERIALS REVIEWED IN PREPARATION OF THIS REPORT:

Before commencing this evaluation, written informed consent of the parties was obtained as required. Specifically, each party was provided an Informed Consent Form through their respective Counsel. This form detailed in writing: 1) the purpose of the evaluation, 2) the relevant standards to be used, 3) release from patient/psychologist therapeutic privilege, 4) limits of confidentiality, 5) fee structure, report production, and cancellation schedule, 6) requested documentation, 7) production of records, 8) psychological testing and other administrative policies/procedure to be used, 9) confirmation of their ability to speak to their attorney about the Informed Consent Form, 10) past due balance and production of the report, etc.

This evaluator then reviewed the Informed Consent Form with each party at the beginning of their respective initial sessions in order to clarify the procedure and answer any questions the parties might have.

After reviewing the Informed Consent Form, the parties reviewed and signed a “Requested Information Form” which detailed specific records and information which were to be submitted/provided by each party.

Subsequent to the review of the Informed Consent Form and the Requested Information Form, the following “in person” procedures were used in the preparation of this report:

  • 02/12/12 Initial custody/parenting time interview with Ms. Williams.
  • 02/26/12 Follow up custody/parenting time interview with Ms. Williams.
  • 03/14/12 Initial custody/parenting time interview with Mr. Jones.
  • 03/14/12 Objective psychometric testing (MMPI-2) with Mr. Jones.
  • 03/17/12 Objective psychometric testing (MMPI-2) with Ms. Williams.
  • 04/01/12 Follow up custody/parenting time interview with Mr. Jones.
  • 04/17/12 Follow up custody/parenting time interview with Ms. Williams.
  • 05/01/12 Follow up custody/parenting time interview with Mr. Jones.
  • 06/02/12 Follow up custody/parenting time interview with Ms. Williams.
  • 06/09/12 Collateral interview and objective psychometric testing with Ms. Lisa Jones.
  • 06/16/12 Follow up custody/parenting time interview with Ms. Williams.
  • 06/28/12 Collateral follow up interview with Ms. Lisa Jones.
  • 07/02/12 Follow up custody/parenting time interview with Ms. Williams.
  • 07/03/12 Collateral interview and objective psychometric testing with Mr.

Thomas Schaeffer.

  • 07/0712 Follow up collateral interview with Mr. Thomas Schaeffer.
  • 07/07/12 Follow up custody/parenting time interview with Ms. Williams.
  • 07/16/12 Telephone conference with Ms. Shirley Mason, parenting

coordinator.

  • 07/17/12 Home visit with Mr. Jones, John and Jane.
  • 07/17/12 Interview with John Jones.
  • 07/17/12 Interview with Jane Jones.
  • 08/15/12 Collateral interview with Ms. Janet Williams.
  • 08/18/12 Follow up custody/parenting time interview with Ms. Williams.
  • 08/22/12 Home visit with Ms. Williams, John, Jane and initial

custody/parenting time interview with Ms. Williams.

  • 08/22/12 Follow up collateral interview with John Jones.
  • 08/22/12 Follow up collateral interview with Jane Jones.
  • 11/12/12 Follow up custody/parenting time interview with Mr. Jones.
  • 11/13/12 Follow up custody/parenting time interview with Ms. Williams.
  • 12/17/12 Follow up custody/parenting time interview with Ms. Williams.
  • 06/24/13 Collateral telephone call with Ms. Shirley Mason, parenting

coordinator.

The following materials were also reviewed in preparation of this custody/parenting time evaluation.

  • 04/12/08 Matrimonial Settlement Agreement between Mary Williams and

James Jones.

  • 04/12/10 Letter with attachment report from Dr. Michael Graham to Ms. Mary

Williams and James Jones.

  • 01/16/12 Letter from Mr. Daniel Anderson, Esq. to Dr. Wayne Roberts with

Attached Order signed by Judge Spencer file January 27, 2012.

  • 01/19/12 Letter from Mr. Daniel Anderson, Esq. to Dr. Wayne Roberts with

attached:

  • Certification of Defendant, Ms. Mary Williams dated 10/25/12 without exhibits.
  • Notice of Motion with attached Model Order.
  • Certification of Defendant, Ms. Mary Williams dated 01/24/10 with attached Exhibits:
  • Exhibit A: Final Judgment of Divorce dated 01/13/09
  • Exhibit B: Matrimonial Settlement Agreement between Mary Williams and James Jones dated 04/12/08.
  • Exhibit C: Consent Order filed 12/2011.
  • Exhibit D: Consent Order appointing Parent Coordinator dated 01/16/11.
  • Exhibit E: South River Police Incident Report.
  • Exhibit F: Emails between parties.
  • Exhibit G: Emails between parties.
  • Exhibit H: Two letters from Ms. Shirley Mason toMr. James Jones and Mary Williams dated 03/07/11 and 06/03/11.
  • Exhibit I: Emails between parties.
  • Exhibit J: Emails between parties.
  • Exhibit K: Email from Mr. Jones to Ms. Williams.
  • Exhibit L: “Agenda of Key Outstanding Issues for Discussion with Parent Coordinator”.
  • Exhibit M: Consent Order appointing Parent Coordinator dated 01/16/11.
  • Exhibit N: Letter from Mr. Daniel Anderson, Esq. Ms. Shirley Mason dated 7/25/11.
  • Exhibit O: Letter from Ms. Shirley Mason to Mr. James Jones and Ms. Mary Williams dated 01/11/11.
  • Exhibit P: Letter from Ms. Shirley Mason to Ms. Sharon Parker, Esq. and Ms. Amina Patel, Esq. dated 07/25/11.
  • Exhibit Q: Letter from Ms. Shirley Mason to Mr. James Jones and Ms. Mary Williams dated 05/01/11.
  • Exhibit R: Email from Ms. Mary Williams to Ms. Shirley Mason.
  • Exhibit S: Emails between parties.
  • Exhibit T: Email from Ms. Mary Williams to Mr. James Jones.
  • Exhibit U: “Holiday/Special Day/Vacation Day Schedule”.
  • Exhibit V: Certificate of Baptism for John Jones and Certificate of Baptism for Jane Jones both dated 09/13/01.
  • Exhibit W: Program for John and Jane’s Baby Name/Christening.
  • Exhibit X: Email between parties.
  • 01/23/12 Letter from Mr. Daniel Anderson, Esq. to Dr. Wayne Roberts with

attached signed and dated signature page from Ms. Williams Informed Consent Form.

  • 02/12/12 Consultation Center Informed Consent for a custody evaluation

signed by Ms. Mary Williams.

  • 02/12/12 Consultation Center Requested Form signed by Mr. Thomas

Schaeffer.

  • 07/03/12 Minnesota Multiphasic Personality Inventory (MMPI-2) Extended

Score Report for Mr. Thomas Schaeffer.

  • 07/22/12 Letter from Ms. Shirley Mason, parenting coordinator to Dr. Wayne

Roberts with attached letters dated 02/12/12, 02/13/11, 03/07/11, 04/03/11, 04/19/11, 05/01/11, 07/25/11, 02/13/12, 03/19/12, 07/03/12 and 07/20/12.

  • 07/23/12 Letter from Mr. Daniel Anderson to Dr. Wayne Roberts, Ms. Sharon

Parker, Esq. and Ms. Shirley Mason, parenting coordinator.

  • 10/03/12 Letter from Ms. Shirley Mason, parenting coordinator to Dr. Wayne

Roberts.

  • 10/07/12 Letter from Mr. James Jones to Dr. Wayne Roberts.
  • 12/04/12 Letter from Ms. Sharon Parker, Esq. to Mr. Daniel Anderson, Esq.
  • 01/15/13 “Follow up/wrap up meeting with Dr. Roberts” provided by Ms.

Mary Williams.

  • Undated: Autobiography provided by Mr. James Jones.
  • Undated: Autobiography provided by Ms. Mary Williams.
  • Undated: Mary Williams documentation, Volume I of 6 provided by Ms.

Williams including:

  • “Log of issues regarding James co-parenting, poor judgment, efforts to alienate the children from me, etc.” with supporting emails, various dates.
  • Letter from Ms. Sharon Parker, Esq. to Mr. Daniel Anderson, Esq. dated 06/20/12.
  • Letter from Mr. Daniel Anderson, Esq. to Ms. Sharon Parker, Esq. dated 06/27/12.
  • Undated: Mary Williams documentation, Volume 2 of 6 provided by Ms.

Williams including:

  • List of Physicians, Counselors, Therapists and Social Workers for M. Williams and/or John and Jane Jones over the last 7 years with attached records, various dates.
  • Undated: Mary Williams documentation, Volume 3 of 6 provided by Ms.

Williams including:

  • Email communications with John’s OPS English/grammar teacher, Ms. Julie Donnelly, various dates.
  • Email communications with John’s OPS history/science teacher Ms. Lacey, various dates.
  • Email communications with John’s OPS learning coordinator, Mr. Andrews, various dates.
  • Email communications with OPS school nurse re annual physicals and John’s asthma management plan, various dates.
  • Email communications with OPS 2nd and 3rd grade teachers, various dates.
  • John’s 4th grade OPS report card and progress reports from various teachers.
  • Jane’s 4th grade OPS report card and progress reports from various teachers.
  • Email communications with John’s 5th grade OPS learning coordinator Ms. Greene.
  • Undated: Mary Williams’ documentation, Volume 4 of 6 provided by Ms.

Williams including:

  • Report regarding John from Dr. Michael Graham to both Ms. Williams and Mr. Jones dated 04/12/10.
  • Dr. Graham’s Summary of findings Power Point Presentation, undated.
  • “1-2-3 Magic, Training Preschoolers and Preteens To Do What You Want” by Dr. Thomas Phelan.
  • Undated: Mary Williams’ documentation, Volume 5 of 6 provided by Ms.

Williams including:

  • Emails communications regarding John’s educational therapy, various dates:
  • verview of the Susan Petrick Educational Therapy Program, unsigned and undated.
  • “Math Assistance Packet 1 Prepared to help John…” unsigned and undated.
  • Copy of calendar from March 2012 indicating Johns practice time for trumpet.
  • “Countdown Calendar” for Petrick program 2010 through 2012.
  • Email from Ms. Mary Williams to Mr. James Jones dated 04/06/12, “Book Notes” and Summer Reading Assignment from OPS (i.e. Oratory Preparatory School).
  • Undated: Mary Williams documentation, Volume 6 of 6 provided by Ms.

Williams including:

  • Various emails
  • Proposed calendar from February 2012 through November 2023.
  • Various: Emails to/from/between parties, parenting coordinator Dr. Mason,

counsel, etc.

  • Various: Medical/dental/vision records for John Jones.
  • Various: Medical/dental/vision records for Jane Jones.

The following records were requested both in verbally and in writing. However, they were never received. (Note: If and when these records are received, an addendum can be issued upon a request from the Court).

  • Hospitalizations records for Mr. Jones.