Name Robert G. Kearns, Jr.
Address RR#3 Box 254A1
City Hollidaysburg
State Pa.
Zipcode 16648
Phone 814-696-3022

While going through papers, notes and letters left in the marriage residence, I had discovered a poem written by my step daughter that graphically described a daughter being molested by her mother. Carelessly and ignorantly, my sister revealed this poem to her gynecologist. Immediately, the gynecologist informed my sister that she is bound by law to contact child protective authorities. My sister was given the ultimatum to have my daughter Stephanie in her office for an examination by 4:00 p.m. that day or CYS would be notified to pull my daughter from the mother's care. Since I had not seen my daughter for nearly two weeks and had no contact with her, I was left with a serious dilemma. After contacting my attorney, Donald Speice, and telling him of my position, he advised I was still within my legal rights to take Stephanie to this doctor's appointment. When my sister and I went to the Calvary Baptist school that afternoon to pick Stephanie up, we were stunned at what we found. Stephanie was traumatized and appeared to be in a lethargic state of shock from what her mother had done to her. When my daughter began to respond to my presence the first words out of her mouth was does my mom know you are here and did you ask her if you can take me.

It wasn't until December 11, 1996, that I was given my first court ordered visitation with Stephanie. The standard order. While these short visitation periods with me served to slow down Stephanie's emotional deterioration, she began expressing her fears to return home to her mother after her weekend visits with me and the paternal family. She would display her anxiety to return to her mother's residence by hiding in corners of the house, or she would sit on the staircase and punch her fist into the carpeting, and when we were outdoors she would repeatedly kick at the ground pleading with me and my family not to take her back to her mother.

In February 1997, I picked Stephanie up on a Friday night to begin one of my weekend visits, I and my family noticed that Stephanie was missing most of her eyelashes, was showing signs of pulling the hair out of her head, and was missing the hair on her arms. Stephanie then began to tell everyone she met that she wanted to live with me (her dad). Because Stephanie's situation did not change, she began to fall into a deep depression and her emotional health deteriorated further.

Rather than the court making a radical custody visitation adjustment to correct Stephanie's failing emotional health, Ilissa Zimmerman, Esq., Stephanie's appointed guardian ad item, petitioned the court to have Dr. Nancy D. Baker council Stephanie to help her adjust to a situation she had grown to hate. While my attorney expressed his objections to Baker counseling my daughter, Zimmerman stayed the course. Of course, Judge Jolene Kopriva granted Zimmerman's petition.

Around March 1997, Stephanie's emotions outwardly surfaced and she disclosed to me an incident that took place the night her mother removed her from our home. Stephanie told me that she never wanted to leave that night with her mother. I asked Stephanie if so, why she didn't cry out for help? Stephanie said she couldn't because Jandora (her half-sister) was holding a knife to kill you, if you caught them leaving. Steph said Jandora held her other hand over my mouth so I couldn't yell out to you. Stephanie said she tried to resist her mother taking her away, but her mother grabbed her arms and gouged her fingernails into her skin until her arms bled. She was then dragged to the van. The following day I notified Attorney Speice of Stephanie's disclosure.

In March and April 1997, Dr. Baker had her first intake interview with me and my wife separately before beginning to counsel Stephanie. On my daughter's first counseling appointment with Dr. Baker, I was advised that she referred Stephanie to psychiatrist Richard Hill who maintained an office in Baker's building. Without ever talking to my daughter, Baker told me Stephanie needed medicated basing her decision on my wife's perception that Stephanie suffered a lifelong mental illness.

Sometime in May 1997, I had taken Stephanie to Dr. Baker for a counseling session. After Stephanie was done, Ms. Baker called me into her office and made a verbal attack on me. She sat me down at her desk and showed me a drawing Stephanie just drew for her. It depicted the knife scene event that Stephanie told me about months earlier. It had shown Stephanie being held behind the back door of the house with her half-sister holding a long bladed knife. However, that drawing didn't alarm Ms. Baker one iota. Instead, she told me that Stephanie has developed an alignment with me that she has never heard or seen before. Baker said Stephanie told her she wanted to live with her daddy. Ms. Baker jumped down my throat asking me what I did to make Stephanie swing her allegiance towards me. I told Baker I never said anything to Stephanie, but Stephanie just told me that her mother said she will be living with her and she will never get to see me again. I told Baker that Dr. Hill told Steph's mother at our last meeting that I would never get custody of my daughter because girls belong with their mothers. Baker kept insisting that it was me that told Stephanie something to make her want to live with me. Needless to say, Baker pushed my buttons too far and we got into a heated verbal exchange.

By my first custody hearing on June 23, 1997, my daughter's mental health had deteriorated so dramatically under Baker's counseling, that she had pulled out all her eyelashes, eyebrows, and most of the hair on her head. My daughter's only problem before Baker's involvement was depression caused by the alienation from the paternal family. Vehemently, my daughter's desires were to return home to live with her daddy. Driving my daughter into a deeper depression, Ms. Baker deliberately refused to acknowledge my child's problem and was looking hard to place some superfluous blame on me for Stephanie's deterioration.

During my first evidentiary custody hearing on June 23, 1997, Ms. Baker testified for nearly 51\2 hours and blatantly attempted to conceal the knife drawing my daughter drew for her at the counseling session in May, 1997. Accommodating my wife to retain custody of my daughter, Baker attempted to construct a tranquil and loving home life setting for her. After one short interview with my step daughter, Baker was able to endorse her as a nice church going girl of high morals. Attorney Speice then showed Dr.Baker a photograph of my then 17 year old step daughter, exposing her breasts in the home she baby-sat in. He had shown her drawings and poetry of oral sex acts and a molestation poem that my step daughter authored and drew. He asked Baker if she considered that moral conduct and did anything alarm her that she looked at. Baker said nothing there alarmed her and it was moral behavior for 16, 17, and 18 year old girls. To chemically force my daughter's compliance and submission to accept and live with this repulsive situation, Ms. Baker highly recommended to the court that my daughter be medicated by Psychiatrist Richard Hill. Subsequently, she recommended that any visitation between my daughter and I cease. Baker suggested the suspension should be in effect for years until the drugs had time to work her desired results on Stephanie. Only after years of being medicated and only if my daughter still wanted to see me, she claimed that some visitation with me could be re-instated.

Wearing down with the extensive cross-examination by Attorney Speice, Baker's testimony finally revealed that my daughter loved her daddy more than her mother and wanted to come home to live with me. At the end of the hearing, I was ordered two things until the next scheduled bearing on July 17th. (1) I was given additional days of visitation with my daughter and (2) a period of two weeks to get a second medical opinion before any court ordered medication would be considered for Stephanie.

On July 2nd, I was to pick my daughter up at my wife's residence only to discover a vague note tacked to the door telling me that Stephanie was involved in some emergency.

I should contact my lawyer in the morning. Not until 3:00 P.M. July 3rd, did my attorney discover that Stephanie was placed in a mental institution, collusively by Ms. Baker, CYS and my wife. On July 3rd, Judge Jolene Kopriva acted on the fabrications and whims of Ms. Baker, and issued an order to institutionalize my daughter and medicate her if deemed necessary. My court ordered second medical opinion was now to be done at the Meadows Psychiatric Center. Ironically, that was where Dr. Richard Hill had practiced and was a director. Furthermore, the custody hearing disclosed that the Meadows paid the rent to Nancy Baker for Mr. Hill's office space in her building. A second medical opinion by a Meadows psychiatrist to medicate my daughter or not was in fact no second opinion at all. Baker knew an independent second medical opinion and psychological reevaluation of my daughter would have exposed her for being a fraud, and pathological liar.

This time Kopriva aided Baker's irrational moves to institutionalize my daughter and circumvent my opportunity to have a neutral medical opinion done. Kopriva's July 3, 1997 order stated that every effort was made to contact my attorney as well as my daughter's guardian ad litem before incarcerating Stephanie. Supposedly they were unavailable to participate in the crisis. Not being taken in by Kopriva's lie, Attorney Speice wrote a letter to Kopriva asking her to explain exactly what attempts were made to contact him. Kopriva refused to answer his request.

On July 15th, 1997, Stephanie was released from the Meadows heavily medicated with Prozac and Risperidal. Ms. Baker also filed an oral complaint with the Blair County Children and Youth services accusing me of severely emotionally abusing my daughter. Accordingly, Baker requested that all my visitation with Stephanie be stopped. Not completely accomplishing her goals my every other weekend visitation with Stephanie was restricted and heavily monitored during the 84 day investigation by CYS. I was now required to take Stephanie to Ms. Zimmerman's office on the Sunday evenings of my every other weekend custody exchange. Also, Stephanie was not allowed to see any adult paternal family member that I didn't reside with.

When Dr. Baker caught wind of Mr. Consigilo's decision, she went on a rampage to overturn his custody recommendation. She sent an ex parte letter to Ms. Frederick's attorney, Darlee Sill, asking him to take some action to stop my visitation with Stephanie. Baker's actions resulted in one petition being filed by Zimmerman and another from Sill. Both requested a judge to overrule Mr. Consiglio's recommendation. Judge Peoples denied the request. This still didn't stop Baker so she tried to sway Mr. Consiglio to reverse his recommendation to no avail.

In any case, the already restricted visitation arrangement had just about pushed Stephanie to a mental breakdown. In complete counter distinction to Baker's allegations of me, the CYS investigation netted numerous reports by independent social workers, and psychologists that I did not cause my daughter the mental abuse Baker accused me of. These reports repetitiously conveyed Stephanie's wishes to live with me.

At a September 22, 1997, custody hearing, CYS caseworker, Catherine Hoover, testified that the 84 day CYS investigation resulted in no charges of emotional abuse as Dr. Baker reported. After changing the allegations to medical neglect in the middle of the investigation, without notification, CYS concluded that there was no indications of medical neglect as Dr. Baker reported. This charge was discounted by psychologist Lynn Kagarise. However, Ms. Hoover said there was an indication of indulgence. Attorney Speice asked exactly what is indulgence? Ms. Hoover answered inappropriate parenting. She explained that Stephanie had told CYS that her father had bought her so many toys it filled the second floor of his garage. Attorney Speice asked if CYS had ever been to my house to question me or my family members. Ms. Hoover answered no, because we didn't think you would allow CYS to talk with Mr. Kearns' family.

Two days after the September 22nd hearing, Attorney Speice had contacted me to tell me that CYS had sent him a letter stating that I was notified at some point during the 84 day investigation that the emotional abuse allegations were changed to medical neglect. Being news to me, I suddenly found myself being indicated by CYS for not providing my daughter Dr. Hill's recommended psychotic medications.

On October 10,1997, Ilissa Zimmerman, Esq. was called to the witness stand by Attorney Darlee Sill. Ms. Zimmerman gave testimony to her involvement with Stephanie as her guardian ad litem. Ms. Zimmerman gave her view of the emotional and degenerative condition Stephanie was in since her first contact with her in December 1996. Ms. Zimmerman testified that it has always been Stephanie's desire to live with her father.

Attorney Speice cross examined Zimmerman as to what is causing Stephanie's seemingly irreversible emotional deterioration. Zimmerman concluded that Stephanie needed to have more contact with her father over and above the every other weekend visits.

Concluding this hearing, Master Consigilo asked Zimmerman how much additional visitation should I be given with Stephanie, for example, a couple days per week, perhaps? Zimmerman answered one hour extra per week is enough. Ms. Frederick argued that I shouldn't of had any additional visitation with Stephanie.

On October20, 1997 Stephanie concluded the evidentiary hearings with her interview before the attorneys and master.

On January 30, 1998, I received a final order from the custody master and approved by Judge Jolene Kopriva. The order granted me my every other weekend visits plus one overnight stay per week. Being totally devastated by the order, I decided it was a losing battle and gave upon my fight for custody of Stephanie. I was dejected and decided not to appeal. When Attorney Speice reviewed the order with me, he pointed out an endless string of errors in Mr. Consiglio's ruling. That is when I requested Attorney Speice to continue the custody litigation.

Judge Hiram Carpenter became involved with my custody case on or about May22, 1998, when my attorney, Donald Speice, filed exceptions to the master's custody order. Attorney Speice requested that a de novo hearing before a common pleas court judge be granted to decide custody of my daughter Stephanie. (Frederick vs. Kearns--Docket # 96 GN 2139).

On August 28, 1998, we had our first of a series of custody hearings with psychiatrist Dr. Richard Hill being the first and only witness to testify that day. Basically, his testimony indicated that Stephanie had no mental illness but was suffering from the stress of the divorce situation. His opinion of Stephanie's emotional problems differed dramatically to Dr. Baker's opinions. On or about September 15, 1998, Attorney Speice had acquired a copy of that hearing transcript which I had the opportunity to review. I found it to be about 99% accurate according to my recollection of the hearing.

On or about December 12, 1998, I filed a pro se petition requesting that Ilissa Zimmerman, Esq. be dismissed as guardian ad litem. I also asked that Zimmerman be placed under investigation for contributory abuse to her client. My family and I had witnessed on numerous occasions Zimmerman's professional actions and cruel comments to Stephanie caused her severe emotional upheavals. During Zimmerman's three year tenure as Stephanie's guardian ad litem, she was starting to look more and more like Ms. Frederick's second attorney. Ms. Zimmerman's conduct went beyond the duties of guardian ad litern and was obvious to all concerned that she had aligned herself with Ms. Frederick and was susceptible to her persuasions. The petition was promptly dismissed the following day by Carpenter citing counsel of record.

On February 1999, the custody bearings again resumed. On February 1, 1999, Dr. Nancy Baker, psychologist Lynn Kagarise, and psychiatrist Eugene Polmueller had taken the stand on behalf of the plaintiff mother. On February 2, 1999, Lynn Kagarise, Eugena Barefoot, CYS caseworker Catherine Hoover, and Kay Engelbret of CYS took the stand on behalf of the plaintiff mother.

During the above hearings, Attorney Speice's cross examination of the witnesses brought forth and developed a pattern of conspiracy between Ms. Frederick, Children and Youth Services, Dr. Nancy Baker, Dr. Eugene Polmueller, and Judge Jolene Kopriva to have committed and/or ignored various incidences of judicial, medical, emotional, and physical abuses against my daughter Stephanie and me.

The hearings further revealed that CYS and Dr. Baker had made a conscious and blatantly obsessive effort to destroy my relationship with Stephanie. What appeared as insidious, CYS and Dr. Baker ignored my wife's hateful and abusive conduct towards Stephanie which included but was not limited to the knife point abduction. CYS was so incessant to place the blame of my daughter's emotional deterioration on me they changed allegations of abuse against me in the middle of an ongoing investigation without notification and falsified their reports. To cover it up, they lied on the witness stand. Kay Engelbret testified that in December 1998, CYS, Dr. Baker, and Ms.Frederick secretly had Stephanie medically examined by Dr. Marianne Hanlon to see if I had sexually molested her. Like Zimmerman and Baker, CYS was so mesmerized and aligned with my wife they were abetting the mother's abuse of my daughter. CYS testified that in July 1997, they had instructed Ms. Frederick two times to violate the custody order that denied me the extended visitation with Stephanie that was court ordered. CYS demonstrated through their criminal actions a frightening abuse of power.

On February 3, 1999, the custody hearing was put on hold as the attorneys appeared to be negotiating some legal matters. Meanwhile, two witnesses (school teachers), subpoenaed by Ilissa Zimmerman, were poised to testify.

By late afternoon, Attorney Speice came to me and offered a shared physical and legal custody agreement. Hoping to stop and turn back my daughter's emotional deterioration, I accepted Attorney Speice's proposal with reservations that my wife (Ms. Frederick)would not stop her well established pattern of making false and frivolous complaints to CYS, Dr. Baker, and Ilissa Zimmerman, Esq. My attorney assured me that Ms. Frederick had requested counseling as a stipulation in accepting the agreement. This would stop the complaints he said. In counter distinction, my wife had taken a couple hours to accept the custody agreement that Attorney Sill believed would be in Stephanie's best interest. In my wife's own admittance she was convinced that she was unduly forced into the agreement. She then became bitter with her attorney. So, much, she refused to return to the courthouse on the evening of February 3rd, to consummate the agreement.

Consequently, on February 4th, my wife was still embittered at the custody resolution and arrived late at the courthouse. The parties were gathered together in Judge Carpenter's courtroom to be read the custody order and work out the visitation schedule.

As I had feared, it was only a matter of weeks following the custody agreement that my wife reinstituted her volley of attacks on me through CYS and Ilissa Zimmerman. In spite of the mother's resistance to the shared custody, Stephanie's emotional health made a dramatic recovery for several months following the custody agreement. So much so, school personnel recognized and testified on April 5, 2000, that Stephanie was happy for the first time since entering the public school almost three years earlier. By July 1999, Ms. Frederick made no effort to cooperate in making the agreement work and escalated her attacks on me and Stephanie to the degree that it became intolerable to bear any longer. As far as the counseling went with Jack Murray, my wife ended that when she ran out the door after the fourth session.

An indicator that Ms. Frederick was again reuniting her allies to destroy the custody agreement had manifested itself through an incident that had occurred in Dr. Marianne Hanlon's office involving Ms. Frederick and Stephanie. It was my custody day and I had taken Steph to a scheduled doctors appointment. Shortly after Ms. Frederick entered the office and had escorted Stephanie into the doctor's examining room as I waited in the lobby. About ten minutes had passed when an upset Stephanie came bursting into the lobby telling me that her mother told Dr. Hanlon she recently tried killing herself with a knife. Following that incident Ilissa Zimmerman wrote Dr. Hanlon a letter asking what my (Mr. Kearns) involvement was that caused the incident. Dr. Hanlon responded to Ms. Zimmerman with a list of Ms. Frederick's complaints against me that were unrelated to the office episode.

Realizing I had made a terrible mistake accepting the custody agreement, I believed my only relief and recourse was to revive the custody litigation arid file civil suits against CYS and several of the doctors involved with Stephanie's mental health treatment. What had become a definable pattern over the last three years, Ms. Frederick was instigating, promoting, and exaggerating Stephanie's behavioral outbursts toward her and other maternal family members. She would then report these alleged incidents to Dr. Baker, the psychiatrists, and CYS as being a recurrence or worsening of Stephanie's fabricated mental illness.

On or about March 19, 1999, Attorney Speice requested that the court reporters, Christa Miloro and Sally Zeek, produce the transcripts of the February 1st, 2nd, 3rd, and 4th, hearings. The court reporters notified Attorney Speice that they could not produce those transcripts immediately because they were too busy and one reporter suffered an injured wrist.

In July 1999, Attorney Speice received the transcripts of the February custody hearings. Upon my review of those transcripts, I discovered the February 2, 1999 transcript had numerous material errors in the transcribed testimony. Since these errors had mysteriously incorporated new dialogue into witnesses' testimony (particularly CYS) it was obvious the alterations were the act of deliberate tampering. From my recollection of the hearings I estimated these transcripts to be about 85% accurate. Accordingly, I brought these discrepancies to Attorney Speice's attention. He reacted by not denying or confirming any discrepancies.

I told Attorney Speice that since the alterations were designed to cover for the CYS employees' outrageous conduct: it appeared Judge Carpenter was the saboteur. My personal feelings were the court reporters had nothing to gain by tampering with transcripts. Believing I could only get a raw deal by Mr. Carpenter should he make any rulings of custody, I asked Attorney Speice to reopen the custody hearings and have Mr. Carpenter recuse himself. Attorney Speice asked me what judge would we use as a replacement. I told him an out of county judge. At that point, he went on a sales campaign and told me there are two out of county judges that come to Blair County. One is old and falls asleep during testimony and the other is arrogant and indifferent. The latter demands the litigants to work out their own agreements. Given these options, Attorney Speice suggested that Judge Carpenter was my best chance to gain full custody of my daughter. He just couldn't envision him tampering with testimony.

Because of Attorney Speice's advice combined with hints from third party sources that atleast one Blair County judge was already under investigation for their unethical links to Dr. Nancy Baker, I warily proceeded on with my custody case with Carpenter.

On October 18, 1999, I again became the subject of a CYS investigation for allegedly punching my daughter in the ribs. As usual, Ms. Frederick spearheaded the charge. Again Stephanie was placed under severe emotional strain as CYS caseworkers prodded at her to implicate me (her father) of this phony allegation. This time CYS caseworker, Shannan Kelly, was overheard on October 19th, telling Stephanie that if she felt threatened by her father in any manner she should telephone CYS immediately. The 30 day investigation netted no abuse charges by CYS.

On or about October 26, 1999, Attorney Speice filed a petition to modify my custody order. Again my hopes was to gain full custody of my daughter to eradicate Ms. Frederick's emotional and physical abuse of her. I further believed the constant intrusions by CYS and the regiment of psychologist's and psychiatrist's into my daughter's life was contributory to the absolute destruction of her mental health, childhood, and ultimately her life. In response, a conference was ordered for January 6, 1999. A pre-hearing conference was scheduled for May 9, 2000.

During the time following my petition for custody modification, Stephanie's emotional health began to degenerate at a pace I haven't seen in years. It became apparent to me that my modification petition served to infuriate my wife's wrath even more. CYS was taking advantage of every opportunity. They were now trying to lay the blame on me for causing my daughter's mental regression because I resurrected the custody litigation, During a conversation with Shannan Kelly in October, she confirmed Stephanie was told by her mother that I never wanted her as a baby and wanted to adopt her out. Ms. Kelly discounted this emotional abuse of Stephanie by telling me and my brother that she couldn't believe Ms. Frederick was capable of making a comment like that. Kelly believed Stephanie's mother loved her too much. The truth of the matter was CYS employees' were ignoring anything Ms. Frederick did to Stephanie and in reality was feeding my wife's abusive nature. Adding to Stephanie's problems, CYS was encouraging Ms. Frederick to institutionalize Stephanie to control her emotional outbursts that historically and predominantly were taking place at the mother's residence during her periods of custody.

The catalyst to Stephanie's mental regression was had taken form in CYS caseworkers. CYS caseworker, Shannan Kelly, began a bombardment of intrusions into Stephanie's life. At one point Stephanie had a scratch on her hand made by her cat's claw. Ms. Frederick told Shannan Kelly it was a knife cut. Ms. Kelly went to the Baker school and pursued Stephanie to admit the scratch was a knife wound self inflicted at my home. CYS wouldn't let her alone at school and they began to make frequent visits to my home.

Stephanie said Ms. Kelly constantly questioned her about Grandma Kearns' health who was suffering with cancer and how is your dad treating you. Steph became so upset with these questions that she wouldn't answer them anymore. Pretending to be concerned for Steph, Ms. Kelly even introduced her into a 4H horse program to enhance her social life. While this program did nothing to help her emotions, it turned her every waking and sleeping thoughts towards owning horses and building barns. Since I and my family had the acreage, I became the targeted parent to disappoint Stephanie and fend off her CYS inspired whims.

Around November or December 1999, it was brought to my attention that Ilissa Zimmerman, Esq. held an ex parte meeting with my wife and daughter. It was revealed to me that in the presence of the mother she asked my daughter to which parent she preferred to live with full time. When attorney Speice asked Zimmerman why I was not included in that meeting, she lied and said she telephoned my residence but I failed to respond to her telephone call. Infuriating me again, I filed a revised pro se petition to have Zimmerman removed as guardian ad litem and place her under investigation for abusing her client. At a January 6, 2000 conference, Carpenter agreed to voluntarily dismiss Zimmerman from her duties and claimed he would enter an order as such. He also dismissed my petition without prejudice.

By the end of December 1999, Stephanie's emotional condition had sank to its lowest point since being abducted from our residence in 1996. The school was concerned for her behavioral decline and Stephanie began pulling out her hair again. For fear that Dr. Baker was going to pull off another emergency trip to the Meadows for Stephanie, I filed a pro se petition for injunctive relief against CYS and Baker. My intention was to have a psychiatric reevaluation of Stephanie done by an independent psychologist without the input or influence of CYS or Baker breathing down their neck. The petition also made reference and passed blame to the Blair County court for negligently allowing Stephanie to emotionally deteriorate under its directives. Again Carpenter dismissed my petition citing council of record.

In March 2000, allegations emerged that Stephanie had threatened to kill people in her school and burn down the building. Rising to the occasion was CYS. However, Ms. Kelly said CYS did not know what to do to help Stephanie. Accordingly, Dr. Nancy Baker's counseling services were going to be utilized and CYS was now making emergency appointments for Stephanie with Baker. They believed Baker would get to the bottom of Stephanie's regressive emotions and aggressive behavior and institutionalize her if appropriate.

Because I couldn't bare to see Stephanie suffer any longer, I filed a special relief petition pro se based on allegations that Ms. Frederick was deliberately abusing Stephanie emotionally to force CYS or Dr. Baker to take emergency medical actions against her. I laid on the court that Stephanie was about to have a nervous breakdown. From my experience Ms. Frederick had taken a similar course of action back in July 1997 that resulted in Stephanie being institutionalized by Dr. Baker and CYS at the Meadows Psychiatric Center. As I had mentioned earlier, this action resulted in Stephanie being heavily medicated and being restricted to certain paternal family members on my every other weekend visits. CYS, Dr. Baker, and Ms. Frederick were still not satisfied with that arrangement and pushed the court hard to remove Stephanie from my life.

Ms. Frederick responded to my petition with a pro se answer that I was not qualified to determine Stephanie was on the verge of a nervous breakdown and passed blame on me for Stephanie's degenerating mental health. Carpenter dismissed my petition citing attorney of record.

It was around mid March 2000 that Attorney Speice and I were not seeing eye to eye in his handling of my case. He started to distance himself from me. Stephanie's condition and situation seemed to be of no concern to him. What I hadn't realized at the time, he was deliberately upsetting me so I would dismiss him. Taking the bait, I asked that he no longer represent me in further custody proceedings and I requested that he turn over the entire case file to me.

I began to mentally review and piece together Ms. Frederick's pattern of behavior and control she had over the professionals involved with Stephanie's treatment. It was then I realized Ms. Frederick's' behavior went beyond the revengeful scorn of a disgruntled woman going through a bitter divorce. My wife was displaying characteristics of mother's suffering with Munchausen by Proxy Syndrome. She was deliberately causing Stephanie to act out emotionally and then run to the professionals with her conclusions and observations that Stephanie was mentally ill from birth. Most of these episodes were either induced or feigned. The gratification Ms. Frederick received from all this was the attention, camaraderie, and support she was receiving from the court, the doctors, and other professionals she forced into Stephanie's life.

This theory added new light to why Stephanie's mental health had been deteriorating at such a rapid pace. Fearing for the direction Ms. Frederick was taking Steph, I filed a pro se petition for emergency relief. The crux of my petition alleged that Ms. Frederick was a Munchausen by Proxy mother who was inflicting severe emotional abuse on her daughter.

This time Carpenter reacted by rescheduling the May 9, 2000 pre-hearing conference up to March 31, 2000. He also required that pre-hearing statements be filed 10 days prior to the hearing.

At the March 31 pre-hearing conference, we were advised by hearing officer Michael Reighard that Carpenter wanted this custody issue ended and therefore scheduled hearings beginning April 5, 2000. We were both urged to get busy since we had numerous professional witnesses to be subpoenaed within 5 days.

Reacting to the alleged school threats by Steph, CYS entered my parents home on March 31, 2000, where Steph and I lived and asked to see the whereabouts of our guns and ammunition as Stephanie watched. When we had showed them our guns were stored in a closet and our ammunition was in my dresser drawer, they demanded that the shells be locked away from Stephanie's access.

On April 3, 2000, CYS returned to double check that the shells were locked away. Ms. Kelly was inquisitive as to what I planned to ask her on the witness stand during the upcoming hearings.

Because Carpenter gave such short notice to prepare a case of this magnitude, I asked Attorney Speice if he would be willing to get involved with the case again. He either had first hand information or was a mind reader when he quipped that he thinks Judge Carpenter wanted me and Ms. Frederick without counsel.

On April 5, 2000, we had our first hearing of what became a series of six. Before the hearing began, a lawyer by the name of Beverly Mears approached us. Ms. Mears conveyed that she had just been appointed this morning as Stephanie's guardian ad litem by Carpenter to see that Stephanie's interests were adequately represented. There were four common witnesses that day. In chronological order they were Dr. Hanlon, Bonita Reimer, Stephanie's inclusion teacher at the Baker school, Shannan Kelly of CYS, and psychologist Scott Lambert.

As I had expected, every witness who had extensive contact with Ms. Frederick, prior to the hearings, except Mr. Lambert, would begin their testimony struggling to give an appearance of impartiality. Within a few minutes, each witness except Mr. Lambert would start to lean their testimony in favor of the plaintiff mother. Three of these witnesses confirmed that their professional interactions with Stephanie were solely based on Ms. Frederick's input and perceptions of Stephanie. Scott Lambert said he considered input from Ms. Frederick and myself.

In summary, Dr. Hanlon's testimony was primarily restricted to her medical treatment and physical condition of Stephanie. She had also displayed an unusual closeness to Ms. Frederick and believed her to be an ideal mother who deeply loved her daughter. Dr. Hanlon described Stephanie's visit to her office as normally uncooperative and tumult when accompanied by her mother. In contrast, she saw Stephanie as cooperative and behaved when accompanied by her dad alone. I asked Dr. Hanlon if she ever heard of Munchausen by Proxy? She answered yes, it is a condition that mother's have who make their children physically sick and then they have them medically treated. I asked Dr. Hanlon if that would also include making their children appear to be mentally ill. She hesitated and then answered yes, they can do that. I asked Dr. Hanlon if these Munchausen by Proxy mothers have the unique ability to fool doctors? She answered yes, they do.

When Ms. Mears asked her first question on cross examination, I found her purported neutrality to be absolute bunk. It was a direct attack at me.

In summary, Ms. Reimer's testimony centered on Stephanie's behavior pattern in school. She testified to observing Stephanie biting herself, pulling out the hair on her head, becoming aggressive towards teachers, picking at herself until sores developed, poking at herself with a pencil, repeatedly tying and untying her shoe laces, outbursts, openly bringing family problems up during class discussions, falls asleep in class, couldn't stay focused on school work, and made demands that her one on one tutor do her class assignments and turn the pages of her book. Ms. Reimer further testified that before each school day began Ms Frederick would approach the school teachers and give an account of Stephanie's mood for the day and what they should expect to deal with. Because Ms. Reimer was vague on the exact time period the shared custody took effect, I am sure it was by accident that she testified to seeing Stephanie happy for the first time in March 1999, since entering the Baker School.

When I questioned Ms. Reimer, I gave her a list of psychological symptoms that were indicators of severe emotional abuse. Ms. Reimer agreed they fit her behavioral profile of Stephanie. She went on to admit they were aware that these were signs of emotional abuse that the school had been watching for some time.

In summary when Shannan Kelly testified, she tried to portray me as this uncooperative father who just couldn't believe his daughter was mentally ill. Accordingly, I just couldn't get behind CYS's suggestions or Dr. Baker's and Dr. Eugene Polmueller's treatment regimen of Stephanie.

About five minutes into my cross examination of Ms. Kelly, it came to my attention that she failed to bring as much as a piece of paper to the witness stand let alone CYS records as was directed by subpoena. I asked Ms. Kelly where the CYS records were? Carpenter intervened and asked if I was interested in something particular? I answered yes, their daily casework sheets. Carpenter then negotiated with me that perhaps Ms. Kelly could give him those records later and he would review them. He asked what I wanted from those records in particular? I told him I was interested in how many complaints Ms.Frederick filed against me after the custody agreement was reached. Carpenter asked if I would care if the records were given to him and he would look for that information privately. Reluctantly, I agreed. However, my very next question to Ms. Kelly was, were there complaints filed by Ms. Frederick after the agreement? She answered, yes. I asked Ms. Kelly if CYS ever thought that Ms. Frederick was trying to undermine the custody agreement? She answered no.

I then questioned Ms. Kelly if she was aware of Stephanie being abducted by knife point? She answered yes, CYS knows about it. I asked her if this could be considered emotional abuse. She hesitated and then answered, she didn't know. I asked if Stephanie had told her that mom said her daddy never wanted her. She answered yes, but I couldn't believe that Stephanie's mother could say something like that to her. I asked if this actually occurred would this be emotional abuse? She answered, I don't know. I sarcastically asked Ms. Kelly if this was child protective services? She answered yes, well I know if someone told me my dad never wanted me it would bother me. I then read Ms. Kelly the same list of emotional abuse symptoms that I gave Ms. Reimer and I asked her if the symptoms reminded her of anyone? She answered "yes, Stephanie." I asked Ms. Kelly if she was aware of Munchausen by Proxy? She answered, she was. I asked Ms. Kelly to define this condition. She described it as mothers who make their children sick and then pretend to have these illnesses treated. I asked Ms. Kelly if she was saying that other mothers can make their children sick, but not Ms. Frederick? She answered, I didn't say that. I shot back, ma'am you just testified to that.

On re-examination, Ms. Frederick asked Judge Carpenter if she may ask Shannan question about something that was said to her in confidentiality? Mr. Carpenter said, she could. Ms. Kelly, could you tell the court what your opinion of Mr. Kearns is after a telephone conversation you had with him? Yes, I said Mr. Kearns is insane.

In summary, Mr. Lambert had testified that he was appointed by the school system to delve into Stephanie's emotional problems in the school environment. Mr. Lambert said from talking with Stephanie and his observations of her in class she was a likable normal girl who was under a lot of stress caused by the divorce situation. He saw Steph as being extremely perceptive to strangers entering her class room, especially if the teacher was pulled aside to talk. He believed that the parents not cooperating was the cause of her emotional instability. However, he acknowledged that Stephanie's deterioration was exacerbated by outside individuals (CYS and other professionals). He further reasoned Steph was to the point she was being pushed over the edge by the constant intervention into her life, but at the same time couldn't be left dealing with her problems alone.

When I questioned Mr. Lambert, if Stephanie's emotional deterioration was necessarily the result of both parents or could one parent effect her the same way? He answered one parent could cause it. I told Mr. Lambert that Stephanie had been put through several traumatic events in her life. He said that Stephanie's behavior's could be indicative of Post Traumatic Stress Syndrome and he never thought to explore that avenue. I asked Mr. Lambert if he saw Stephanie as being to the point of a nervous break down? He answered that Stephanie was just about ready to crack. He then told the court to excuse his language, but if you want my opinion the "Hell" has been beat out of Stephanie.

During the April 6th, 2000 hearing, three witnesses testified in chronological order: Mrs.Diane Beiswenger, Dr. Eugene Polmueller, Diane Beiswenger (finishing up), and Mr. David Kearns.

Mrs. Beiswenger's and Mr. David Kearns' testimony centered on Stephanie's behavior before and after the marriage breakup. Essentially, they described Stephanie as a kind, likable, well-behaved girl before the breakup. They described her attitude and behavior with the paternal family during the post breakup as virtually the same. Mr. Polmueller's testimony hinged on his treating Stephanie with mind altering drugs and his psychological conclusions that were primarily and regularly formulated on the input from Ms. Frederick.

Taking the same approach with Polmueller as I did with Ms. Kelly and Ms. Reimer, I asked him to listen to a list of the behaviors that Ms. Reimer and Ms. Kelly admitted to observing while professionally interacting with Stephanie. I then read him the list of psychological symptoms of emotional abuse that I had given Ms. Reimer and Ms. Kelly. Given that, I asked Mr. Polmueller to supply a definition to those symptoms? He answered that could indicate emotional distress. I asked would that mean emotional abuse? He answered "yes."

The Rest of the Story - continued