Chronology of The Civil Rights Crime Stemming From My Divorce From Attorney Richard A. Voytas
July 1, 2021 • Following a year of separation, Attorney Richard A. Voytas (Petitioner), represented by At- torney Jack Cavanagh, filed a Divorce Petition in St. Louis County Missouri Family Court. Mr. Cavanagh emailed me on 07/01/21 to notify me that a divorce petition had been filed however, he delayed serving me with a copy of the pleadings , as evident in our email exchanges in July 2021. July 14, 2021 • Mr. Cavanagh’s Paralegal emailed me the pleadings they filed on Mr. Voytas’s behalf on 07/01/21. This was following two weeks of me requesting copies from Mr. Cavanagh after his initial email to me on 07/01/21 when he notified me they had been filed.. In addi- tion, I was forwarded a copy of an order assigning the case to The Division of Associate Circuit Judge Joseph L. Green (Div. 36) of St. Louis County Family Court, which according to the document was assigned to his division on July 8, 2021. Links Petitioner Rick Voytas’s: Petition For Dissolution Of Marriage Motion To File Under Seal * note that this document included an
assortment of lies suggesting that I had a “complicated custody situation”, when I had sole legal and physical custody of my sons from a previous marriage since 2018. They also claimed that my marriage to Mr. Voytas had been kept a secret from Mr. Voytas’s children, which was false. This was just the beginning of a barrage of materially fraudulent information that was about to ensue. It served to lay the foundation for the undermining my character, as well as my teenage sons, which only compounded as the litigation persisted. Mr. Voytas's Property Statement
August 6, 2021 • Attorney Susan Jacobson filed an Entry of Appearance & Request For Additional Time To File Responsive Pleadings on my behalf (Respondent), which was granted. August 30, 2021 • Attorney Susan Jacobson filed pleadings in response to Mr. Voytas’s Divorce Petition. A joint-motion was filed by Ms. Jacobson and Mr. Cavanagh, to request that The Court file The Parties’ pleadings under pseudonyms due to concerns related to my first-husband,
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and my sons’ and my known domestic abuser to St. Louis County Courts, Victor A. Ojeda. This was also necessary to correct the claims Mr. Cavanagh made in his Motion To File Under Seal that he filed with Mr. Voytas’s Divorce Petition in July (see 07/14/21). Links Respondent Anne Ojeda’s: Answer To Petitioner’s Petition For Dissolution Of Marriage Counter-Petition For Dissolution Of Marriage Property Statement Joint Motion For The Parties To Proceed By Pseudonym September 10, 2021 • The paralegal for Mr. Voytas’s attorney, Jack Cavanagh, emailed Ms. Jacobson to notify her that Mr. Cavanagh filed a Motion For Judgement On The Pleadings on Mr. Voytas’s behalf and scheduled a settlement conference for 10/06/21, and a hearing date for 10/19/21 in Judge Green’s Division (Div.36). October 6, 2021 • Attorney Susan Jacobson and I called into Judge Green’s Division for the settlement con- ference scheduled to take place via a conference call at 9:45am. Neither Ms. Jacobson or Judge Green’s Clerk, Karrie Cooper, were able to get in touch with Mr. Voytas’s Attorney, Jack Cavanagh, who ultimately ended up being a no-call/no-show. • Ms. Jacobson followed up with an email to Mr. Cavanagh regarding his absence the same day. She told Mr. Cavanagh that the settlement conference would need to be continued due to his absence and that I intended to proceed pro se moving forward. October 11, 2021 • Ms. Jacobson emailed Mr. Cavanagh a copy of her Motion To Withdraw from the case. At this point Ms. Jacobson still had not received a response from her email to Mr. Ca- vanagh on 10/6/21 regarding his absence at the settlement conference. Ms. Jacob- son’s motion included a copy of a formal letter filed with The Court, which a ffi rmed the in- formation she previously communicated to Mr. Cavanagh following his absence from the 10/06/21 settlement conference. This served as a formal record reflecting the status of the case at the time she withdrew. • Ms. Jacobson recommended that the settlement conference Mr. Cavanagh missed on 10/06/21 be continued to 10/19/21 since The Parties had yet to have one since their Peti- tion, and Counter-Petition, for Dissolution of Marriage were filed. Mr. Cavanagh never re- sponded or acknowledged the need to continue the settlement conference that he missed on 10/06/21, or ever addressed his unexplained absence to Ms. Jacobson or The Court .
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October 18, 2021 • Susan Jacobson emailed Jack Cavanagh after not receiving a response to her corre- spondence, due to his absence for the scheduled settlement conference on 10/06/21. She told Mr. Cavanagh that Judge Green had not signed o ff on her Motion to Withdraw which she filed on 10/11/21. • Ms. Jacobson told Mr. Cavanagh that I was copied on the email she sent him, to ensure that I was provided information regarding whether the court setting scheduled in Judge Green’s Division for the following day (10/19/21) would be held in-person or online, since it was no longer going to be a hearing but rather a continuance of the settlement con- ference for which he was an unexplained no-call/no-show. • Jack Cavangh responded to Ms. Jacobson’s email to let her know that the settlement con- ference on 10/19/21 would be held online on The Court’s video-conference system called Webex. He did not express any disagreement with Ms. Jacobson’s assertion that the following day, 10/19/21, was not going to be a hearing but rather a settlement confer- ence to make-up the one he was absent for on 10/06/21. October 19, 2021 • I emailed Judge Green’s Division Clerk, Karrie Cooper, to confirm there was no need to call into the division for the settlement conference, which my former attorney, Susan Jacobson, had confirmed details about with Mr. Cavanagh the prior day by email. Ms. Cooper emailed me back to let me know that it was still scheduled as a hearing, despite Susan Jacobson’s confirmation with Mr. Cavanagh that it would replace the settlement con- ference he was a no-show for on 10/6/21. • Judge Green’s Division previously acknowledged that the missed settlement confer- ence would need to be continued (see 10/6/21 email between attorneys regarding The Division’s plan to continue the settlement conference after no one could reach Mr. Cavanagh). • At 4:00 PM, Mr. Cavanagh and I both logged into The Court’s online platform (Webex) to attend a hearing, despite Mr. Cavanagh knowing that Ms. Jacobson confirmed with him just 24 hours earlier that the meeting would be treated as a continuation of the set- tlement conference he missed on 10/6/21 . Links Video with audio and captions from the 10/19/21 hearing with Judge Joseph L. Green, held via the online platform Webex, which was supposed to be The Parties’ first settlement conference in the case rather than a hearing Certified Transcript from 10/19/21 which corresponds with video/audio linked above. • After the hearing, I never received a copy of any orders, or the Interim Judgement entered by Judge Green dissolving The Parties’ Marriage in advance of The Court even having accurate income and property statements from Mr. Voytas. I did not find out an Interim Judgement had been entered l until months later (see events listed under 12/29/22. It wasn’t signed by The Parties and based on the transcript and audio of the hearing held on 10/19/21, Mr. Voytas and his Attorney Jack Cavanagh had not submitted the minimum 3
required information to proceed with a hearing, let alone for an Interim Judgement to be entered. • In addition to the fact The Parties had not signed anything that day, Judge Green did not request my verbal consent to enter an Interim Judgement. Instead, he only elicited it from Mr. Cavanagh, and proceeded as though my consent was irrelevant as a pro se litigant. November 8, 2021 • Jack Cavanagh filed a Motion for Judgement and a Notice of Hearing for 01/04/22. His paralegal emailed me copies since I still did not have access to the case record or docket, or any means of receiving notifications when something was filed or altered. December 8, 2021 • I filed a Motion in Objection through St. Louis County Court’s Domestic Relations Depart- ment’s e-filing system for pro se litigants in response to Mr. Cavanagh’s Motion For Judge- ment. I also emailed a copy of the motion to Judge Green’s Division Clerk, Karrie Cooper, and the opposing counsel, Attorney Jack Cavanagh. December 14, 2021 • I contacted Attorney Cynthia Albin to have her review the case and emailed her the docu- ments that I had received copies of from Mr. Voytas’s Attorney, Jack Cavanagh up to that point in time. • Since the time of the October 19, 2021 hearing in Judge Green’s Division, I still had not re- ceived copies of The Property Statement Mr. Voytas needed to correct so we would have the minimum information to proceed with litigation. There were other significant outstand- ing issues that were raised during the 10/19/21 hearing, but unresolved. Those issues in- cluded Judge Green’s denial that my former attorney Susan Jacobson filed an Answer and Counter-Petition of Dissolution on 08/30/21 (see links to filings listed under 08/30/21), and that 10/19/21 was supposed to be a continuation of the first settlement conference in the litigation that was inexplicably missed by Mr. Cavanagh on 10/06/21. • It’s evident in my Counter-Motion to their Motion for Judgement which was filed in November 2021 (copy provided to me via email by Mr. Cavanagh) that I was unaware an Interim Judgement was entered on 10/19/21. I did not have access to the case file at the level of security it had been placed under by Judge Green on 10/19/21. December 21, 2021 • I formally retained Attorney Cynthia Albin in advance of the hearing scheduled in January related to Mr. Voytas and Mr. Cavanagh’s Motion for Judgement and my Counter-Pleading filed in response, which Ms. Albin reviewed prior to entering the case.
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December 28, 2021 • Cynthia Albin filed an Entry of Appearance, a Motion for Continuance and a Notice of Hear- ing related to Mr. Cavanagh’s outstanding Motion for Judgement and my Counter-Motion. • Ms. Albin scheduled a settlement conference to be held on 02/09/22 with Mr. Cavanagh and Judge Green. December 29, 2021 • I notified Ms. Albin via email that Mr. Voytas was six months away from getting remarried based on a wedding announcement posted online. Ms. Albin said that Mr. Voytas would need to finalize our divorce prior to his remarriage. She stated she would speak with Mr. Cavanagh regarding the issue causing the delay. • Shortly after consulting with Mr. Cavanagh, Ms. Albin told me that the marriage had already been dissolved without the marital assets and liabilities even being identified. She said it was “atypical” and she knew that on 10/19/21 I wasn’t presented with the terms of that judgement, was not provided a copy to review or sign, hadn’t given my verbal con- sent, did not have my former attorney’s counter-pleadings recognized by Judge Green, nor did I have ongoing access to the active case file/docket. • The Interim Judgement suggested that Mr. Voytas would be the only party to report what our marital liabilities and assets were, how they were going to be divided, and could sub- mit that information to The Court at a later date after the marriage was already dis- solved. It was as if I was not a valid participant in the case. • It didn’t appear to be a reasonable document that any party to a divorce would consent to. The document essentially waived one spouse’s rights to participate in the legal processes required to identify, and divide marital liabilities and assets in Missouri. This was consistent with the fact that on 10/19/21 Judge Green tried to intimidate me from a ffi rming the truth about the Counter-Pleadings that were filed by my former attorney, Su- san Jacobson (see 08/30/21), and that a settlement conference had not been held yet in the case. This was evident due to Mr. Cavanagh’s unexplained absence on 10/06/21 (see events listed under 10/06/21 and 10/19/21). • Judge Green and Mr. Cavanagh delayed/obstructed my ability to identify in real-time when materially-fraudulent orders and judgements were being filed because I never had access to the active case file/docket. This was a well-documented issue throughout the litiga- tion, as there has never been a formal acknowledgment or remedy provided . • The Interim Judgement provided to Ms. Albin by Mr. Cavanagh, represents the first legal document entered by Judge Green that constitutes criminal fraud based on the criteria set forth in MO Rev Stat § 570.095 as part of a Conspiracy Against Rights Crime (18 U.S.C.,Section 241). January 2022 • While The Parties awaited the next case setting scheduled in the matter, which was sched- uled for 02/09/22 by Ms. Albin (see 12/28/21), Attorney Jack Cavanagh was unresponsive to Cynthia Albin’s attempts to resolve the issue preventing the resolution of The Parties’
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Divorce. The issue was Mr. Voytas’s unwillingness to allow The Court to enter an en- forceable Marital Property Settlement Agreement, congruent with Missouri Law, and directed by the terms of The Parties’ Post-Nuptial Agreement. • While I was represented by Attorney Susan Jacobson she had the same issues with Mr. Cavanagh’s lack of responsiveness, including incidents like his unexplained absence at the only settlement conference that had been scheduled (see 10/06/21) since The Parties’ Divorce Petition, and Counter-Petition were filed in The Summer of 2021. • Mr. Cavanagh and Mr. Voytas remained insistent that The Marital Property Settlement Agreement state that the former marital home was going to remain co-titled, and the sale deferred, preventing me from fully severing ties with Mr. Voytas and regaining control of my individual liabilities and assets. This was particularly distressing as a sole cus- todian of two minors who I have been the sole financial provider for since 2017. February 9, 2022 • Ms. Albin emailed me the morning of the Settlement Conference that was scheduled to be held between her, Jack Cavanagh and Judge Green on this day. In that email, Ms. Albin forwarded an exchange she had with Mr. Cavanagh in which she indicated to him that The Martial Property Settlement Agreement should reflect that The Parties planned to sell the former marital home, rather than continuing to co-own it. • The Opposing Party’s position was unchanged, despite the fact there was not a legal claim which would support what they were motioning of The Court , as outlined in my Motion In Objection filed in response to The Opposing Party’s Motion for Judgement. • I emailed Ms. Albin that evening to ask her what happened at the settlement conference between her, Mr. Cavanagh and Judge Green earlier in the day. She said she would con- tact me afterwards, but never did. February 11, 2022 • Ms. Albin emailed me to set up a time to discuss what occurred during the Settlement Con- ference on 02/09/22. February 26, 2022 • In an email exchange between Cynthia Albin and I following the settlement conference held on 02/09/22, I explained to Ms. Albin that I would not sign the Consent Judgement and Stipulation she and Attorney Jack Cavanagh were proposing at that time because it directly conflicted with Missouri Law related to the division of marital property. March 1, 2022 • I received an email from Cynthia Albin’s paralegal with a copy of Petitioner’s Motion For The Court To Declare Postnuptial Agreement For Full Division of Property and Liabilities of The Parties which was filed by Jack Cavanagh, on Mr. Voytas’s behalf. The email was sent to me on 03/01/22 but the motion attached to it was dated as being filed on 02/25/22. • This motion was essentially the same as The Motion for Judgement Mr. Cavanagh filed in November 2021, and I filed a Counter-Motion in response to, which I retained Attorney
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Cynthia Albin to represent in December 2021. After a settlement conference on 02/09/22, the issues between The Parties remained unresolved. March 3, 2022 • Cynthia Albin and I had another email exchange regarding why I refused to sign the Con- sent Judgement and Stipulation she sent me a draft of following the settlement conference between her, Attorney Jack Cavanagh, and Judge Green on 02/09/22. March 9, 2022 • Cynthia Albin emailed me with the only correspondence she received in response to her attempts to contact Attorney Jack Cavanagh regarding the redundant motion they filed (see 03/01/22) which was the same as the one I already filled an outstanding Counter-Motion in response to. The only thing preventing settling the case was The Court identifying and dividing The Parties’ liabilities and assets in a Martial Property Settlement Agreement entered by The Court which reflected the terms of the final home sale rather than a continued co-ownership. March 11, 2022 • I emailed Ms. Albin asking her if we needed to respond to their redundant pleadings, even though there was already an outstanding motion filed by me which objected to the same motion when they filed it in November 2021. March 14, 2022 • Ms. Albin emailed me to re-assert her position, which was totally opposite from the position she held upon her agreement to enter the case (see events listed under December 2021). The Parties’ Post-Nuptial Agreement specifically stated that The Court would defer to “the wife” as to the date of the home sale, and that The Court would perform a statutory review and strike terms no longer valid as a result, without invalidating the entire agreement, when entering a final Marital Property Settlement Agreement. • In Missouri, pre- and post-nuptial agreements include directives about how The Parties would like The Court to execute the identification and division of their marital liabilities and assets in the event of a divorce being filed. In contrast, a Martial Property Settlement re- flects how The Court actually did identify and divide parties’ marital liabilities and assets upon divorce, whether or not it was based on the directive of a pre- or post-nuptial agree- ment or not. A pre- or post-nuptial agreement is not legally equivalent to The Court’s final judgement, which is why in industries that require accountability to The Law, such as mortgage lending, a pre- or post-nuptial agreement cannot be submitted in place of a final divorce judgement entered by The Court to determine someone’s post-dissolution debt-to-income ratio and assets. • Accordingly, The Opposing Party had no legal basis to suggest that The Court would not serve its mandated function, and instead request that I sign a stipulated consent judgement stating that the way the property division was being handled was congruent with Missouri Law. Ms. Albin read the motion I filed just prior to retaining her in December 2021 which cited Missouri Law, and Case Law, that establish the legal bounds that Missouri Courts must operate within when dividing marital liabilities and assets in order to provide fi- nality for the e ffi ciency of The Courts and preservation of The Public’s interests.
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• In Ms. Albin’s email, she notified me that there was a hearing date set for The Opposing Parties’ Motion To Enter Post-Nuptial Agreement as Judgement on 04/19/22, which is the motion I emailed her about on March 11, 2022. I never received a response as to whether we needed to refile the Counter-Motion objecting to the same pleadings that I filed in De- cember 2021 after they filed the same pleadings in November 2021. There had not been a hearing for those outstanding motions since the time of the 02/09/22 settlement conference with Judge Green, which left those motions unresolved by consent of The Parties. • The technique for advancing the crime Ms. Albin engaged in was repetitively gas-lighting me by suggesting that I was asking something of The Court that Missouri Law doesn’t require of it anyway, and was somehow being unreasonable. She would then use these claims to support why she would not represent me if I would not waive my right to protections provided by the terms within The Post-Nuptial Agreement, which provided for me to determine the date of sale at the time a divorce petition was filed and the marital liabilities and assets divided. Ms. Albin was aware this would prevent my sons’ and I from being able to establish a new home that I could a ff ord to maintain post-divorce as a sole custodian and sole financial provider, and leave unresolved legal matters with someone who was months away from getting married again. • I emailed Ms. Albin a link to the audio from the only other meeting between The Parties and Judge Green in the case, which was held on 10/19/21, during which Judge Green and Mr. Cavanagh pretended there had been a settlement conference, and that my former at- torney hadn’t filed counter-pleadings, when it was clear that she had. In addition, it indicated that the property still had not even been identified by The Court because the op- posing party had not provided the information required to do so. I was requesting her to file a Motion to Disqualify For Cause which would need to be filed in The Division of The Presiding Judge of The Judicial Circuit, Judge Mary E. Ott (Div. 7). March 18, 2022 • There was an email exchange between Ms. Albin and I regarding my request for her to file a Motion to Disqualify Judge Green for Cause on my behalf. The last message in the email thread was sent by me and I did not receive any further contact from Ms. Albin or her o ffi ce, until an email correspondence I received from her paralegal on 03/30/22. March 30, 2022 • Cynthia Albin’s paralegal emailed me a copy of a letter, Motion to Withdraw, and Notice of Hearing filed by Ms. Albin. Her Notice of Hearing requested a 04/11/22 date which was exactly seven business-days from the time she was notifying me of it. She did not even co- ordinate a date or time that I could be available. That date was also just a week away from the hearing Jack Cavanagh had set for April 19, 2022 for their Motion to Enter Post-Nuptial Agreement as Judgement. • Ms. Albin knew that I requested that she, at minimum, notify The Presiding Judge of The St. Louis County Judicial Circuit, Judge Mary E. Ott, that she refused to file a Motion to Dis- qualify Judge Green for Cause on my behalf, and was requesting to withdrawal from my case as a result of that disagreement. This would allow The Presiding Judge, who hears motions related to judicial misconduct of other judges practicing in The Judicial Circuit, to be aware there was an immediate issue significant enough to result in Ms. Albin’s with- drawal.
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April 8-10 2022 • I had an email exchange with Mr. Albin regarding my therapist’s (Stacey Smith) attempt to reach her. Ms. Smith had just notified another division a month before about what appeared to be an attempt by my two former spouses keep me tied up in two lawsuits at the same time, while they misrepresented a multitude of important facts that were mater- ial to the cases (see timeline for other case in March 2022). April 11, 2022 • I corresponded via email with Ms. Albin in the days leading up the hearing held on 04/11/22 regarding the fact that I could not be present in-person at the day/time she chose for the hearing for her Motion to Withdraw because my son had an outpatient medical procedure scheduled that day. I implored Ms. Albin to ensure that upon her withdrawal from the case that she notify The Division of The Presiding Judge of The Judicial Circuit, Judge Mary E. Ott, that she was withdrawing from a case because she refused to file a Motion to Disquali- fy Judge Green For Cause for a client. This was important so that Judge Ott would be aware that upon Ms. Albin’s withdrawal she would be receiving that motion from me, as a newly self-represented client. This was particularly important because Ms. Albin scheduled her hearing for her Motion to Withdraw a week before the opposing party scheduled a hearing for their Motion to Enter Post-Nuptial Agreement as Judgement and I did not want to proceed prior to having The Presiding Judge hear a motion regarding the criminal misconduct of Judge Green. This also included the misconduct of the attorneys who had been involved in the case up to that point. In addition, the issue of not having access to my active case file was also still unresolved, which Ms. Albin was aware of . • I attended the hearing for Ms. Albin’s Motion to Withdraw on 4-11-22 via the online plat- form Webex, while the other parties attended in-person. Judge Green said there were technical issues preventing my audio from coming through so I was only able to hear what was happening and not participate. However, I tested the audio prior to the hearing, since The Webex Platform allows participants to ensure their audio and video are functioning pri- or to going “live” with a hearing, and there was not an issue. Regardless, during the hear- ing Ms. Albin did not indicate to The Court that our disagreement was regarding her refusal to file a Motion to Disqualify Judge Green for Cause or that I was concerned about it being filed prior to me being pro se again in Judge Green’s Division. • Judge Green granted Ms. Albin’s withdrawal from the case. He also told The Parties that we would proceed with the April 19, 2022 hearing scheduled for The Opposing Party’s Motion to Enter Post-Nuptial Agreement as Judgement, and my counter-motion which was outstanding from December 2021 when I first retained Ms. Albin. April 15, 2022 • As a pro se litigant since the time of Attorney Cynthia Albin’s hearing for her Motion to Withdraw on 04/11/22, I filed the Motion to Disqualify Judge Green for Cause that Ms. Albin would not. • I filed an Emergency Motion to Disqualify Judge Green for Cause in two Administrative Di- visions- one in The Division of The Presiding Judge of The Judicial Circuit, Judge Mary E. Ott (Div.7) and the other in The Division of The Head of Family Court, Judge Jason D. Dod- son (Div.10).
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• I also filed an Emergency Motion for Continuance for the hearing that was scheduled to be held in Judge Green’s Division on 4/19/22. I sent email correspondences confirming receipt of the filings with all parties on the same day, and to secure a date for the Motion to Disqualify Judge Green for Cause. Links Email to Attorney Jack Cavanagh with copies of filings and notice of The Motion for Continuance of the hearing that was scheduled for 4/19/22. Email correspondence with The Presiding Judge’s Clerk, Carol Turner, copying all parties including Judge Green’s Division Clerk, Karrie Cooper. Email correspondence with Carol Turner who is The Division Clerk for The Presiding Judge of The Judicial Circuit, Judge Mary E. Ott. She directed me to file the motions in The Division of The Head of Family Court, Judge Jason D. Dodson (Div.10) and contact his clerk, April Moore. Email confirming receipt of filings from The Domestic Relations O ffi ce. April 19, 2022 • April Moore, the clerk for The Division of The Head of Family Court, Judge Jason D. Dod- son, emailed me to let me know that without a hearing, or formal response of any kind, Judge Dodson was communicating through her that The Parties had to proceed with the hearing scheduled that day, April 19, 2022, in Judge Green’s Division (36). • The hearing scheduled for R.V.’s Motion to Enter Post-Nuptial Agreement as Judgement, and my counter-motion proceeded despite my Emergency Motion for Continuance request- ing a hearing regarding my disqualification motion in an Administrative Judge’s Division, prior to proceeding with another hearing in Judge Green’s Division following Ms. Albin’s withdrawal from the case on 4-11-22. • During the hearing, Judge Green denied that I filed pleadings related to his disqualification for cause and a continuance of the hearing scheduled for that day (4/19/22), despite the fact I was in receipt of a filing confirmation from The Domestic Relations Department. (transcript of hearing, pg. 8-11) When I requested that there be a resolution to the filing is- sues that I was experiencing exclusively in Judge Green’s Division, he proceeded to mock my ability to follow instructions. • Judge Green told me that if I filed something that I would have received a notification from The Court’s Online Case Filing System known as “Case Net”. Judge Green and Attorney Jack Cavanagh were aware that was false since the case file was sealed and he is the one who sealed it on 10-19-2, so there was nothing visible online related to the case (transcript of hearing, pg. 9, lines 19-25). • Judge Green stated that I would lose my right to give an oral argument to The Court in the hearing that was about to take place should I continue to ask about resolving issues related to Due Process in his division. (transcript of hearing, pg. 11). • During the hearing I continued to try and compel Judge Green to recognize that the
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governance MO Statutes have over marital property division is not discretionary, but he continued to deprive me of my ability to engage The Law. He continued to create the need for protracted litigation by suggesting a need for additional legal processes which were unnecessary to the issue being presented, which was a failure to state a legal claim by R.V. and his counsel. The Court can’t enter something that isn’t legal- the law would supersede it (transcript of hearing, pg. 13 lines 1-41 and pg. 18, lines 7-19). • At the end of the 4-19-23 hearing, Judge Green told the parties that he knew that I “wanted to get away from him” (transcript of hearing, pg. 17 lines 28-32) and the parties were then presented an order which they signed consenting for the case to be reassigned to another judge’s division to have the marital property identified/divided. June 3-8th 2022 • After not receiving any kind of notice regarding whether the case had been reassigned to one of the other divisions The Parties consented to at the end of the hearing on 4/19/22, I followed up with Judge Jason D. Dodson’s Division by emailing his clerk, April Moore, who I previously corresponded with regarding the motion I filed for Judge Green’s Disqualifica- tion for Cause. In the email, I included a link to the audio of the hearing held on-record on April 19, 2022 in Judge Green’s Division after Judge Dodson refused to allow me to set a hearing date for The Motion to Disqualify Judge Green For Cause. I let Ms. Moore know that there was still a need for Judge Dodson to hold a hearing because the issues were persisting, and I didn’t even have access to the case file. I did not receive further correspondence from Ms. Moore following the last email in that exchange. June 14, 2022 • As evidenced by my correspondence the week prior with the clerk of the judge who was supposed to reassign the case to another division, Judge Dodson (Div. 10), the case re- mained unassigned, so further movement in the litigation was on hold. • I emailed Attorney Jack Cavanagh to see if Mr. Voytas was willing to settle the outstanding litigation by agreeing to terms of a Marital Property Settlement Agreement, which would reflect the date the marital home would be listed and how the proceeds would be divided. We still hadn’t even identified The Parties’ martial liabilities and assets (see hearing 10/19/21) and Mr. Voytas was getting remarried in just a few weeks at this time. • I never received a reply from Mr. Cavanagh. The next time Mr. Cavanagh contacted me was at the end of August 2022, a few weeks after Mr. Voytas’s destination wedding in July 2022. At that time, Mr. Cavanagh’s O ffi ce provided me a copy of a motion they filed in a newly-assigned court division which claimed I was in breach of the post-nuptial agreement (reference 8/23/24). July 2022 • There was no correspondence from The Opposing Party, or The Court, during this month. Mr. Voytas was remarried by the end of the month. He was able to proceed with remar- riage, and fund a destination wedding among other things, even though The Court had not even identified his marital liabilities and assets with me (see 10/19/21 hearing), nor entered a plan for their future division. Mr. Voytas was forming financial entanglements with a new spouse while I could not be recognized by financial institutions to establish new
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credit, because I could not provide a legal judgement indicating my post-dissolution debts and assets. August 23, 2022 • I was not notified when the case was temporarily reassigned to Judge Mondonna Ghasedi in Division 43 , prior to her ordering the case to be sent back to Judge Green after R.V. and Mr. Cavanagh filed a motion in her division titled Petitioner’s Motion For The Court To Find That Respondent Has Breached The Post-Nuptial Agreement And To Divide The Marital Property Equitably And In Accordance With The Source Of Funds Rule; For Rent From Respondent For Occupation Of The Real Estate; For Quantum Merit Of Rent Due From Respondent’s Occupation Of Real Estate. When Mr. Cavanagh filed this motion in Judge Ghasedi’s Division on 08/23/33, Attorney Jack Cavanagh’s Paralegal emailed me a copy of the motion they filed and stated it was being filed in Division 43, which was the only way I found out the case had been assigned to a new division at that point, or that a motion had been filed. • The reassignment of the case to another division, by consent of The Parties at the 4/19/22 hearing in Judge Green’s Division (Div. 36), was being handled by The Head of Family Court, Judge Jason Dodson (Div.10). Judge Dodson’s Clerk, April Moore, was aware that I did not have access to the case file and was not receiving notifications. On 06/03/22, Ms. Moore responded by email regarding my concern about my lack of access to the case file and inability to receive notifications about the status of the case reassignment. In that email , Ms. Moore assured me that she would notify me when the case had been as- signed a new division however she did not, nor did she respond to my last email sent in the exchange on 6/9/22 related to the outstanding issues. August 24, 2022 • The Parties received an email from Judge Ghasedi’s Division (Div.43) notifying them Judge Ghasedi entered an order transferring the case back to Judge Green’s Division the day after the opposing party emailed me a copy of the motion they filed in her division as a result of the reassignment, which I was unaware had even been made. Just two months prior I contacted Judge Dodson’s Division and notified his clerk, April Moore, that I did not have access to the case file and could not receive notifications. • In Judge Ghasedi’s order, she noted the reasons she was transferring the case back to Judge Green’s Division for “further proceedings”, despite The Parties agreement for it to be transferred in April 2022. Judge Ghasedi cited the fact that The Parties did not contact her division promptly when it was assigned to it, even though as evidenced by my cor- respondence with Judge Dodson’s Division Clerk, April Moore, in June 2022 that Ms. Moore said she would notify me since I didn’t have access to the case file, and she never notified me . The second reason Judge Ghasedi cited was the fact that The Opposing Party filed a motion that was unrelated to the legal issue The Parties still needed to resolve, which was the identification and division of their marital liabilities and assets in the form of a Marital Property Settlement Agreement.
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• The Opposing Party continued to act as though I was breaking a contractual agreement by asking that The Court to enter a Marital Property Settlement Agreement in accordance with Missouri Law, even though it would be directed by The Parties Post-Nuptial Agreement. As stated in my counter-motion filed in December 2021 in response to their Motion For Judgement, Mr. Cavanagh and Mr. Voytas weren’t even asserting a legal claim. The terms of The Parties’ Post-Nuptial Agreement directed The Court to defer to me as to whether the former marital home sale would be delayed post-dissolution, since I would be responsible for the maintenance if it was, and strike terms that were no longer valid follow- ing a statutory review prior to The Court entering the final judgement. • Mr. Voytas did not want The Court to execute a Marital Property Settlement Agree- ment that was legally enforceable and congruent with Missouri Law. They continued to try and contort the simplicity of the issue when I would not consent to The Court sim- ply entering a divorce decree, and agreeing that The Parties had already su ffi ciently divided their liabilities and assets because they entered into a post-nuptial agreement . A pre- or post-nuptial agreement does not replace The Court’s Marital Property Settlement Agree- ment in a divorce which contains terms that provide for a complete severance of ties and other criteria prescribed by Missouri Law. • Mr. Voytas, an attorney himself, wanted to prevent the finality and enforceability that a Marital Property Settlement Agreement entered in accordance with Missouri Law possess. This would have prevented his ability to weaponize legal proceedings in order to obstruct me from liquidating my stake in our most significant marital asset, the marital home, upon its sale. Mr. Voytas was attempting to use St. Louis County Court, and his network of legal colleagues within it, as a means to prevent me, and the two sons who I am the sole custodian and financial provider for, from regaining our financial inde- pendence post-divorce. September 6, 2022 • Attorney Jack Cavanagh’s Paralegal emailed me a copy of a notice of a settlement confer- ence, filed by Mr. Cavanagh in Judge Green’s Division (Div.36) related to the motion that he originally filed in Judge Ghasedi’s Division two weeks prior (see 8/23/22). The matter was transferred back to Judge Green’s Division after Judge Ghasedi noted in her Transfer Order that the motion Mr. Cavanagh filed on 8/23/22 indicated that The Parties were not ready to proceed with a trial related to the identification and division of their marital liabilities and assets (see 8/23/22 and 8/24/22). • Mr. Voytas scheduled the phone settlement conference with Judge Green for 11/03/22. September 9, 2022 • I filed a second Motion To Disqualify Judge Green For Cause , since the first one I filed on 4/15/22 was denied a hearing and/or a formal response by The Head of Family Court, Judge Jason D. Dodson. Despite The Parties consenting to the case being reas-
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signed to a di ff erent judge on 4/19/22, the case had been transferred back to Judge Green before I was even notified of its reassignment (see 8/23/22 and 8/24/22). • This motion, and the 57 exhibits filed with it, presented a persistent pattern of due process obstruction and fraud. I specifically cited The Federal Civil Rights Codes which were applicable at that point in time, given the obstruction of Due Process had proven to be intentional. • A hearing date was set for October 11, 2022, in The Division of the Presiding Judge (Div. 7), Judge Mary Elizabeth Ott. • The first Motion to Disqualify Judge Green For Cause I filed on 4/15/22, four days after the withdrawal of my former attorney, Cynthia Albin, was originally filed in Judge Ott’s Division but she requested that it be refiled in The Head of Family Court’s Division, Judge Jason D. Dodson, who ultimately refused to hold a hearing for it. October 11, 2022 • A hearing was held for my Motion To Disqualify Judge Green For Cause in The Division of The Presiding Judge of The St. Louis County Judicial Circuit, Judge Mary E. Ott (Div.7). Links Emergency Motion to Disqualify Judge Green For Cause filed by me in September 2022 in The Presiding Judge’s Division (Div.7) Corresponding Exhibit Book filed with motion Certified Transcript of the hearing held on 10/11/22 in Judge Mary E. Ott’s Division (Div.7) Audio of 10/11/22 hearing that corresponds with the certified transcript above • At the end of the hearing, Judge Ott was made aware that since the first time I contacted her division with a Motion to Disqualify Judge Green For Cause on April 15, 2022, that Judge Green was assigned to a second lawsuit that was filed against me by my first husband and known domestic abuser to The Court, Victor A. Ojeda (see pages 32-35 of hearing transcript ). Mr. Ojeda’s ongoing harassment of my teenage sons and I was one of the primary causes cited for my divorce from my second husband, Mr. Voytas, to be filed under initials. Reference 8/30/21 joint-motion filed by my former attorney (Susan Jacob- son) and Mr. Voytas’s Attorney, Jack Cavanagh, to have my divorce from my second hus- band, Mr. Voytas, filed under pseudonyms. • In April 2022, Judge Ott referred the first Motion to Disqualify Judge Green For Cause that I filed at that time, to The Head of Family Court’s Division, Judge Jason D. Dodson. Howev- er, Judge Dodson refused to hear the motion and instead assigned Judge Green to a
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second active case filed against the same woman who was reporting to Judge Dodson that Judge Green was engaging in criminal misconduct in another active case. • It was just two months after my last email correspondence to Judge Dodson’s Clerk regarding the ongoing issues I was experiencing with Judge Green in my divorce from local attorney Rick Voytas, that he assigned Judge Green to a lawsuit filed against me by my first husband and known domestic abuser, Victor A. Ojeda. • Judge Ott was made aware at the end of the hearing in her division on 10/11/22, that Judge Green had begun scheduling dates in his division for the second matter, filed by Mr. Ojeda in June 2022 and assigned to Judge Green in August 2024. In fact, Judge Green scheduled the first case conference for the second legal matter assigned to him, filed by Mr. Ojeda, to take place less than 24 hours after the hearing we were having re- garding his Disqualification for Cause in my divorce from Mr. Voytas on 10/11/22. October 13, 2022 • I emailed Judge Ott’s Division Clerk, Carol Turner, to find out how I will be notified when a judgement has been entered from the hearing held two days earlier, on 10/11/22 in Judge Ott’s Division. I explained to her that I had not had access to the active case file, nor was I receiving notifications electronically due to the level of security the case was further elevat- ed by Judge Green in October 2021. I never received a response from her. October 18, 2022 • I received a judgement via certified mail from Jude Ott’s Division (Div.7) approximately a week after the hearing was held. I did not know a judgement had been entered until this time. Despite contacting Judge Ott’s Division on 10-13-22 for a confirmation as to whether she entered a judgement yet, and how I would be notified. No one would confirm a judge- ment was entered in the file and how/when I could review it. • Judge Green proceeded with litigating the second case filed against me by a di ff erent for- mer spouse, and known domestic abuser, Victor A. Ojeda. He met with Mr. Ojeda’s Attor- ney, Roseanne Horan on 10-12-23 for the first time since the matter was assigned to his division, less than 24 hours after the hearing for his Disqualification For Cause in my di- vorce from Attorney Rick Voytas. • The judgement summarized a legal argument and evidence, which the transcript from the hearing on 10/11/22 reveals is not what occurred in Judge Ott’s Division that day. This is particularly evident on pages 19-20 of the transcript when Judge Ott clarifies my argu- ment, when compared to what she states it was in her judgement. The discrepancy is evi- dent in reviewing the certified hearing transcript and exhibits filed, juxtaposed to the judgement entered.
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• Judge Ott’s judgement claimed that my argument for Judge Green’s Disqualification For Cause was precisely what she clarified on-record that it was not . Based on the judgement, no one would even know that I accused Judge Green of intentionally obstructing my 14th Amendment Rights and covering it up with a fraudulent case record, which I still did not have the ability to access or receive notifications about when there was activity. • Judge Ott engaged in the same crime that I brought to her attention in her role as The Presiding Judge of The St. Louis County Judicial Circuit. In her judgement, she described a set of materially fraudulent facts that would allow her to apply the law in a way that would result in the outcome her colleague, and the attorneys involved in the case, needed to conceal their crime and finish it to completion. • In response, I filed an Emergency Motion for Relief From Judgement or Order In Accor- dance With MO Procedural Rule 74.06 , along with the corresponding exhibits, in Judge Ott’s Division (see January 13, 2022). According to MO Procedural Rule 74.06, this motion can be granted by The Court at any time upon a motion being filed, or by The Court’s own initiation, to remedy an order, judgement, or other part of a court record, that is not accurate due to clerical error, oversight, irregularities, the absence of due process which would render a judgement “void”, or intentional fraud. November 2, 2022 • I received an email from Attorney Jack Cavanagh’s Paralegal reminding me of the phone settlement conference they scheduled in Judge Green’s Division for the following day relat- ed to their outstanding motion (see 9/6/22 when the notice was filed). November 3, 2022 • As instructed the day before by Mr. Cavanagh’s Paralegal, via email, I waited for a call from Mr. Cavanagh just prior to 9:30am. • I received a timely call from Mr. Cavanagh’s Paralegal, Cindy Goepel, who then requested that I remain placed on-hold while Mr. Cavanagh called Judge Green’s Division on another line. She said that once Mr. Cavanagh reached The Division, he would take me o ff hold and merge my call with his and Judge Green’s. • I remained on hold for at least thirty minutes before Mr. Cavanagh’s voice came on the line to tell me that no one was answering Judge Green’s Division’s phone-line and that his paralegal would email me about rescheduling the settlement conference. • His paralegal, Cindy Goepel, contacted me by email later that morning to reschedule the settlement conference that was missed because of Judge Green’s unexplained absence. In my response to her, I asked whether Mr. Cavanagh heard back from Judge Green’s Division since he mentioned that he left a message with The Division when no one answered after multiple attempts.
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• When Mr. Cavanagh’s paralegal, Cindy Goepel, emailed me again, my last response in the email thread, where I asked if they ever heard back from The Division, was deleted and she responded in a new email-thread without it. • I requested that Ms. Goepel provide me with a copy of Mr. Cavanagh’s Motion once it was filed, which would continue the settlement conference that was inexplicably missed by Judge Green that day. Mr. Cavanagh filed his notice that same-day, moving the confer- ence to 1/05/23, and she emailed me a copy of his scheduling motion as I had requested. • Recall that these case settings are for the last motion filed by Mr. Cavanagh on 8/23/22 in another division, which was transferred back to Judge Green’s Division by Judge Ghasedi. She stated in her 8/24/23 transfer order that based on Mr. Cavanagh’s "breach of contract" motion filed on 8/23/24 in her division, The Parties were not ready to proceed with a trial and therefore needed to go back to Judge Green for further pre-trial proceedings. November 7-8, 2022 • On 11/07/22 Attorney Jack Cavanagh copied me on an email he sent to a real estate ap- praiser, which prompted further email exchange between Mr. Cavanagh and I. • In that email exchange, when Mr. Cavnagh mentioned the case being set for a trial, I told Mr. Cavangh that I was totally unaware and hadn’t received orders. This was particularly disorienting because the case had been transferred back to Judge Green’s Division be- cause The Parties were not ready for a trial based on Mr. Cavanagh’s outstanding mo- tion. • The last thing to occur in the litigation at this point was that Mr. Cavanagh filed a motion rescheduling the 11/03/23 settlement conference, that Judge Green was inexplicably ab- sent for just three days prior to this email exchange. • After responding to Mr. Cavanagh’s email to tell him that I had no idea what trial he was referring to, his paralegal forwarded copies of the orders that he referenced in our email exchange over the course of these two days. Upon review, I noticed that the date written next to Judge Green’s signature was 11/03/22, which was the day of Judge Green’s unex- plained absence which resulted in Mr. Cavanagh rescheduling the settlement conference, for the last motion he filed. • Judge Green entered orders for a trial on the same day he wasn’t available to partici- pate in the scheduled actions in the case. What was scheduled on 11/03/22 was a set- tlement conference for The Opposing Party’s outstanding motion, but Judge Green wasn’t available for it, nor did he follow-up with The Parties following his absence. Now, four days later, I was learning that he and Mr. Cavanagh had other plans than making up that missed settlement conference. • Reference the events listed under 10/06/22 to see a similar situation related to a scheduled settlement conference. In that instance, it was Mr. Cavanagh that was a no-call/no-show to
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a settlement conference. Later, in Judge Green’s Division on 10/19/22, both Mr. Cavanagh and Judge Green acted as though a settlement conference had taken place. During the hearing on 10/19/22, when I started to speak about the fact that my former attorney and I were the only ones to show up for that conference because Mr. Cavanagh was a no-call/ no-show, Judge Green quickly cut me o ff (see 10/19/21 transcript, pg. 13). He then warned me about how if I brought up what was said in a settlement conference again, it would be contemptuous, but there never was a settlement conference . This was even noted in the letter my former attorney, Susan Jacobson, filed in Judge Green’s Division to document that all parties were on the same page about the state of the case. • I still didn’t have access to the active case file, and wasn’t receiving notifications if some- thing was entered in it- aside from what Mr. Cavanagh’s O ffi ce would email me, but I was unable to view what was being entered in The Court Docket. Therefore, I had no way of knowing if it reflected what was actually happening in the case in real-time. My inabil- ity to access the active case file, among other obstructions to my right to The Due Process of Law, had remained unresolved for over a year at this point. The last time The Parties had a hearing in Judge Green’s Division, before agreeing the case could be reassigned, was on April 19, 2022. During that hearing I told Judge Green I still didn’t have access to the active case file, and wasn’t being notified of entries in The Court’s Docket. Those is- sues with access were reported yet again to The Head of Family Court’s Division, but noth- ing was done and I was not notified when the case was assigned to her division in June 2022. • I appropriately reported those outstanding issues related to the obstruction of my Right to Due Process in motions filled in The Presiding Judge of The St. Louis Judicial Circuit’s Divi- sion, Judge Mary E. Ott. I included audio with certified transcripts, to demonstrate exactly how The Opposing Party and Judge Green were misrepresenting what was filed in the case, or what proceedings had taken place, more than once , to Administrative Divisions within The St. Louis County Judicial Circuit. However, The Presiding Judge of The Judicial Circuit, Judge Mary Ott, concealed what I had reported to her in her judgement (refer- ence events listed under 10/11/22 and 10/18/22). • Refer to when the case was reassigned to Judge Mondonna Ghasedi (Div. 43) without my knowledge, and she transferred it back to Judge Green’s Division. In Judge Ghasedi’s 8/24/22 order, she cited that Mr. Cavanagh filed a motion in her division on 8/23/22 that in- dicated The Parties had outstanding issues to resolve before proceeding with a trial. That was the last motion filed by The Opposing Party at this time, and The Parties had not met with Judge Green since Judge Ghasedi entered her order transferring it back to his division on 8/24/22. • The only reason the case was transferred back to Judge Green’s Division was because The Parties still had outstanding pre-trial issues which were evidenced by Mr. Cavanagh’s mo- tion filed on 08/24/23. This motion suggested The Parties were divorced and The Court had already identified and divided The Property and that I was in contempt of those orders.
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