Chronology of Ojeda Case

Chronology of Case #2 Related to My First Husband’s Post-Separation Domestic Abuse, and Custody Loss 1) 08/17/2016 - The Court granted my uncontested divorce from my first husband, Victor A. Ojeda, which included a Custody Agreement and Parenting Plan for our two sons who were then ages 6 and 9. At that time, Mr. Ojeda and I shared joint legal and physical custody, and he had approximately nine overnight visits a month based upon my work schedule. Mr. Ojeda was ordered to pay $650/month in child support. 2) 02/21/17 - The Parties consented to a Stipulation For Modification of Judgement of Dissolution of Marriage . This included a modification of language in The Parenting Plan to include details regarding how many of Mr. Ojeda’s monthly overnight visits would fall on weekends since they were based upon my work schedule. It also specified what day Mr. Ojeda would have the children each week for a two-hour visit after school, rather than the existing plan which required Mr. Ojeda and I to coordinate that on a weekly basis. In order for Mr. Ojeda to consent to those changes, I agreed to waive the existing judgement requiring Mr. Ojeda to pay monthly child-support. a. Mr. Ojeda’s child support terminated in February 2017 and never resumed. When it was ordered by The Court to resume in April 2018, Mr. Ojeda did not pay it (reference court filings on 06/01/18 and 07/02/18). To present day, Mr. Ojeda has not provided any form of financial support to the minors since February 2017. Missouri Law a ffi rms that a parent cannot waive their child support obligation outside of extraordinary criteria specified by law , but Mr. Ojeda has never been held accountable to that law. 3) 03/30/17 - My attorney filed a Motion for a Temporary Restraining Order (TRO) and Preliminary Injuction Without Notice for the minors related to an incident involving Mr. Ojeda and our oldest son. It was granted, immediately suspending Mr. Ojeda’s custody and visitation with both children. a. The Court further ordered , “Petitioner granted leave to proceed with The Motion to Modify Custody without submitting financial statements and grants her 30 days from the filing of The Motion to Modify to submit her financial statements.” My attorney at this time, Allison Schreiber-Lee, filed a Motion to Modify Custody which corresponded to the TRO and Preliminary Injunction which was granted by the judge assigned to the case, until his later retirement, Judge Douglas Beach. A hearing was scheduled for 04/05/2017, as a TRO requires renewal by The Court every seven days. 4) 04/04/17 - Mr. Ojeda’s attorney at that time, Michael O’Shea, filed Respondent’s Answer to TRO in which he denied the allegations.

5) 04/05/17 - There was hearing regarding the renewal of the 03/30/17 TRO suspending Mr. Ojeda’s custody and visitation with the minors. a. A TRO for a minor from a parent requires renewal by The Court every seven days until it is dismissed or dissolved by other orders of The Court. b. The TRO was renewed and The Court appointed a Guardian Ad Litem (GAL) for the minors (Attorney Je ff Medler). 6) 04/12/17 - The Parties, along with the court-appointed GAL Je ff Medler, submitted a consent judgement to The Court dissolving the oustanding TRO against Mr. Ojeda, which would otherwise require renewal every seven days while the corresponding Modification of Custody proceeded. The judgement called for Mr. Ojeda to resume his custody and visitation with our youngest son only, while his custody and visitation with our older son would remain suspended and per the orders of The Court- Appointed GAL while a Modification of Custody proceeded. 7) 05/03/17 - A settlement conference was held for the ongoing Modification of Custody corresponding to the suspension of Mr. Ojeda’s custody and visitation, in a new court division (Judge Mary Schroeder) following the former judge’s retirement (Judge Beach). An order was entered a ffi rming that our oldest son’s custody and visitation with Mr. Ojeda remained suspended and per the directives of the GAL since 03/30/17. 8) 05/15/17 - My attorney filed a Motion for Psychological Evaluation of Respondent which requested that The Court order a psychological evaluation of Mr. Ojeda (see 05/17/17 for hearing). 9) 05/16/17 - My attorney filed a TRO and Preliminary Injuction with Notice , for my youngest son whose custody and visitation with Mr. Ojeda resumed six weeks prior (see 04/12/17). His older brother’s custody and visitation with Mr. Ojeda remained suspended and pending recommendations of the GAL appointed to resolve Mr. Ojeda’s custody and visitation suspension which began on 03/30/17. The Motion for TRO and Preliminary Injunction filed on my youngest son’s behalf was supported by evidence attested to The Court by the GAL, as well as an a ffi davit filed by the children’s therapist Julie-Walther Scheibel. 10) 05/17/17 - Following a hearing, The Court granted the TRO and Preliminary Injunction with Notice for my younger son. The Court’s Judgement states that the TRO was “granted in part and denied in part”. This was due to the fact that if The Court granted only a TRO for my younger son, it would require a renewal by hearing every seven days. Instead The Court found su ffi cient evidence to suspend Mr. Ojeda’s custody and visitation of our younger son, as was already the case for

our older son since 03/30/17, while a Modification of Custody pending the recommendations of the court-appointed GAL proceeded. a. The Motion for Psychological Evaluation of Mr. Ojeda, filed by my attorney on 05/15/17, was also heard. During the hearing, Mr. Ojeda requested that The Court also order a psychological evaluation of me, even though he did not file a formal motion. The Court granted my motion , as well as Mr. Ojeda’s request that both parties undergo a psychological evaluation, as neither my attorney or I objected to Mr. Ojeda’s request. b. Mr. Ojeda’s Attorney at this time, Michael O’Shea, withdrew from the case. Attorney Chelsea Kay Merta entered the case as Mr. Ojeda’s new legal counsel. Note: From this day forward, the most visitation Mr. Ojeda was granted by the GAL, who was appointed to make recommendations about his custody and visitation while it remained suspended during a year-long custody modification, was two weekly visits held in a public place (usually a restaurant). 11) 04/04/18 - The Parties were scheduled for trial for the Motion to Modify Custody which was ordered to resolve the suspension of Mr. Ojeda’s custody of the minors beginning in The Spring of 2017. On the day of trial, The Parties consented to the GAL’s proposed judgement to The Court. a. The 04/04/18 judgement awarded sole legal and physical custody to me. It provided for Mr. Ojeda to have highly limited visitation which was required to take place in a public place, as it had been during the year-long custody modification. The GAL also recommended other orders restricting Mr. Ojeda’s contact with the children at school, extracurricular activities and by phone. b. There were also orders which limited Mr. Ojeda’s ability to have contact with me. I was awarded $35,000 in attorney’s fees and Mr. Ojeda was ordered to pay child support again, which he had not since February 2017. In addition, Mr. Ojeda was ordered to pay $10,000 in outstanding fees to the GAL. 12) 05/03/18 - My attorney filed a Motion To Reopen Evidence and/or Amendment of The Court’s 04/04/18 Judgement . a. The motion alleged that Mr. Ojeda was in contempt of many of The Court’s Orders related to the minors, as well as orders restricting his contact with me, in a period of less than thirty days since a judgement was entered by The Court.

13) 05/04/18 - Mr. Ojeda’s new legal counsel, Attorney Richard Magee, filed a Motion to Vacate The Court’s 04/04/18 Judgement. a. The motion alleged that the judgement was irregular because there were handwritten corrections made to it, that psychologists cannot diagnose people, and that the fees recommended by the GAL, and consented upon by Mr. Ojeda, were “simply staggering”. 14) 06/01/18 - My attorney filed a Motion for Contempt and Motion to Determine Sums Due and Owing , a Proposed Order to Show Cause and a Notice of Hearing for 06/11/18. 15) 06/11/18 - There was a hearing for my Motion for Contempt which all parties were present for, including the GAL (Je ff Medler) who represented the minors when the 04/04/18 modification judgement was entered. a. The Court ordered that the Contempt Hearing, as well as The Parties’ respective Motions to Vacate Judgement filed the first week of May 2018, be continued to a hearing scheduled for 07/02/18. b. The Court ordered that Mr. Ojeda’s limited visitation with the minors, which had previously been unsupervised in public places, be supervised on Sundays from 2-4pm until the next hearing date on 07/02/18. The Court also entered an order stating that if Mr. Ojeda violated any of The Court’s Orders prior to then, he would be sentenced to a week in jail. 16) 07/02/18 - There was a continuance of the 06/11/18 hearing for the Motion for Contempt filed by my attorney against Mr. Ojeda, as well as each party’s outstanding Motion to Vacate and/or Amend Judgement. a. The Parties, along with the former GAL Je ff Medler, whose consent was also required to make an amendment to the judgement entered by The Court on 04/04/18, agreed to amend the judgement. b. The Amended Judgement included an order for Mr. Ojeda to have one weekly supervised visit (supervised by Pam Petit, Harry Glen, or their designee) and no other contact with the minors or their school. In addition, Mr. Ojeda was restricted from contacting me through the court-ordered messaging system (Our Family Wizard). This prevented Mr. Ojeda from engaging in any form of contact with me . It was even specifically ordered that I could block Mr. Ojeda’s number from my phone.

c. I waived the child support that Mr. Ojeda was ordered to begin paying on 04/04/18, because he would only amend the judgement if he was relieved of financial responsibility of the minors and I could not a ff ord protracted litigation. The amended judgement indicates that Mr. Ojeda was relieved of child support because he was paying for the cost of his supervision, however those costs were not equivalent to the amount of child support he was ordered to pay, nor would that meet Missouri’s legal criteria for a parent to waive support. d. I agreed to withdraw my outstanding Motion for Contempt against Mr. Ojeda since the amendment of The Court’s 04/04/18 Judgement provided adequate judicial relief of the outstanding issues. 17) 01/15/19 - I filed an Application for a Full Order of Protection against Mr. Ojeda due to his violations of The Court’s 07/02/18 Judgement which prevented him from any contact with me. 18) 1/19/19- Following a hearing, The Court granted a Full Order or Protection against Mr. Ojeda on my behalf, with evidence adduced of domestic violence related to harassment. 19) 03/07/19 - Mr. Ojeda’s Attorney, Richard Magee, filed an appeal with The Missouri State Court of Appeals (Eastern District) of the Full Order of Protection entered against him on 02/11/19. a. Mr. Ojeda’s appeal was heard by The Missouri State Court of Appeals a year later, and The Lower Court’s judgement ordering a Full Order of Protection was a ffi rmed in an Opinion issued by The Higher Court on 02/11/20. 20) 05/24/19 - Mr. Ojeda filed a Motion to Modify Custody , in the same cause as the Motion to Modify Custody which was ordered to resolve the suspension of his custody and visitation of the minors (see 07/02/18 judgement ). Mr. Ojeda’s motion asserted that the legal cause for a custody modification was his, “perfect compliance record” (see pg. 2, #7 of his motion ). a. In Missouri, modifications of custody judgements that are ordered to resolve the suspension of a parent’s custody brought about by acts constituting the abuse or neglect of a child in Missouri cannot be readjudicated in The Lower Courts. 21) 07/08/19 - The Court dismissed Mr. Ojeda’s Motion to Modify Custody. 22) 08/29/19 - Mr. Ojeda filed a Chapter 13 Bankruptcy Application in which he lied and claimed to pay over $1,000 in child support each month. He misrepresented that

the fees he consented to pay to me in July 2018 in accordance with The GAL’s recommendations to The Court, were dischargeable when they were not. This forced me to retain a collections attorney, Jimmy Fendelman, to dispute Mr. Ojeda’s attempt to dodge the nearly $40,000 he owed me in court-ordered fees in Federal Bankruptcy Court. 23) 02/05/2020 - Mr. Ojeda’s outstanding Appeal of the Full Order of Protection ordered by The Lower Court on 02/11/19 was heard by The Missouri Eastern District Court of Appeals. 24) 02/11/2020 - The Missouri Eastern District Court of Appeals entered an Opinion a ffi rming The Lower Court’s judgement of a Full Order of Protection against Mr. Ojeda. 25) 05/12/2020 - My attorney, Allison Schreiber-Lee, filed a Motion for Contempt and a Proposed Order to Show Cause against Mr. Ojeda related to a multitude of his violations of The Court’s 07/02/18 judgement and 02/11/19 Full Order of Protection . 26) 05/26/2020 - The Court issued an order to Show Cause in response to my Motion for Contempt against Mr. Ojeda. 27) 10/02/2020 - While the Motion for Contempt I filed against Mr. Ojeda was pending adjudication, Mr. Ojeda’s newest attorney, Chris Karlen, filed a Motion to Modify Custody . a. Mr. Ojeda’s attorney filed the motion despite the fact that the custody judgement which was entered on 04/04/2018 , and amended on 07/02/2018 , can’t be readjudicated in The Lower Court . This is because it serves as the resolution to the suspension of Mr. Ojeda’s custody ordered to resolve two separate TRO’s first granted for the minors on 03/30/17 and 05/17/17. b. Regardless, Attorney Chris Karlen’s Motion to Modify asserted a multitude of bizarre and fraudulent claims which directly contradicted the material facts of the case history indicated by The Court’s Record itself, which became a pattern of Mr. Ojeda’s attempts to motion litigation following The Court’s 2018 Custody Judgement , which The Parties consented to . 28) 10/30/2020 - My attorney filed a memorandum confirming to The Court that our exhibits related to the outstanding Contempt Motion against Mr. Ojeda were shared with his attorney . 29) 11/05/2020 - The Court entered a Consent Judgement with Findings of Fact of Mr. Ojeda’s Contempt.

30) 11/06/2020 - The Court entered that Mr. Ojeda’s Motion to Modify was “dismissed by The Parties” a week after The Court ordered The Parties to exchange exhibits related to the outstanding Motion for Contempt filed by my attorney. Mr. Ojeda admitted to being in contempt of the same orders he was seeking The Court modify on 11/05/2020, and as part of that judgement he was forced to dismiss his Motion to Modify since someone cannot motion The Court to modify orders that they are concurrently in contempt of. 31) 11/24/20 - Mr. Ojeda consented to the renewal of The Full Order of Protection that was first ordered by The Court on 02/11/19 , and the judgement a ffi rmed by The Eastern District of Missouri’s Appellate Court on 02/11/20 . 32) End of December 2020 - The long-time judge assigned to the case since May 2017, Judge Mary Bruntrager Schroeder, retired from her position after reaching the age of mandatory retirement for judges in Missouri. 33) 01/14/21 - Mr. Ojeda’s Chapter 13 Bankruptcy Plan was dismissed for non- payment . His dismissed Chapter 13 Bankruptcy Plan included the $35,000 in outstanding legal fees he was ordered to pay me in the July 2, 2018 judgement, as well as the $10,000 in outstanding fees he owed the former GAL Je ff Medler. 34) 01/21/21 - Mr. Ojeda’s Attorney, Chris Karlen, filed the same Motion to Modify Custody which had been dismissed by their consent, at the same time Mr. Ojeda consented to a judgement finding him in contempt of the same orders he sought to modify. As previously stated, Mr. Karlen’s motion grossly misrepresented the case history. The case was assigned to Judge John Lasater’s Division 38. 35) 03/02/21 - My attorney, Allison Schreiber-Lee, filed a Motion to Dismiss and Motion for Sanctions in response to Mr. Ojeda’s Motion to Modify Custody . 36) 04/02/21 - A hearing was held for my attorney’s Motion to Dismiss and Motion for Sanctions in Judge John Lasater’s Division 38 and the cause was taken under advisement. Links: • Certified transcript of 04/02/21 hearing • Audio with subtitles of 04/02/21 hearing (subtitled with transcript) 37) 04/06/21 - Upon my request, my attorney, Allison Schreiber-Lee, filed a Motion to Withdraw and I became self-represented.

38) 05/05/21 - The collections attorney who represented the former GAL, Je ff Medler, and me in our separate attempts to collect the outstanding fees owed to us by Mr. Ojeda per the July 2018 Amended Judgement, filed documents to start garnishing Mr. Ojeda’s wages . a. Mr. Ojeda paid no child support for the minors since 2017, and owed me $35,000 in attorney’s fees awarded by The Court as part of the 07/02/18 judgement. Since July 2018, Mr. Ojeda continued to incur more legal fees, while dodging payment of the tens of thousands he owed me, by claiming he could not a ff ord to pay attorney’s fees and lying about his liabilities and assets on bankruptcy applications. 39) 05/20/21- Mr. Ojeda’s Attorney filed a Motion to Appoint Karen Warren-Strong As Successor Supervisor after the supervisors named to supervise Mr. Ojeda’s visits, or appoint an alternate in their absence, notified The Parties that they would no longer supervise Mr. Ojeda and refused to appoint an alternate due concerns for the minors. a. Mr. Ojeda’s Attorney, Chris Karlen, misrepresented in the motion that the supervising group was simply no longer available. A Notice of Hearing was filed in Judge Lasater’s Division to hear Mr. Ojeda’s Motion to Appoint Karen Warren-Strong As Successor Supervisor on 07/02/21. 40) 06/03/21 - Mr. Ojeda filed an Exemption from Ganishment claiming that he filed taxes as a Head of Household, despite the fact he paid no child support for the minors since 2017 and did not have custody. 41) 06/10/21 - Attorney Jimmy Fendelman, who represented the former GAL and I in our separate attempts to collect on-the-over $40,000 in fees Mr. Ojeda owed to us combined, filed a notice with The Court requesting Mr. Ojeda’s Exemption from Garnishment be reviewed. a. The Court addressed Mr. Ojeda’s perjured Exemption from Ganishment at the beginning of the 07/02/21 hearing that was already scheduled for Mr. Ojeda’s outstanding Motion to Appoint Karen Warren-Strong As Successor Supervisor . 42) 07/02/21 - The Court heard Attorney Jimmy Feldelman’s objections to Mr. Ojeda’s Exemption From Garnishment prior to The Court hearing Mr. Ojeda’s Motion to Appoint Karen Warren-Strong As Successor Supervisor . Links: • Certfified Transcript of 07/02/21 hearing for Respondent’s Exemption from

Garnishment and Motion to Appoint Karen Warren-Strong As Successor Supervisor • Audio with subtitles of 07/02/21 hearing (subtitled with transcript) a. Mr. Ojeda claimed to have an adult child from a previous marriage living with him, when he did not. The Court denied Mr. Ojeda’s Exemption from Garnishment. Judge Lasater ordered that 100% of Mr. Ojeda’s wages be garnished until the $35,000 in attorney’s fees he owed me were paid back. b. Mr. Ojeda’s Motion to Appoint Karen Warren-Strong As Successor Supervisor was also heard by The Court at this time. I was self-represented during the hearing and made an oral argument that their pleadings failed to state a legal claim. c. The Court took the matter under advisement and ordered that by 07/09/21 I submit my objections to their motion in writing. The Court later granted an extension for my objections to be filed by 07/13/21. 43) 07/13/21 - I filed a Motion Objecting to Appoint Karen Warren-Strong and Motion to Reconsider Dismissal of Respondent’s Motion to Modify Without Further Hearings and/or Relief From Litigation Abuse . 44) 07/18/21 - Mr. Ojeda filed a second Chapter 13 Bankruptcy Applicaton , after his first was dismissed for non-payment, which included the outstanding fees owed to me ($35,000) and the former GAL Je ff Medler ($10,000). 45) 10/15/21 - Judge Lasater informed The Parties that he was recusing from the case on The Court’s own motion. 46) 12/30/21 - Following the appointment and recusal of two other St. Louis County Court Divisions, the case was reassigned to Judge Virginia Lay in Division 16 for hearing and determination of the parties’ outstanding motions, which included: a. Mr. Ojeda’s Motion to Modify Custody b. Mr. Ojeda’s Motion to Appoint Karen Warren-Strong As Successor Supervisor (a motion filed within his Motion to Modify Custody) c. The Motion to Dismiss and Motion for Sanctions filed by my former attorney d. My Motion Objecting to Appoint Karen Warren-Strong and Motion for Dismissal of Respondent’s Motion to Modify Without Further Hearings Relief From Litigation Abuse.

47) 03/16/22 - A hearing was held on-record in Judge Lay’s Division for Mr. Ojeda’s Motion to Appoint Karen Warren-Strong As Successor Supervisor which was a motion within his outstanding Motion to Modify Custody . a. After accepting into evidence an a ffi davit filed by the former supervising group, Judge Lay dismissed Mr. Ojeda’s Motion to Appoint Karen Warren-Strong As Successor Supervisor, and also dismissed Mr. Ojeda’s Motion to Modify Custody. Links: • Certified transcript of the 03/16/22 hearing in Judge Lay’s Division (16) • Judgement dismissing Mr. Ojeda’s motions • Exhibit book filed in Judge Lay’s Division, and referenced during the 3/16/22 hearing, to show how Mr. Ojeda’s Attorney, Chris Karlen, had been misrepresenting the case history since the retirement of Judge Schroeder at the end of December 2020. 48) 04/13/22 - Attorney Roseanne Horan filed a Motion to Substitute Counsel for Mr. Ojeda’s Attorney, Chris Karlen, and filed a Motion to Vacate Judge Lay’s 03/16/22 judgement for Mr. Ojeda. a. Attorney Roseanne Horan’s motion a ffi rmed that as a result of The Court’s Judgement, Mr. Ojeda no longer had contact with the minors . 49) 04/19/22 - Judge Lay dismissed Attorney Roseann Horan’s Motion to Vacate The Court’s 03/16/22 judgement. 50) 06/28/22 - Attorney Roseanne Horan filed a Motion to Modify Custody which suggested that The Court had not held a hearing for Mr. Ojeda’s Motion to Modify Custody and Motion to Appoint Successor Supervisor and entered a judgement on 3/16/22 , and dismissed his attorney’s Motion to Vacate that same judgement on 04/19/22. a. Their Motion to Modify claimed that Mr. Ojeda no longer had supervised visits because I was alienating the children from him and violating The Court’s Orders. This was a direct contradiction to Ms. Horan’s assertions to The Court three months earlier, in the Motion to Vacate she filed on 4/13/22, which was dismissed by The Court on 04/19/22, in which she cited The Court’s Orders and Judgements as the cause that Mr. Ojeda no longer had contact.

51) 08/03/22 - Mr. Ojeda’s Motion to Modify was automatically assigned to Judge Lay’s Division again when it was filed on 06/28/22, but Judge Lay unexpectedly recused herself . a. Just a few months earlier, on 4/19/22, Judge Lay dismissed Mr. Ojeda’s Motion to Vacate the same judgement that he and his attorney were now pretending did not exist. 52) 08/10/22 - Mr. Ojeda’s Motion to Modify was reassigned by The Head of Family Court, Judge Jason D. Dodson, to The Division of Judge Joseph L. Green (36) and the case number changed from “-04” to “-05”. a. Note that Judge Jason Dodson was the same Administrative Judge I had been in contact with since April 2022 regarding Judge Joseph L. Green in Division 36, who was assigned to my divorce matter from Attorney Rick Voytas since July 2021, and it was still an active case.** b. **My last correspondence with Judge Dodson’s Division Clerk, April Moore, regarding the motion I filed in his division related to The Disqualification of Judge Green For Cause in my divorce from my second husband, Attorney Rick Voytas, was on 06/08/22. c. The Administrative Judge who assigned the motion to Judge Green, Judge Jason Dodson, and The Presiding Judge of The St. Louis County Judicial Circuit, Judge Mary Ott., were both aware that I was reporting that Judge Green, and the attorneys involved in my divorce from Attorney Rick Voytas, were involved in criminal misconduct and fraud as of April 2022 (reference the chronology of events in my divorce from Mr. Voytas). d. Judge Green was in receipt of evidence related to the claims made in Mr. Ojeda’s 06/28/22 Motion to Modify Custody, prior to his assignment to it , as the result of his pre-existing assignment to my divorce from my second husband, Attorney Rick Voytas. Mr. Ojeda’s ongoing harassment of my sons and I, served as evidence for The Court to grant a motion for Mr. Voytas and I to file our divorce petitions under our initials. The fact that I am a sole custodian and financial provider of two children by Mr. Ojeda, who is our known domestic abuser to The Court, was also addressed during hearings in Judge Green’s Division in my divorce from Mr. Voytas. 53) 08/11/22 - In response to the assignment of Mr. Ojeda’s Motion to Modify to Judge Green’s Division, I emailed Mr. Ojeda’s Attorney, Roseanne Horan, to notify her that there was a conflict with the assignment.

54) 09/12/22 - I filed a second Motion to Disqualify Judge Green For Cause in my divorce from my second husband, Attorney Rick Voytas, which was still active at this time. a. The Head of Family Court, Judge Dodson, refused to hear the first motion I filed to Disqualify Judge Green For Cause when Judge Ott referred my motion to his division in April 2022 (reference chronology my divorce proceeding from Mr. Voytas). Instead Judge Dodson assigned Judge Green to a second lawsuit filed against me, only this one by Mr. Ojeda, when I was already formally reporting Judge Green’s criminal misconduct in my divorce from Mr. Voytas. 55) 10/05/22 - Judge Green did not recuse himself once appointed to Mr. Ojeda’s Motion to Modify. I filed a motion in Judge Green’s Division to serve as notice in the case record, that I previously filed two Motions to Disqualify Judge Green For Cause in another matter to which he was still actively assigned, and those motions had not been ruled on. The fact there were two open lawsuits filed by both of my former husbands, during the same period of time, was already unusual, let alone that one was directed to the same judge that was already presiding over the other. a. Judge Green’s Division did not enter this motion in The Case Record, despite it’s filing being confirmed by The Domestic Relations Department. This was one of the tactics used by Judge Green to intentionally obstruct my Due Process Rights, while covering up that he was, via the fraudulent case record he was creating. This same tactic was cited in my Motion to Disqualify Judge Green for Cause filed in my divorce from Attorney Rick Voytas, which was pending a future hearing in The Division of The Presiding Judge of St. Louis County’s Judicial Circuit, Judge Mary E. Ott. 56) 10/11/22 - There was a hearing held in The Division of The Presiding Judge of St. Louis County’s Judicial Circuit, Judge Mary E. Ott, for my Motion to Disqualify Judge Green for Cause in my divorce from Attorney Rick Voytas, to which Judge Green was already assigned to prior to being assigned to Mr. Ojeda’s motion. a. It was the second Motion to Disqualify Judge Green for Cause that I filed in my divorce from Mr. Voytas because the first one I filed was denied a hearing or formal response from Judge Ott, or The Head of Family Court, Judge Jason Dodson (see 04/15/22 of chronology of my divorce from Mr. Voytas). Links: • Certified transcript of hearing held on 10/11/22 in Judge Ott’s Division. • Audio which corresponds to the transcript

b. 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 a second matter, filed by Mr. Ojeda in June 2022 and assigned to Judge Green in August 2024. c. 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 regarding his Disqualification for Cause in my divorce from Mr. Voytas on 10/11/22. 57) 10/12/22 - Mr. Ojeda’s Attorney, Roseanne Horan and Judge Green proceeded with a first case conference related to the Motion to Modify Custody that Ms. Horan filed in June 2022, that was assigned to Judge Green’s Division by the same Administrative Judge, Judge Dodson, who was aware of the oustanding issues related to Judge Green’s appointment to another open case. a. Ms. Horan and Judge Green were aware they scheduled this initial case conference to take place less than 24 hours after The Presiding Judge of The Courts, Judge Ott, was holding a hearing regarding Judge Green’s disqualification in my divorce from Rick Voytas, to which he was already assigned. b. Judge Green and Ms. Horan knew I was not available for a conference on this day in advance, and Judge Green’s Division would not acknowledge the formal motion I filed in his division which alerted The Court to the conflicts, despite it being confirmed filed with The Court by The Domestic Relations Department. 58) 10/13/22 - I emailed Judge Ott’s Clerk, Carol Turner, to let her know that I had not received a judgement from Judge Ott’s hearing regarding Judge Green’s Disqualification For Cause in my divorce from my second husband. I told her that I was concerned because Judge Green was proceeding in a second case. 59) 10/18/22 - I received a judgement via mail from Jude Ott’s Division, for my Motion to Disqualify Judge Green For Cause in my divorce from Attorney Rick Voytas. I did not know a judgement had been entered until this time, despite contacting Judge Ott’s Division on 10-13-22 . a. 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 argument, when compared to what she states it was in her judgement . The discrepancy is evident in reviewing the certified hearing transcript and exhibits filed, juxtaposed to the judgement

entered.

b. 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 Judge Ott’s judgement, no one would even know that I accused Judge Green of obstructing my Fourteenth Amendment Rights and covering it up with a fraudulent case record. c. 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, Judge Ott described a set of materially fraudulent facts that would allow her to apply the law in a way that would result in the outcome that her colleague, and the attorneys involved in the crime, needed. (see RSMo570.095 and 18 U.S.C., Section 241 ). d. In response, I later filed an Emergency Motion for Relief From Judgement or Order In Accordance With MO Procedural Rule 74.06 , along with the corresponding exhibits , in Judge Ott’s Division on 01/13/22. 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. 60) 12/22/22 - Mr. Ojeda’s Attorney, Roseanne Horan filed a notice for a telephone settlement conference to be held with Judge Green’s Division for Mr. Ojeda’s outstanding Motion to Modify Custody on 01/03/23 at 9am. 61) 01/03/23 - In accordance with the instructions included with Attorney Roseanne Horan’s settlement conference notice , I waited for Ms. Horan to initiate a call. When Ms. Horan had not initiated a call as of 08:59am, per The Division’s order, I called the listed phone line. I called at 8:59am, 9:01am, 9:03am, 9:05am, 9:09am, 9:14am, and 9:35am per my mobile phone record . The Division’s phone line just continued to ring with no answer each time. a. Judge Green’s Division’s website page stated at this time , “Division 36 preference is to conduct Status Conferences (previously referred to as “Settlement Conferences”) by phone. Be sure to review Division 36 Phone Conference Order which can be found on this webpage. If the attorneys and/or parties prefer an “in person” conference they shall designate such preference on written notice.”. b. At 4:24pm, Ms. Horan emailed me to let me know what “orders” had been entered at the “settlement conference” that day, even though there was not

one held at the scheduled time included in the court notice filed by Ms. Horan on 12/22/22 . At 9pm that evening I received an email notification from The Court’s online case tracker which indicated that Ms. Horan and Judge Green “corrected” her notice for a phone settlement conference at 9am on 01/03/23, to instead reflect that a hearing was held. c. The Court’s online case tracker indicated that Ms. Horan’s notice for a phone settlement conference was altered on 01/03/23 at 12:30pm, which was over three hours AFTER the time that the 9am phone settlement conference was noticed to be held on 01/03/23. d. I was not provided notice of a hearing, nor could I have when Attorney Roseanne Horan’s Notice was altered three hours after the time of the phone conference, which did not occur. These changes were made on the same day that the phone conference was previously noticed for, and after the time that the original notice stated, so there could not have been notice given since the notice itself was altered AFTER THE TIME OF THE EVENT. e. A hearing could not have been held because the opposing party (me) did not receive notice of it. There was not a hearing held on 01/03/23 if both parties didn’t receive notice so that they could respond, be present and engage in due process of law. The only thing that could have taken place on 01/03/23 was a phone settlement conference at 9am, as was previously noticed by Attorney Roseanne Horan, but it did not (see 01/03/23). f. Judge Green and the attorneys involved in the two cases assigned to him, were intentionally obstructing my Fourteenth Amendment Rights, and covering up the evidence of their crime, through the fraudulent court records they were creating. g. This same pattern of criminal misconduct and fraud was already thoroughly documented in my divorce from Attorney Rick Voytas (full chronology of that case found here ). However The Presiding Judge of St. Louis County Courts, Judge Mary Ott, engaged in the same type of fraud as Judge Green was committing, when she entered her judgement for his Disqualification For Cause in my divorce from Attorney Rick Voytas. h. Judge Green’s 01/03/23 orders stated that he was “reminding” The Parties that there was an order for Karen Warren-Strong to be holding supervised visits with Mr. Ojeda, when there was not. In his “reminder order” Judge Green preemptively threatened that if I did not comply with it, I could face sanctions by The Court. i. In addition, Judge Green appointed Attorney Cynthia Albin to serve as a Guardian ad Litem (GAL) but she recused herself two weeks later. Ms. Albin

represented me in my divorce from Attorney Rick Voytas, until she withdrew because she refused to report the criminal misconduct and fraud being committed by Judge Green and the attorneys involved in the case. j. The last two judgements entered in response to motions filed by Mr. Ojeda in St. Louis County Family Court, included a 3/16/22 judgement by Judge Virginia Lay denying Mr. Ojeda’s Motion to Appoint Karen Warren-Strong as Successor Supervisor , which cited evidence adduced during a hearing. That judgement also dismissed Mr. Ojeda’s pending Motion to Modify at that time. Later, on 04/13/22, Mr. Ojeda’s Attorney Roseanne Horan filed a Motion to Vacate Judge Lay’s 3/16/22 Judgement, and in that motion she stated that the reason Mr. Ojeda no longer had contact with the minors was due to Judge Lay’s Judgement entered on 3/16/22, which was why she was motioning The Court that it be “set aside”. Judge Lay dismissed Ms. Horan’s Motion to Vacate her judgement on 04/19/22. k. There is no circumstance in which Attorney Roseanne Horan could file a Motion to Modify Custody based on the claim that I was the reason that Mr. Ojeda was no longer having supervised visits and that The Court had not held a hearing regarding why the supervising group named to provide supervised visits to Mr. Ojeda, or appoint an alternate in their absence, was refusing to. Ms. Horan’s Motion to Vacate , and subsequent dismissal by Judge Lay on 04/19/22, serves as her attestation to The Court that the cause her client no longer had contact with the minors was because The Court denied his motion for a replacement . l. Judge Green and Attorney Roseanne Horan were misrepresenting the past legal proceedings and judgements, in order to create the appearance there was a legal cause for The Court to modify custody based on on something I had done to my sons who I have been the sole legal/physical custodian of, and sole financial provider for, since 2017. m. The fraudulent court record they were creating served to undermine my credibility in a public fashion, since I was already reporting Judge Green and a group of other St. Louis County Legal Professionals of committing a crime stemming from my divorce from Attorney Rick Voytas. 62) 01/10/23 - I filed an Emergency Motions For Relief From Judgement or Order and Disqualification of Judge Green for Cause in the case involving Mr. Ojeda. It was filed in The Division of The Presiding Judge of The Judicial Circuit, Judge Mary Ott. I also filed a Notice of Hearing in Judge Ott’s Division for 02/03/23.

63) Also on 01/10/23 - Attorney Roseanne Horan filed a Contempt Motion and a Motion For Replacement of Guardian ad Litem (GAL) , which were set for a hearing in Judge Green’s Division on 05/23/23. a. The Motion For Replacement of Guardian ad Litem claimed that on 01/03/23 The Court determined that a Guardian ad Litem needed to be appointed. b. There was not a legal process that could have resulted in that determination on 01/03/23 because Attorney Roseanne Horan filed a notice on 12/22/22 for a phone settlement conference to be held at 9am on 01/03/23, and it was not (see summary of events on 01/03/23 )*. * Note that a similar tactic was also used by Judge Green and the attorneys involved in my divorce from St. Louis County Attorney Rick Voytas , to intentionally obstruct my Fourteenth Amendment Rights, while concealing the evidence that they were, via fraudulent records (see example from my divorce from Rick Voytas ). c. Their Motion For Replacement of Guardian ad Litem stated that the “court- appointed visitation supervisor, Karen Strong, suggests Modupe Oji to serve as Guardian ad Litem”. There was a November 2020 Judgement of Mr. Ojeda’s Contempt with Findings of Fact that indicated Karen Strong was not the court- appointed supervisor. e. There was also a March 2022 Judgement dismissing Mr. Ojeda’s Motion to Appoint Karen Strong as Successor Supervisor following a hearing in Judge Lay’s Division with evidence adduced. f. There was also a Motion to Vacate filed by Mr. Ojeda’s Attorney, Roseanne Horan, in April 2022 motioning Judge Lay to set her March 2022 Judgement aside because Mr. Ojeda no longer had contact with the minors (as of May 2021). Judge Lay dismissed that Motion to Vacate. g. Judge Green could not enter a “reminder order” stating that Karen Strong was appointed by The Court to hold supervised visits with Mr. Ojeda, when that order is precisely opposite of what The Court’s Record reflects is true. Judge Green needed to create a fraudulent legal cause to give the appearance that he had the authority to enter legal orders and judgements that would modify existing ones which prevented my sons and I from being subject to Mr. Ojeda’s abuse. e. Attorney Roseanne Horan also filed a Motion for Contempt in which she a ffi rmed that there was a hearing held on 01/03/23 and orders entered, when there could not have been a hearing held when the only notice provided to

me by Ms. Horan was for a 9am phone conference that was never held. Ms. Horan’s Contempt Motion also cited my absence from the 10/12/22 settlement conference she scheduled when she and Judge Green refused to recognize the motion I filed on 10/05/22 , notifying them of the conflict with his case appointment as well as the fact that I was unavailable on 10/12/22. 64) 02/03/23- There was a hearing in Judge Ott’s Division for my Emergency Motion For Relief From Judgement or Order and Disqualification of Judge Green for Cause related to Judge Green’s appointment to Mr. Ojeda’s motion, when he was already appointed to my divorce from my second husband, Attorney Rick Voytas, and being reported by me for criminal misconduct. a. Following the hearing, Judge Ott took the matter “under advisement” and a judgement was not entered at that time. Links: • certified transcript of the hearing in Judge Ott’s Division on 02/03/23 • audio that corresponds with transcript 65) 02/22/23 - There was a hearing scheduled in Judge Ott’s Division for the Emergency Motion for Relief From Judgement or Order In Accordance With MO Procedural Rule 74.06 I filed in my divorce from Attorney Rick Voytas in response to Judge Ott’s 10/11/22 judgement . Links: • Transcript 02/22/23 -reference highlighted lines of transcript on pages: 5, 8-9,10-13,17,19-22 • Audio that correlates with transcript • On pages 19-22 of the transcript , I reference an a ffi davit that was filed in Judge Ott’s Division on 01/02/23 by a therapist and that document can be reviewed here . a. At the time the hearing was supposed to take place, Judge Ott said she would not be holding a hearing on the merits of my motion at that time because she needed to determine if she was “procedurally postured” to make a ruling on it (see pages 17 and 19 of 02/22/23 transcript ). b. Judge Ott referenced the outstanding judgement she needed to make following the 02/03/23 hearing which she held related to Judge Green’s Disqualification

for Cause in the additional case to which he was assigned, involving Mr. Ojeda and Attorney Roseanne Horan. Judge Ott suggested her ruling on that motion was interlocked with Judge Green’s appointment to my divorce from Attorney Rick Voytas as well. 66) 4/18/23 - Judge Ott entered a judgement for my Emergency Motion for Relief From Judgement or Order In Accordance With MO Procedural Rule 74.06 that was related to Judge Green’s Disqualification for Cause in my divorce from Attorney Rick Voytas. When The Parties met for a 02/22/23 hearing in Judge Ott’s Division for that motion, Judge Ott said she would not hear the merits of my motion at that time because she needed to determine whether she was “procedurally postured” to rule on it. a. In her judgement , Judge Ott misrepresented that a hearing was held on 02/22/23 and she wrote a narrative that can be identified as fraudulent when juxtaposed to the transcript and audio from her division, and the content of the motion filed. She didn’t even reference the correct motion that her judgement was supposed to be related to because it was a Emergency Motion for Relief From Judgement or Order In Accordance With MO Procedural Rule 74.06 . Judge Ott engaged in the same method of fraud in order to obstruct of my Fourteenth Amendment Rights while concurrently covering up the evidence with fraudulent court records, as her colleague who I was reporting to her. b. Judge Ott made it appear that the circumstances existed to apply procedural rules and case law that were unrelated to what actually took place on-record in her division, so that she could produce the judgement that the the legal professionals committing fraud in my divorce from Attorney Rick Voytas needed her to. c. There is no indication in Judge Ott’s 10/11/22 judgement or 04/18/22 judgement, that I was reporting the obstruction of my Due Process Rights or the creation of fraudulent court records by Judge Green. 67) 04/28/23 - Judge Ott entered a judgement for my Emergency Motions For Relief From Judgement or Order and Disqualification of Judge Green for Cause which was related to Judge Green’s appointment to the matter involving Mr. Ojeda and Attorney Roseanne Horan, which was heard in Judge Ott's Division on 02/03/23. a. Judge Ott’s 04/28/23 judgement was fraudulent in the exact same way her other two judgements entered related to Judge Green’s Disqualification for Cause were in my divorce from Attorney Rick Voytas. She lied about what was reported to her , the evidence filed with The Court, and what had taken place

during the hearing so that if her judgement was juxtaposed to the motion that was heard, and the transcript of the 02/03/23 hearing , it would be evident that the narrative in her judgement was fraudulent. 68) 05/23/23 - There was a hearing scheduled in Judge Green’s Division related to Mr. Ojeda’s Motion to Modify Custody for the Motion For Replacement of Guardian ad Litem filed by Attorney Roseanne Horan on 01/10/23. a. This was the first time that both parties were present in Judge Green’s Division for a meeting of any kind, let alone a hearing, since Mr. Ojeda’s Motion to Modify was assigned to his division in August 2022. The two other dates in the case record being created by Judge Green and Attorney Roseanne Horan, that were made to fraudulently appear as though the litigation was advancing forward according to due process of law, were 10/12/22 and 01/03/22. Links: • Certfied Transcript of 05/23/23 • Audio of hearing that corresponds to transcript b. When referencing the 05/23/23 “hearing”, it does not mean a valid hearing took place, because it could not have because Ms. Horan’s motions for Mr. Ojeda were now referencing the fraudulent case record that she and Judge Green were creating since the time of his assignment. Ms. Horan couldn’t cite orders entered at a 01/03/23 hearing in Judge Green’s Division as evidence, when there was not a hearing that day because there was not a notice for one provided to me. c. Judge Green asked me on 05/23/23 if I was prepared for a hearing and I told him that I could not have been, and that Attorney Roseanne Horan was aware of that. I informed Judge Green that at the last hearing held in Judge Ott’s Division regarding a Motion to Disqualify him for cause, held on 02/03/23, Ms. Horan admitted that she and Judge Green had proceeded on Mr. Ojeda’s Motion knowing that I could not participate, but denied anything “substantive” had occurred ( pg 5-13 of 02/03/23 transcript ). d. I stated that the motions I filed in Judge Ott’s Division for his disqualification cited the obstruction of my Due Process Rights in his division, which began with his appointment to my divorce from Attorney Rick Voytas. I confirmed that I did not have a Continuance Motion recognized in Judge Green’s Division for the purposes of scheduling.

e. I indicated that I could not proceed forward based on a fraudulent representation of The Court’s previous orders and judgements because it posed harm to the minors since the existence of the judgement being denied, was one that says it was entered due to concerns related to their interests. f. Judge Green denied that he and Attorney Roseanne Horan were misrepresenting The Court’s Record and accused me of misrepresenting it instead. When I asked him if he could specifically cite in what way I had misrepresented it so that I could understand, he would not. g. Judge Green asked a member of his sta ff to find out if I needed an escort, when in my divorce from Attorney Rick Voytas, Judge Green was already using court security as a means of intimidation (see example from my divorce from Mr. Voytas in Judge Green’s Division on 01/17/23). h. Judge Green said he was going to appoint Attorney Modupe Oji, who Ms. Horan and Mr. Ojeda had requested to serve as a GAL. There had not been legal proceedings, or meetings between The Parties of any kind, since Mr. Ojeda’s Motion to Modify was filed in June 2022. Therefore a cause could not be established to appoint one, particularly when the material facts of the record were being disputed. i. I called The Court’s attention to the fact that Mr. Ojeda had $30,000 in outstanding attorney’s fees owed from The Court’s 2018 Judgement. I had been prevented from more aggressively attempting to collect these outstanding fees because he had a Chapter 13 Bankruptcy Application approved based on his inability to pay attorney’s fees in the same matter he was incurring attorney’s fees (see the 07/08/21 order to garnish Mr. Ojeda’s wages which he immediately dodged with a 07/18/21 bankruptcy application that was perjured). j. Judge Green and Attorney Roseanne Horan a ffi rmed their intention to push forward. However, it was unclear how they were moving forward when they had no contact with my teenage sons, or access to records related to them, since The Court’s July 2018 Judgement restricted Mr. Ojeda’s access to their school records and information related to activities of their daily lives. There was no further direct communication between Attorney Roseanne Horan and I, or The Court and I, regarding Mr. Ojeda’s Motion to Modify Custody from this point forward. Judge Green and Attorney Roseanne Horan’s intention was to proceed forward based on fraud, in order to deprive me, and the sons for whom I am the sole legal and physical custodian, of our Fourteenth Amendment Rights while

concealing that they were with a fraudulent case record. ( 18 U.S.C., Section 241 and RSMo570.095 ) 69) 05/25/23 - Two days after The Parties met in Judge Green’s Division on 05/23/23 in the case involving Mr. Ojeda, there was a hearing scheduled in my divorce from Attorney Rick Voytas in Judge Green’s Division. During the 05/25/23 hearing related to my divorce from Mr. Voytas, Judge Green told me that my sons “would not have a parent” when he threatened to put me in jail when I attempted to state that my access to the case record in that matter was obstructed. a. I knew that I would face the risk of detainment if I continued to a ffi rm reality during hearings held on record in Judge Green’s Division in both cases assigned to him. Judge Green and the attorneys involved in both cases involving my two former spouses, were trying to create chaos around whether certain legal processes had, or had not, taken place, whether I had notice of them, and what prior orders and judgements already existed. b. When I attempted to engage my Due Process Rights, Judge Green and the opposing attorneys, would simply conceal what actually took place with a fraudulent court record of what they needed to take place even though it did not (see example from 05/23/23 in case with Mr. Ojeda and 05/25/23 in the case with Mr. Voytas). c. During this time, Judge Green deprived me of access to my only asset in my divorce from Attorney Rick Voytas, and of the Marital Property Settlement Agreement required in Missouri to provide someone with financial independence post-divorce. Judge Green threatened my sons and I with eviction from the home that Mr. Voytas and I purchased during our marriage, based upon a lie that I signed a consent judgement requesting The Court sell the property in advance of identifying and dividing it in a Marital Property Settlement Agreement. d. The fabrication of facts in both cases was material, and could easily be disproven with evidence from The Court’s Record itself. The perpetrators were relying upon the fact that The Public would never believe such an egregious crime could be committed by judges and attorneys, and that their colleagues wouldn’t report it, particularly when the victims include minors. e. The endless process of being forced to unwind a longer and longer case record, as they pushed forward to make it appear valid litigation was proceeding, became an exercise in my psychological abuse. f. The perpetrators deprived me of my only asset in my divorce from Mr. Voytas, and forced my sons and I out of our home without the Marital Property

Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24

litigantontheloose.com

Made with FlippingBook interactive PDF creator