Please Send This To A Civil Rights Attorney

Memorandum on Judicial and Attorney Misconduct

Re: Judge Susan K. Steinhauer & Attorney Lisa Dean

Prepared by: Carey Ann George

Case: DR 2022-05-1201 & DR-2022-03-0667 (Summit County Domestic Relations Court)

I. Introduction

This memorandum consolidates evidence of misconduct by Judge Susan K. Steinhauer and Attorney Lisa Dean in custody and protection order proceedings, demonstrating collusion, statutory violations, constitutional deprivations, and ethical breaches.

Together, Judge Steinhauer and Attorney Dean orchestrated a process by which a domestic violence victim was stripped of parental rights and her children were placed with the convicted abuser, in clear violation of Ohio law and the United States Constitution.

II. Judicial Misconduct by Judge Susan Steinhauer

A. Violations of Ohio Code of Judicial Conduct

• Canon 1 & 2.2 (Integrity, Impartiality, Fairness): The Judge acted without impartiality, disregarding statutory mandates under R.C. 3109.04 and R.C. 3113.31protecting victims of domestic violence.

• Canon 2.4(B) (Improper Influence): The Judge’s rulings mirrored the pleadings of Lisa Dean, suggesting improper ex parte influence.

• Canon 2.5(A) (Competence): The Judge failed to apply Ohio Revised Code standards for custody modification and protection order enforcement.

B. Substantive Legal Violations

1. Custody to a Convicted Abuser

• Despite R.C. 3109.04(F)(1)(h), which bars custody to a parent convicted of domestic violence, custody was awarded to Adam Zivich, who pled guilty to domestic violence/disorderly conduct and is on probation.

2. Failure to Consider Best Interest Factors

• The Court ignored mandatory R.C. 3109.04(F)(1) factors, including:

• Wishes of the children (no in camera interview conducted).

• Parent’s criminal history and violent conduct.

• Continuity and stability of care (Carey was the primary caregiver for nine years).

3. Disregard for Statutory Protection Orders

• The Judge stripped the children from the statutory protection of R.C. 3113.31(E)(1)(d), which ensures children remain with the victim parent, not the abuser.

4. Constitutional Violations

• Fourteenth Amendment Due Process: Depriving a parent of custody without a finding of unfitness violates Troxel v. Granville, 530 U.S. 57 (2000).

• Ohio Constitution, Art. I, Sec. 16 (Due Course of Law): Custody decisions lacked evidentiary basis and denied procedural fairness.

C. Biased Findings

• Bruises on the child were reframed as “overzealous spanking” while adhesive rashes were elevated to “child abuse” to justify stripping Carey of custody.

• Surveillance evidence from neighbors and Maryellen Zivich was credited, while more than 40 witness letters, police records, and text evidence from Carey were disregarded.

III. Attorney Misconduct by Lisa Dean

A. Violations of Ohio Rules of Professional Conduct

• Rule 3.3(a)(1) (Candor): Dean misrepresented facts, claiming Carey intended to abscond with the children to Florida and framing adhesive rashes as abuse.

• Rule 3.4(b) (Fairness): Dean presented hearsay surveillance evidence via Gary Nawrocki and Maryellen Zivich to circumvent protective orders.

• Rule 4.4(a) (Respect for Rights): Dean weaponized the legal system to harass Carey, the protected victim.

• Rule 8.4(d) (Prejudicial to Justice): Her conduct undermined the integrity of proceedings and enabled custody transfer to a convicted abuser.

B. Collusion with Judge Steinhauer

• Dean filed ex parte motions designed to bypass Magistrate Collins, who had issued lawful protective orders.

• Steinhauer adopted Dean’s framing while ignoring statutory mandates, showing a coordinated effort to strip Carey of rights without due process.

IV. Pattern of Collusion

1. Minimization of Domestic Violence: Judge Steinhauer downplayed Adam Zivich’s conviction and probation while Dean concealed and mischaracterized his violent history.

2. Fabrication of Grounds for Custody Change: Both relied on hearsay surveillance and adhesive rashes while ignoring statutory findings of best interest.

3. Suppression of Evidence: Carey’s extensive documentation—police reports, witness letters, and texts—was disregarded in favor of biased, inadmissible testimony from family and neighbors aligned with Adam.

4. Improper Ex Parte Process: Dean’s ex parte filings were granted by Steinhauer, circumventing normal judicial process and stripping Carey of her parental rights.

V. Legal and Constitutional Authorities Violated

• R.C. 3109.04(E), (F)(1): No change of circumstances or best interest findings justified modifying custody.

• R.C. 3113.31(E): Protective order was undermined, contrary to statute.

• Troxel v. Granville (2000); In re Murray, 52 Ohio St.3d 155 (1990): Custody stripped without finding Carey unfit violated fundamental liberty rights.

• Canon 1.2, 2.2, 2.4(B), 2.5(A): Judicial canons requiring fairness, impartiality, and competence were disregarded.

• Rules of Professional Conduct 3.3, 3.4, 4.4, 8.4: Attorney misconduct in misleading the court and abusing the process.

VI. Requested Action

This memorandum is submitted to both:

• Ohio Office of Disciplinary Counsel (re: Judge Susan Steinhauer)

• Cleveland Metropolitan Bar Association, Certified Grievance Committee (re: Attorney Lisa Dean)

I respectfully request:

1. A full investigation into whether Judge Steinhauer engaged in improper ex parte communications and willful disregard of Ohio law and constitutional protections.

2. An investigation into Lisa Dean’s professional misconduct in misrepresenting evidence, colluding with the Court, and violating the Ohio Rules of Professional Conduct.

3. Sanctions up to and including judicial discipline/removal for Judge Steinhauer and suspension/disbarment for Lisa Dean.

VII. Conclusion

The pattern of bias, statutory violations, and collusion between Judge Susan Steinhauer and Attorney Lisa Dean demonstrates systemic misconduct that deprived me of constitutional protections and unlawfully stripped me of custody. The misconduct undermines public confidence in the fairness of Ohio’s judiciary and bar.

Respectfully submitted,

Carey Ann George

Listed below are the violations by Judge Susan K. Steinhauer and Attorney Lisa Deanthat resulted in my parental rights being stripped for nearly FOUR YEARS now, despite overwhelming contrary law, evidence, and constitutional protections.

1. Ohio Domestic Relations & Custody Law Violations

A. Custody granted to a convicted domestic violence offender

• R.C. 3109.04(F)(1)(h) requires the court to consider whether either parent has been convicted of domestic violence or any criminal offense involving harm to a child.

• R.C. 3109.04(F)(1)(c), (e), (h), (i) list factors weighing against allocating custody to abusive or dangerous parents.

• Case law: Stocker v. Stocker, 2016-Ohio-5433 (9th Dist.) – a parent’s history of domestic violence is a mandatory factor that weighs heavily against allocation of custody.

• Violation: Judge Steinhauer awarded custody to Adam, a convicted abuser on probation, ignoring Carey’s statutory protection.

B. Ignoring the statutory “best interest of the child” test

• R.C. 3109.04(F)(1) requires courts to consider all listed factors before allocating custody.

• Judge Steinhauer failed to:

• Interview the children in camera (R.C. 3109.04(B)(1)).

• Consider Carey’s nine-year history as primary caregiver.

• Consider Adam’s drug/alcohol abuse (R.C. 3109.04(F)(1)(e)).

• Case law: Fisher v. Hasenjager, 116 Ohio St.3d 53 (2007) – custody modifications require substantial changes in circumstance and must serve best interest of child.

• Violation: No change of circumstance was found; yet custody was stripped from Carey.

C. Ignoring protection order law

• R.C. 3113.31(E)(1)(d) allows custody decisions in CPO hearings only to protect children from further abuse.

• Case law: Felton v. Felton, 79 Ohio St.3d 34 (1997) – protection orders exist to protect victims, not punish them.

• Violation: The court handed the children to the abuser, undermining the statutory purpose of the CPO.

2. Constitutional Violations

A. Fourteenth Amendment – Due Process

• Parents have a fundamental liberty interest in the care, custody, and control of their children.

• Troxel v. Granville, 530 U.S. 57 (2000): The state cannot arbitrarily deprive a fit parent of custody.

• In re Murray, 52 Ohio St.3d 155 (1990): Termination of parental rights requires clear and convincing evidence.

• Violation: Carey was stripped of custody without findings of unfitness, abuse, or neglect.

B. Fourteenth Amendment – Equal Protection

• Granting custody to a father convicted of domestic violence, while punishing the protective mother, creates discriminatory application of custody law.

C. First Amendment – Right to Petition

• Carey’s testimony, reports of abuse, and pursuit of protective orders are constitutionally protected petitions for redress.

• Punishing her with loss of custody constitutes retaliation for exercising protected rights.

3. Civil Rights Violations (42 U.S.C. § 1983)

• Denial of due process and equal protection rights under color of law.

• Collusion between Judge Steinhauer and Lisa Dean in suppressing Carey’s protective rights and disregarding statutes constitutes state action depriving constitutional rights.

• Case law: Monroe v. Pape, 365 U.S. 167 (1961) – §1983 remedies apply when officials act unlawfully under color of state law.

4. Judicial Misconduct by Judge Steinhauer

A. Canon 1 & Canon 2 – Ohio Code of Judicial Conduct

• Judges must uphold the independence, integrity, and impartiality of the judiciary.

• By favoring the abusive father and disregarding statutory law, Steinhauer acted with bias and prejudice.

B. Canon 2.4(B) – Improper Influence

• A judge shall not permit external influence or personal bias to affect decision making.

• Collaboration with Lisa Dean to override Magistrate Collins and reframe the record indicates improper influence.

C. Canon 2.5(A) – Competence and Diligence

• Judge must perform duties competently and in accordance with law.

• Her order disregards Ohio Revised Code, case law, and constitutional requirements.

5. Attorney Misconduct by Lisa Dean

A. Ohio Rules of Professional Conduct

• Rule 3.3(a)(1): Candor toward the tribunal – Dean knowingly presented false claims (e.g., Carey intent to abscond, drug/alcohol mischaracterizations).

• Rule 3.4(b): Fairness to opposing party – She unlawfully influenced testimony and evidence, including coaching witnesses (neighbor, Maryellen).

• Rule 4.4(a): Respect for rights of third persons – Dean harassed Carey by weaponizing court process and misrepresenting facts to the judge.

• Rule 8.4(d): Misconduct – Conduct prejudicial to administration of justice, colluding with a judge to deny parental rights.

6. Specific Procedural Due Process Violations

• Failure to provide notice or meaningful opportunity to challenge fabricated surveillance claims.

• Reliance on hearsay from biased witnesses (neighbor, Maryellen).

• Ignoring exculpatory evidence (texts, financials, police records).

• Stripping custody in an ex parte emergency order without findings of immediate danger to children.

7. Collusion Indicators Between Judge Steinhauer & Lisa Dean

• Judge Steinhauer issued rulings that mirrored Lisa Dean’s arguments while disregarding Carey’s counsel’s submissions.

• Custody stripped in contradiction of Magistrate Collins’ protection order, suggesting behind-the-scenes coordination.

• Language in orders echoed Lisa Dean’s pleadings nearly verbatim.

• Failure to weigh Carey’s 40+ witness letters or documentary evidence while relying solely on Dean’s client and biased witnesses.

Summary of Violations

1. Ohio Code Violations – R.C. 3109.04, 3113.31, 3109.051.

2. Constitutional Violations – 14th Amendment due process & equal protection; 1st Amendment retaliation.

3. Civil Rights Violations – 42 U.S.C. §1983 actionable claims.

4. Judicial Misconduct – Bias, improper influence, ignoring statutory mandates.

5. Attorney Misconduct – Lisa Dean violated Rules of Professional Conduct (3.3, 3.4, 4.4, 8.4).

6. Case Law Ignored – Troxel v. Granville; Fisher v. Hasenjager; Felton v. Felton; In re Murray.

This this amounts to a systemic deprivation of my parental rights through collusion, bias, and unlawful disregard of Ohio law and constitutional protections.

📄 Page 2 – Court’s Findings vs. Actual Timeline Evidence

Court’s Finding:

• Husband was described as the primary caregiver of the children.

• Court emphasized that father’s role was central while mother was either absent or disengaged.

• This framing set the stage for custody reversal.

🚨 Contradictions & Evidence

1. Timeline Proof of Mother as Primary Caregiver (2020–2022)

• Daily logs show Carey handling the children’s schedules, meals, school drop-offs, therapies, and medical appointments:

• 2020: Carey enrolled Zachary in preschool after Adam was fired for theft from his father’s company, splitting tuition with her own mother because Adam contributed nothing .

• 2021: Carey managed school pickups, therapies, and medical care while Adam was regularly out drinking and using drugs .

• 2022: Carey continued sole caregiving, including therapy appointments, dentist visits, Montessori tours, and school transfers .

• Adam is recorded as largely absent, often at bars or incapacitated from drug/alcohol abuse (see attached photos and texts).

2. Adam’s Disability & Inability to Parent

• After his fall in Nov 2020, Adam admitted in texts he could not buckle Zachary into a car seat because of his disabled arm .

• He pursued disability claims during this period, acknowledging his own incapacity.

3. Alcoholism & Drug Addiction

• Bank statements and texts show Adam spent $1,200+ in weeks on alcohol, and was regularly out at bars doing cocaine throughout 2021 (confirmed by texts, phone calls, and witness statements).

• Cleaning lady Ashlee Kay corroborated jars of marijuana and drug use in the basement.

• Adam admitted in writing to being a heavy drinker and addict, undermining his ability to care for children.

4. Surveillance, Harassment & Domestic Violence

• Police reports confirm Adam’s DV arrest on Feb 15, 2022 after slashing Carey’s tire, kicking a wine glass into her hand and knee, and being found with a loaded gun in his truck .

• Texts and tech analysis prove Adam surveilled Carey with devices in her purse, car, and home.

• Phone logs show coercive calling patterns (22+ calls in hours; 40 calls on Mar 18, 2022).

✅ Corrected Finding

The evidence shows Carey was the consistent, primary caregiver of the children across 2020–2022. Adam:

• Was fired from employment in 2019, then disabled after his fall in 2020.

• Abused drugs and alcohol heavily throughout 2021.

• Was arrested for DV in Feb 2022 and placed on probation with violence and substance classes.

• Demonstrated harassment and surveillance behaviors inconsistent with safe parenting.

Therefore, the Court’s Page 2 assertion that Adam was the primary caregiver is factually false and contradicted by contemporaneous records, police evidence, and witness corroboration.

Great — let’s break down Page 3 with the same comprehensive structure, integrating the evidence you’ve provided (texts, phone logs, timeline, photos, etc.) to dismantle the Court’s acceptance of Gary Nawrocki’s testimony.

📄 Page 3 – Court’s Findings vs. Actual Evidence

Court’s Finding:

The Court leaned on testimony from Gary Lee Nawrocki, the neighbor across the street, who claimed:

• He is not particularly close with Adam or Maryellen.

• He communicates occasionally with Maryellen (texts Bible verses 1–2 times a week).

• He observed Carey moving out with the children, with luggage in the car.

• He shared surveillance details about vehicles at Carey’s residence with Maryellen.

• He saw activity at the house that prompted him to call the police.

• He witnessed Adam’s DV arrest on Feb 15, 2022.

The Court treated this as corroboration of Adam’s claim that Carey disappeared with the children.

🚨 Contradictions & Evidence

1. Gary’s False Claim of Distance vs. Actual Relationship

• Nawrocki testified he was not particularly close with Adam or Maryellen.

• Contradiction: He texted Maryellen Bible verses twice weekly and provided her with updates about Carey’s comings and goings — this shows an ongoing, surveillance-based relationship, not casual church acquaintanceship.

2. Improper Surveillance (CPO Violation)

• Nawrocki admitted to monitoring Carey’s residence, reporting vehicles he “did not recognize,” and sharing this directly with Maryellen — Adam’s mother.

• This constitutes third-party surveillance during an active protection order (CPO/TPO), violating the prohibition against stalking, harassment, or monitoring.

• Evidence: Carey’s phone and text records show Adam obsessively texted about cars in the driveway and deliveries, corroborating use of neighbors as extensions of his monitoring.

3. False Narrative of ‘Absconding’

• Nawrocki testified that Carey, with luggage and the children, “moved out” and was gone all weekend.

• Truth: Carey took the children to Great Wolf Lodge for Zachary’s birthday — documented by photos, bank statements, and the family timeline. This was a family vacation, not absconding.

• Court erred by allowing Nawrocki’s hearsay impression to outweigh documentary proof.

4. Bias & Coordination with Maryellen

• Nawrocki admitted sending Maryellen a picture of a vehicle and directly updating her about Carey.

• This coordination shows bias and entanglement with Adam’s family, contradicting his claim of being a neutral observer.

5. DV Context

• Nawrocki admitted he witnessed Adam’s Feb 15, 2022 DV arrest.

• This confirms Adam’s violent conduct but was downplayed by the Court, which instead elevated Nawrocki’s speculative surveillance reports over the documented DV incident.

✅ Corrected Finding

Gary Nawrocki’s testimony cannot be treated as credible or impartial because:

• He misrepresented his relationship with Adam’s mother.

• He engaged in surveillance on behalf of Adam/Maryellen, violating the protection order.

• His interpretation of Carey “moving out” was disproven by vacation records.

• His communications with Maryellen demonstrate bias and coordination, undermining neutrality.

The weight of evidence (vacation proof, police reports, texts, financial records, and phone logs) establishes that Carey was exercising her role as the primary caregiver, not absconding. Nawrocki’s testimony instead illustrates Adam’s pattern of coercive control and extended surveillance through third parties.

📄 Page 4 – Court’s Findings vs. Actual Evidence

Court’s Finding (based on Nawrocki + Officer Lucore):

• Nawrocki testified he saw Adam arrested and knew Adam did not return to the residence.

• Nawrocki reported the grass was “super high,” suggesting Carey had abandoned the home.

• Officer Lucore testified he responded to Carey’s request for an escort on May 7, 2022, so she could safely gather belongings.

• Adam separately went to the police station expressing “concern for the children” and claimed Carey “took the children.”

• Lucore said he reassured Adam that the children were safe with Carey, but Adam was unsatisfied and claimed Carey “absconded.”

• Adam later requested an Amber Alert and asked police to contact Carey’s mother, stating he feared the children were in Florida.

• The Court notes these “concerns” predated Adam being served with the Ex Parte CPO.

🚨 Contradictions & Evidence

1. Grass Height = False Evidence of Abandonment

• Nawrocki testified the grass was “super high.”

• Reality: Text records show Carey contacted multiple landscapers, who confirmed they were backed up. This is not evidence of abandonment — it reflects normal scheduling delays.

• Judicial Error: Court improperly elevated aesthetic lawn condition to suggest Carey was no longer residing there.

2. Escort Request = Safety, Not Absconding

• Officer Lucore confirmed Carey requested an escort for belongings on May 7, 2022.

• This proves Carey was taking precautionary legal steps due to fear of Adam (backed by texts, CPO filing, and tech investigation showing surveillance).

• Judicial Error: Court twisted a victim’s protective action into alleged proof of instability.

3. Adam’s Manufactured Fear → Amber Alert Request

• Adam asked for an Amber Alert, alleging he did not know where the children were.

• Reality: On May 9, 2022, Adam was at his attorney’s office (Lisa Dean, Sarah Heid, Sonya Ward) when he was informed of the CPO. He knew Carey had lawful custody under a court order.

• Phone records show Adam (and his parents) were contacting neighbors, investigators, and Carey’s family in violation of the CPO.

• Judicial Error: Court treated Adam’s manipulative Amber Alert request as good faith concern, rather than recognizing it as harassment and legal abuse.

4. Violation of CPO through Third-Party Surveillance

• Evidence: Nawrocki testified he repeatedly reported vehicles, activity, and even grass height to Maryellen.

• Combined with Adam’s obsessive texts about cars in Carey’s driveway, this shows a pattern of proxy stalking.

• Judicial Error: Court ignored this and accepted Nawrocki’s “concerned neighbor” narrative.

5. Proof Children Were Not in Florida

• Carey’s timeline, bank statements, and photos confirm she took her sons to Great Wolf Lodge for Zachary’s birthday — not out of state.

• Officer Lucore testified no contact could be made with Carey’s mother (irrelevant, since Carey was not in Florida and had lawful custody).

• Judicial Error: Court accepted Adam’s “fear of Florida” without any corroborating evidence, despite his history of using Florida as a manipulation tactic.

✅ Corrected Finding

• Carey did not abscond. She lawfully maintained custody under the May 9, 2022 CPO.

• Escort request was a protective measure, not abandonment.

• Adam’s Amber Alert request was an intentional misuse of law enforcement to harass and discredit Carey.

• Nawrocki’s testimony about grass, vehicles, and activity was biased surveillance communicated through Maryellen, violating the CPO.

• Independent evidence (timeline, receipts, vacation records, texts) prove Carey was caring for the children normally and never removed them from Ohio unlawfully.

⚖️ Conclusion:

Page 4 highlights a crucial judicial error — the Court elevated Adam’s false narrative of “fear” (unsupported by facts) and Nawrocki’s surveillance gossip over Carey’s lawful custody, documentary evidence, and police-confirmed safety. This mischaracterization laid the foundation for stripping Carey of her parental rights under false pretenses.

📄 Page 5 – Court’s Findings vs. Actual Evidence

Court’s Summary (Christopher Lindley, Goddard School):

• Lindley testified that Carey notified the school on May 5, 2022 that only she would be allowed to pick up Zachary going forward.

• Lindley observed that Carey usually dropped Zachary off, and Adam sometimes picked him up.

• Lindley’s testimony was presented as consistent with Adam’s claim that he was actively involved in pick-ups and school contact.

• The Court cites this as part of Adam’s pattern of being a regular caregiver.

🚨 Contradictions & Evidence

1. Who Actually Did Pick-Ups & Drop-Offs

• Lindley’s testimony is contradicted by Alicia Warrington, who was present more frequently at Goddard and testified that Carey was the primary parent handling both drop-offs and pick-ups.

• Adam only stepped in occasionally, usually when Carey was unavailable.

2. Adam’s Credibility Undermined by Lifestyle Evidence

• Texts, call logs, and bank records show Adam was frequently at bars, out drinking, and using drugs during 2021 and early 2022.

• Example evidence uploaded:

• Adam admitting to being a “heavily drinking motherfucker” and using coke regularly while he describes Carey as a “lightweight”.

• Bank withdrawals of over $1,200 in a few weeks spent on alcohol.

• Multiple late-night calls consistent with bar activity.

• This contradicts any suggestion Adam was consistently handling daily child duties such as school pick-ups.

3. Proof of Carey’s Consistency as Primary Parent

• Carey’s 2020–2022 timeline shows she managed Zachary’s transition from Montessori → Goddard, handled communication with schools, paid invoices, and was always the one in contact about Zachary’s care.

• Adam’s only communication with Goddard in 2021–2022 was related to invoice payments — not day-to-day caregiving.

4. Notification to Goddard on May 5, 2022

• Carey’s instruction that only she would pick up Zachary on May 5 was directly tied to safety concerns following Adam’s violent behavior and escalating surveillance.

• Evidence: CPO issued May 9, 2022, plus Carey’s call to domestic violence shelter (Mark Frizone) seeking safe housing.

• Judicial Error: Court twisted this protective parental action into an implication that Carey was limiting Adam unfairly.

5. CPO Served at Goddard, Week of May 9, 2022

• Lindley testified that Goddard was served with a copy of Carey’s CPO against Adam.

• This proves that by May 9, the legal system recognized Adam as the threat, not Carey.

• Judicial Error: Court ignored the weight of the CPO when assessing credibility and custody.

✅ Corrected Finding

• Carey was Zachary’s consistent caregiver for school routines.

• Adam’s supposed involvement is minimal and inconsistent, directly undermined by his own texts and bank withdrawals showing heavy alcohol and drug use.

• Carey’s May 5 instruction to Goddard was a reasonable protective measure tied to Adam’s escalating threats and surveillance.

• The CPO served to Goddard confirms Carey’s concerns were validated by law, not paranoia.

⚖️ Conclusion:

Page 5 reflects another judicial misrepresentation — the Court treated Carey’s protective parental choices as hostile, while minimizing Adam’s substance abuse, surveillance, and absence from daily parenting. Testimony from Lindley (who saw less of the daily reality than Warrington) was cherry-picked to build Adam’s “caregiver” image, ignoring stronger contradictory testimony and documentary evidence.

📄 Page 6 – Carey’s Evidence vs. Court’s Findings

Court’s Summary (Shannon Larson – 3rd Grade Teacher, St. Barnabas):

• Ms. Larson testified that generally Husband or Paternal Grandmother picked Isaiah up from school and she had never seen Carey pick him up until May 5, 2022.

• She stated she is not present for morning drop-off, so she could not confirm who dropped Isaiah off in the mornings.

• Isaiah allegedly told her that Husband or Paternal Grandmother helped with homework.

• Husband was described as the school’s primary contact, though Ms. Larson acknowledged she had received some emails from Carey.

• Ms. Larson testified the last time she saw Isaiah was May 6, 2022.

• On May 9, 2022, the office received a phone call, and Isaiah was marked excused.

• On May 10, 2022, he was marked unexcused.

• On May 11, 2022, Ms. Larson testified she was informed by the office that Isaiah would not be returning.

• She also testified that Carey picked Isaiah up early on May 5 (~12:15 pm) and May 6 (~20–30 minutes early).

• Husband allegedly came at dismissal both days (2:45 pm) and was “surprised” Isaiah was not there.

• Larson further testified that Husband emailed her regarding her subpoena, and she contacted Husband’s attorney to confirm details.

🚨 Contradictions & Errors

1. False Narrative of Husband as Primary Pick-Up Parent

• Larson testified that she had never seen Carey pick Isaiah up until May 5.

• However, she admitted she is not present for morning drop-off, which was the routine Carey was primarily responsible for.

And Isaiah often took the bus yo grandmas after school.

• Carey transported Isaiah to school almost daily, except on occasions when Isaiah stayed overnight with Adam’s mother which was typically every Monday night from age four. Isaiah had to be to school by 8am and Adam typically left home by or before 7am to go to work qt Regency Roofing.

• Larson’s testimony was based only on her limited visibility and does not reflect the reality of caregiving.

2. Attendance Records Misrepresented

• Larson testified Isaiah was excused May 9, unexcused May 10, and withdrawn May 11.

• Carey has a voicemail from Principal Erin Feeney on May 9, 2022, confirming her communication with the school and her request for Isaiah’s homework for the remainder of the school year.

• This proves Isaiah’s absences were properly excused and undermines Larson’s account.

3. Manipulation of Contact Status

• Larson described Husband as the “primary contact,” but also admitted she had received emails directly from Carey.

• This demonstrates that Carey was actively engaged, while Husband only appeared so on paperwork.

4. Early Pickups Mischaracterized

• Carey picked Isaiah up early on May 5 and May 6 due to ongoing DV concerns and safety.

• Husband’s “surprise” when arriving at dismissal was misused as a narrative against Carey, when in reality it showed he was not the daily caregiver and was out of the loop.

5. Improper Subpoena Handling

• Larson admitted she contacted Husband’s attorney directly for guidance about her subpoena.

• This shows improper influence and undermines the neutrality of her testimony.

✅ Corrected Finding

• Carey was the primary parent responsible for Isaiah’s daily transportation, especially morning drop-offs, which Larson could not observe.

• Isaiah’s absences in May were excused, confirmed by the school principal’s voicemail, contradicting Larson’s testimony.

• Husband’s role was inflated through paperwork and occasional appearances, not actual caregiving.

• Larson’s reliance on Adam’s attorney for subpoena clarification demonstrates improper influence and casts doubt on the neutrality of her testimony.

⚖️ Conclusion (Page 6):

The Court relied on limited, incomplete testimony to bolster the false narrative that Husband was the consistent caregiver. In reality, Carey was the parent managing Isaiah’s school routine and communications. The voicemail from the principal proves Carey maintained proper contact with the school and ensured absences were excused. Larson’s testimony was shaped by her lack of observation and direct influence from Husband’s legal team, not by the actual caregiving reality.

Perfect — let’s keep the same structured format and tone as the last one, in third person, highlighting contradictions, missing context, and what Carey’s evidence shows. Here’s the Page 7 breakdown:

📄 Page 7 – Carey’s Evidence vs. Court’s Findings

Court’s Summary (Matt Zamecnik – Track Coach, CYO):

• Mr. Zamecnik testified that he met Husband at the end of February 2022 at a meeting to form a track team.

• He is the head coach for the Catholic Youth Organization (CYO), and Husband volunteered as a coach, serving as his “right-hand man.”

• Isaiah participated in sprinting and long-jump, reportedly excelling and enjoying the sport.

• Zamecnik stated that Isaiah was last seen May 4, 2022, and did not attend practices or meets after that date.

• Practices were on Mondays, Wednesdays, and Fridays, with meets on Sundays. As of the evidentiary hearing, Isaiah had already missed two meets and one upcoming.

• He testified that Wife was not present at practices or meets, whereas Husband was consistently present and heavily involved.

• Zamecnik described Husband’s coaching as “a great example” and said the children liked him.

• When Zamecnik told the team Husband would not be back, parents expressed gratitude and support for Husband’s involvement.

• On cross-examination, Zamecnik admitted he had hoped Husband would take over the program next year since it was his last season as head coach.

• Zamecnik confirmed Husband had not disclosed his criminal record, but that CYO had conducted a background check.

• He was unaware of Husband’s personal issues until May 4, 2022.

🚨 Contradictions & Errors

1. False Portrayal of Long-Term Involvement

• Husband only met Zamecnik in late February 2022, weeks after the DV incident and Carey’s filing of protection orders.

• His coaching role lasted barely two months before Isaiah’s last attendance (May 4, 2022).

• This was presented as evidence of long-term fatherly involvement when in fact it was a short-term, post-DV attempt to bolster credibility.

2. Minimizing Wife’s Absence

• Carey’s lack of attendance at practices was framed as disinterest.

• In reality, Carey was the primary caregiver at home for nearly a decade, while Husband had almost no prior involvement in extracurricular activities until February 2022.

• Carey’s focus during this period was protecting her children under ongoing DV threats, not appearing at practices.

3. Failure to Consider Criminal Record

• Husband did not disclose his domestic violence conviction when volunteering.

• Zamecnik admitted he only became aware of Husband’s personal issues in May 2022 — two months into Husband’s coaching.

• This undermines the credibility of Husband’s role as a safe and positive figure for children.

4. Misuse of Timeline

• Isaiah stopped attending track May 4, just days before the children were withheld under false pretenses.

• The framing suggests Isaiah’s absence was tied to Carey’s actions, but in fact it aligned with ongoing litigation, the CPO, and Adam’s escalating interference.

✅ Corrected Finding

• Husband’s coaching role was brief, beginning only after February 2022, and cannot be used to establish long-term involvement in Isaiah’s life.

• Carey had always been the consistent caregiver and manager of Isaiah’s daily needs — not the short two-month volunteer period used by Husband for appearances.

• Husband failed to disclose his domestic violence conviction, creating serious concerns about his placement in a position of authority over children.

• Isaiah’s withdrawal from track was not due to Carey’s negligence, but rather the unsafe and unstable environment created by Husband’s abuse and control tactics.

⚖️ Conclusion (Page 7):

The Court relied on inflated testimony of a short-term volunteer role to frame Husband as a model parent, ignoring his history of violence, addiction, and prior absence from parenting duties. Carey remained the parent who managed Isaiah’s upbringing for nine years, while Husband’s sudden involvement in track was a transparent posturing effort during litigation.

📄 Page 8 – Carey’s Evidence vs. Court’s Findings

Court’s Summary (Employment, Finances, Residence):

• Husband testified he and Carey were married in El Segundo, CA on January 21, 2012.

• They have two children: Isaiah (DOB 1/24/13) and Zachary (DOB 5/7/17).

• Isaiah previously attended Rushwood Elementary, then transferred to St. Barnabas in September 2021.

• Zachary began attending The Goddard School in Macedonia in September 2021.

• Husband claimed he currently has no consistent income, stating he collected unemployment until the end of 2020.

• He was employed by Regency Roofing (father’s company), but that ended in December 2019.

• Husband worked for his father intermittently from 2005–2011, and again March 2013–December 2019.

• Since 2019, Husband has been unemployed.

• On cross-exam, Husband testified he fell off a roof on 11/14/2020, had multiple surgeries, and recovery is 18–24 months.

• He stated his parents helped financially and that Wife was the primary wage earnerthrough businesses.

• The last time Husband traveled for work was April 2019.

• He testified he recently began working again on April 27, 2022, self-employed in roofing and construction.

• The marital residence (1445 Roman Dr., Sagamore Hills) was purchased in Dec. 2013, moved into in Feb. 2014.

• The mortgage is in Husband’s name and close to default. Carey had “previously paid the mortgage.”

• Husband’s vehicle loan was also paid by Wife during the marriage but is now in default.

• In Nov. 2019, the parties put the cell phones in Wife’s name.

🚨 Contradictions & Errors

1. False Portrayal of Carey as Primary Wage Earner

• Tax records from 2016–2019 show Husband was the sole breadwinner (Carey’s contributions were limited to supplemental, part-time, or side income).

• Carey’s businesses were small-scale and primarily covered children’s clothing, activities, or part-time income streams.

• Carey never traveled internationally for work during the marriage until London 2022(emergency passport renewal proves this was her first trip abroad since 2012).

• By contrast, Husband’s roofing job with Regency (before being fired) involved frequent out-of-town travel for large projects.

2. Employment History Mischaracterized

• Husband was terminated from Regency Roofing by his uncle for theft just prior to his fall off a roof.

• His testimony suggests an “accidental unemployment” narrative, but in reality, his dismissal was disciplinary.

• The injury on Nov. 14, 2020 is used to frame him as disabled and a “stay-at-home parent.”

• In fact, Carey texted him about not being able to buckle Zachary into a car seat with one arm — proof that he was incapacitated, not caregiving.

3. Recovery & Disability Narrative

• Husband claimed recovery would take 18–24 months, putting him incapacitated until mid-to-late 2022.

• If true, this undermines his testimony of being the primary caregiver during this same period.

• His own attempt to apply for disability benefits further contradicts his portrayal as the “stay-at-home mom.”

4. Mortgage & Financial Responsibility

• The mortgage was always in Husband’s name, never Carey’s.

• Husband applied for a COVID hardship extension after losing his job — not Carey.

• Carey was never legally responsible for the mortgage or vehicle loans, despite Husband’s suggestion otherwise.

• The claim that Carey “paid the mortgage” is misleading — Carey contributed occasionally, but it was Husband’s obligation as sole mortgage-holder.

5. Phone Bill Manipulation

• The phones were transferred into Carey’s name in November 2019 because Husband lost his company coverage when fired.

• Prior to that, Regency Roofing covered phones and fuel.

• This shift was framed as Carey taking responsibility, when in fact it was due to Husband’s job loss and instability.

✅ Corrected Finding

• Husband was the primary wage earner from 2012–2019, not Carey.

• Carey’s businesses supplemented but never replaced Husband’s income.

• Husband was fired for theft from Regency Roofing before his injury, undermining his credibility.

• His 2020 injury left him incapacitated, not caregiving — evidence (texts about car seats, disability applications) confirms he was not capable of being the children’s primary caretaker.

• The mortgage, vehicle loan, and phone accounts were in Carey’s name or paid by Carey only because Husband defaulted or lost coverage. This reflects Husband’s irresponsibility and financial instability, not Carey’s control.

⚖️ Conclusion (Page 8):

The Court accepted Husband’s narrative of unemployment, disability, and Carey being the primary wage earner without reconciling it with tax records, termination circumstances, and his own incapacity. This manufactured narrative falsely supported his claim as “stay-at-home parent,” when in reality he was unemployed, disabled, financially irresponsible, and dependent on Carey’s stability.

📄 Page 9 – Carey’s Evidence vs. Court’s Findings

Court’s Summary (Florida Texts & Relocation Concerns):

• Prior to filing for divorce on March 21, 2022, Husband testified he and Carey discussed separation, and Carey “made clear” she did not want to stay in Ohio.

• Husband submitted Exhibit 4 (text messages) from his devices, showing Carey’s name and dates.

• Court notes multiple texts where Carey “explicitly stated” she wished to live in Florida:

• 6/26/21: Carey asked if Husband would rent a condo nearby if she moved to Florida.

• 8/15/21: Carey said, “Figure out your shit or figure out how to move us to Florida.”

• 8/26/21: Carey referenced getting tax credits for living in Florida six months.

• 12/27/21: Carey texted she deserved to rest and live in Florida, not raise kids in a “f***ing Catholic school,” and preferred Montessori.

• 1/3/22: Carey texted that Ohio harmed her mental health, Florida would make her happy, and she’d choose Florida over Husband.

• Husband responded positively (“let’s do this”), but Carey allegedly rejected, saying: “[N]o I fing won’t because it’s ruining my mental health Adam—you’ll never fing get it.”

• Court frames these texts as evidence Carey intended to abscond with the children to Florida.

🚨 Contradictions & Errors

1. Misrepresentation of Florida Plan

• The texts were not evidence of absconding, but consistent with the couple’s long-standing marital plan to spend winters in Florida.

• Since Isaiah’s birth, the family regularly spent winters in Florida, with discussions of relocating for 4–6 months a year.

• Husband himself discussed which Montessori school the boys should attend and whether they would buy/rent in Palm Beach Gardens or South Palm Beach (near his father’s Florida division of Regency Roofing which he was meant to take over ownership of).

• This was a joint plan, not Carey’s unilateral threat.

2. Omitted Context

• Husband testified to the Florida texts but ignored his own replies, where he encouraged moving: “Let’s do this,” “When do you want to move?” and “I’d move if I knew you’d stay in Ohio if I asked.”

• Husband’s own words confirm he was on board with the relocation — undermining his later claim of being “fearful Carey would abscond.”

3. Mental Health Distress Ignored

• Carey’s statements about Ohio winters worsening her mental health were not threats but pleas for wellbeing.

• She specifically tied relocation to needing sunlight and Montessori education for the children.

• Framing these as “threats” instead of medical and caregiving concerns is a mischaracterization.

4. Fabricated Narrative of Risk

• The Court conflated Carey’s desire for Florida residency (part of marital planning and co-parenting) with an alleged plan to flee Ohio and deny custody.

• Husband was fully aware of Florida family ties (visited in Jan 2021, went on airboat ride and dinner with Carey’s family). His testimony pretending he didn’t know where they lived is false.

• Counsel (Lisa Dean) wrote orders mischaracterizing these Florida discussions, ignoring proof that both parents had considered Florida relocation for years and spent every winter in Florida since Isaiah was born.

✅ Corrected Finding

• Carey’s texts were consistent with the marital plan of dual-state residency (Ohio + Florida), not evidence of parental abduction.

• Husband encouraged these plans in his own replies, confirming it was mutual.

• The Florida plan stemmed from family precedent and childcare/health needs, not sudden absconding.

• Husband’s later testimony contradicted his own supportive texts, revealing a manufactured custody narrative.

⚖️ Conclusion (Page 9):

The Court improperly admitted Husband’s selective presentation of texts as evidence of Carey intending to abscond. In truth, both parties jointly planned Florida relocation for the children’s education and family stability. By stripping away context, the Court allowed Husband to frame Carey’s mental health struggles and parenting concerns as threats — bolstering his false “fear of abduction” claim.

📄 Page 10 – Carey’s Evidence vs. Court’s Findings

Court’s Summary (Florida Family, Utah/London Trips, DV, Calendar):

• Carey texted (3/18/22): “Any man would… give both his nuts to have a wife whose only request was to spend the winter in Florida…” Court frames this as her prioritizing Florida relocation.

• On 4/30/22, Carey texted: “Yeah all I care about is living by the ocean… money is a means to an end…” Court says this proves her intent to move, with husband as “the only thing standing in her way.”

• Husband testified Carey suggested the family split time: 6 months Florida, 6 months Ohio.

• On cross, Husband admitted Carey’s family lives in Florida, but he “doesn’t know exactly where as she has family all over the state.”

• Husband testified that after the TPO in the criminal case was lifted, Carey took a business trip to Utah, leaving children with him. Then, after being served divorce papers, she left the children in his care again for her London work trip.

• Court notes: Husband admitted DV and removal from the house on 2/15/22, but began keeping a calendar after advice from counsel. Calendar noted who had the children, school pick-ups, overnights, etc.

• Husband testified he saw children on 2/16/22, and “every day since” until week of May 2, 2022. Court accepts his calendar as proof of near-daily contact and 50/50 sharing of duties.

🚨 Contradictions & Errors

1. Florida Family Misrepresentation

• Husband’s testimony that he “didn’t know where Carey’s family lives” is false.

• He had visited them in January 2021, gone on an airboat ride and dinner with them, and communicated with Carey’s mother and brother.

• His own text messages show he knew their addresses. The claim of “family all over the state” is fabricated.

2. Trips Mischaracterized

• Carey’s Utah and London trips were work-related, not abandonment.

• Prior to leaving, Carey attempted to leave the boys with her own mother. Adam insisted the boys stay with his mother instead.

• This proves Carey was responsibly arranging childcare, not disappearing.

3. Domestic Violence Context Minimized

• Court notes Adam “admitted to DV and removal from the home” but fails to weigh its significance in custody.

• Police records, photos, and testimony show Adam:

• Kicked a wine glass out of Carey’s hand.

• Broke a door frame by forcing it open.

• Brandished a box cutter with blood on the vacuum, prompting police orders to drop the weapon and slashed Carey’s tire with the box cutter.

• These are not minor — they are serious violent offenses witnessed and documented by police.

4. The “Calendar” is Manufactured Evidence

• Adam admitted he began the calendar only after 2/15/22, on attorney’s advice, meaning it was built for litigation, not daily parenting.

• He and his mother repeatedly requested to have the boys so he could fill in calendar entries — proof Carey never denied visits, but also proof Adam exaggerated his role.

• Carey was the consistent primary caregiver for 9 years, corroborated by witness statements, photos, and records. The Court’s acceptance of a retroactive, self-serving calendar as proof of “daily custody” is legal error.

5. False Claim of Daily Contact

• Adam’s claim he saw the boys “every day since 2/16/22” is disproven by:

• School staff testimony (Carey handled drop-offs and pick-ups).

• Text records showing Adam was at bars or using drugs many nights.

• Bank statements showing large cash withdrawals consistent with drug and alcohol binges.

✅ Corrected Finding

• Carey’s family is in one Florida location (Treasure Coast), known to Husband — he lied about this to suggest risk of absconding.

• Carey arranged proper childcare for Utah and London trips; Adam forced the boys into his mother’s care.

• Domestic violence was serious, ongoing, and ignored by the Court.

• Adam’s post-DV “calendar” is manufactured evidence, not a reflection of actual custody.

• Carey remained the consistent caregiver; Adam exaggerated his involvement to undermine her.

⚖️ Conclusion (Page 10):

The Court erred by accepting Adam’s fabricated calendar and minimizing the documented domestic violence. Mischaracterizing Carey’s work trips and texts as proof of absconding ignored the reality: she was responsibly managing childcare while recovering from abuse, and Adam manipulated the record to paint himself as the primary caregiver.

📄 Page 11 – Carey’s Evidence vs. Court’s Findings

Court’s Summary (Stay-at-home mom claim, TPO removal, guilty plea, probation, violence classes, tire/door/box cutter):

• Court notes: prior to 2/15/22, Husband described himself as a “stay-at-home mom.”

• Temporary Protection Order (TPO) in Stow Municipal Court was lifted on 3/17/22, after Carey did not appear. Husband admitted to the 2/15/22 incident.

• On cross-exam, Husband confirmed he understood a guilty plea meant admitting all allegations in the complaint.

• Children were not present on paperwork and not included in the TPO. Carey had requested they be included, but Judge Hoover allegedly “talked her out of it.”

• Carey also asked the Court for permission to travel to Florida for business; later submitted a letter to Judge Hoover.

• Husband pled guilty to M1 disorderly conduct, placed on community control, required to attend monthly probation meetings, substance abuse classes, and soon after, a violence class with random drug screens.

• Court claims Husband had no DV issues before or after 2/15/22.

• On cross, Husband testified he only “bumped” the door with his shoulder, denied slashing Carey’s tires, and said the blood on his hand was from a splinter he was removing with a box cutter. He recalled police ordering him to drop it.

• Court records Husband also testified about helping process server Petrasik, stating Carey told him to ignore service in a separate defamation suit.

🚨 Contradictions & Errors

1. False Claim: Husband as “Stay-at-Home Mom”

• Husband was fired from Regency Roofing for theft in Dec. 2019.

• He suffered a serious elbow injury in Nov. 2020 and admitted in texts he was unable to lift, buckle his son into a car seat, or function normally.

• He applied for disability and described himself as “clinically depressed” and “self-loathing” in texts.

• He spent 2021 out at bars, drinking and doing cocaine, with bank statements and call logs proving constant withdrawals and nightlife activity.

• Carey worked from home and homeschooled Isaiah, nursed both children for nearly 2 years each, prepared all meals, and managed their daily care.

• Evidence shows Carey was the true primary caregiver, while Adam exaggerated limited involvement to appear as a “mom figure.”

2. Minimization of Domestic Violence

• Husband pled guilty, admitted guilt, and was placed on probation because the DV occurred.

• Police evidence:

• Broken door frame consistent with being forced open.

• Wine glass kicked from Carey’s hand, striking her.

• Blood on vacuum, consistent with self-harm/suicidal gesture with a box cutter.

• Police ordered him to drop the weapon — this was not a splinter incident.

• Court falsely frames this as minor or isolated when it was a violent act with escalation.

3. History of Abuse Ignored

• Carey and the children experienced multiple incidents of strangulation, hitting, stalking, and harassment prior to 2/15/22.

• Carey was afraid to file earlier because Husband threatened to stab himself and blame her in order to take custody of the children (confirmed in texts and audio recordings).

• Children reported fear of their father (“Daddy is bad,” “Mommy, are you going to die?”).

• Court’s finding of “no history before or after 2/15/22” is directly contradicted by witness statements, texts, and police records.

4. Florida Misrepresentation

• Carey’s letter to Judge Hoover about Florida was work-related. She never intended to relocate the children without notice.

• Husband twisted this to accuse her of absconding.

5. Pattern of Harassment & Service Manipulation

• Husband’s testimony that Carey told him to “ignore service” in a defamation suit is misleading.

• In reality, Adam accompanied process servers, selected service times that aligned with Carey’s departures, and manipulated attempts to frame her as “dodging service.”

✅ Corrected Finding

• Husband was not a stay-at-home mom but an unemployed, disabled, addicted, probationary abuser.

• Carey was the sole primary caregiver for 9 years.

• Domestic violence was not minor — it was escalating, documented, and terrifying.

• Husband’s probation and mandatory violence/substance abuse classes underscore his pattern of abuse.

• Court erred by minimizing DV history, ignoring children’s experiences, and reframing Adam’s false narrative as credible.

⚖️ Conclusion (Page 11):

The Court misrepresented Adam as a stay-at-home caregiver, ignored his violent history, and minimized documented abuse. The guilty plea, probation, and court-ordered classes prove his instability. Carey’s caregiving was dismissed, and Adam’s distorted version of events was elevated — a fundamental miscarriage of justice.

📄 Page 12 – Carey’s Evidence vs. Court’s Findings

Court’s Summary (service attempts, London trip, Zachary pickup, cupcakes):

• Service was first attempted April 6, 2022, after Husband filed for divorce on March 21, 2022.

• Husband admitted he wanted Carey served when she was traveling to Utah because she is “hyper-aware of strangers” and would be upset, fearing she would take the children.

• Service was intentionally delayed so children would be with Husband when Carey was served.

• Carey was ultimately served on April 26, 2022, just before her scheduled London work trip (April 27–May 3, 2022).

• Husband testified Carey was upset and attacking him about the service while he was “pacifying her.”

• Court notes: “There was no contact between Wife and the children until the day before Wife returned from London, which Husband facilitated.”

• On May 4, Carey texted Husband that she would pick up Zachary from now on. Husband asked to keep the same schedule for “stability,” but Carey disagreed.

• Husband claimed this was also the first and last time Carey picked up Isaiah from track practice, May 4, 2022.

• On May 6 (Zachary’s birthday weekend), Husband testified he brought cupcakes to Goddard and that was the last time he saw Zachary.

• Husband testified that prior to May 6, he saw the children daily.

🚨 Contradictions & Errors

1. Manipulation of Service

• Husband admitted he delayed service intentionally to control when Carey would be served — planning it around her trips to cause emotional distress and manipulate custody optics.

• Service occurred April 26, the day before Carey’s international business trip.This was intentional retaliation and harassment, not a neutral legal act.

2. False Claim: No Contact During London Trip

• Carey did not “abandon” the children. She attempted to leave them with her mother, but Adam and his mother insisted the children stay with them instead.

• This was consistent with his pattern of control.

• Husband’s testimony that he “facilitated” communication is false — Carey’s contact with the boys was restricted because Adam withheld them as leverage while she was abroad.

3. Pickup Schedule Manipulated

• Carey regularly picked up and dropped off the children, especially Zachary. Witness Alicia Warrington (Goddard) testified Carey was the primary parent for school transport, contradicting Lindley’s claim.

• Texts show Carey telling Adam: “It’s normal for me to pick up Zachary.”

• Husband’s claim that May 4 was the “first time” Carey picked Isaiah up is false. It was the first time Adam chose to highlight it in his manufactured calendar.

4. Cupcake Claim is Posturing

• Husband claimed he brought cupcakes to Goddard on May 6, 2022, for Zachary’s birthday.

• Carey testified Adam never baked anything for their children in their ten-year marriage. This was staged for court optics.

• Witnesses confirm Carey was the parent responsible for birthdays, meals, and caregiving — not Adam.

5. False Claim: Husband Saw Children Daily Until May 6

• Adam fabricated a post-DV incident calendar on advice of counsel to create a false record of “daily contact.”

• In reality, Carey had full custody under an active CPO from Feb. 15 until July 11. Adam and Maryellen repeatedly asked for time with the children during this period, which Carey allowed to avoid further conflict — proof Carey did not restrict contact.

• This was not “daily care” — it was occasional visitation disguised as equal parenting.

✅ Corrected Finding

• Husband manipulated service timing to harass Carey and undermine her travel and work responsibilities.

• Carey was the consistent and primary caregiver; Adam fabricated a narrative that he saw the children daily, despite being under a CPO and probation.

• Pickup and school transport were primarily Carey’s responsibility, corroborated by school staff and texts.

• Husband’s “cupcake story” and claim of “daily involvement” were posturing attempts to rewrite the history of caregiving.

⚖️ Conclusion (Page 12):

The Court accepted Adam’s narrative of daily caregiving and facilitation during the London trip without acknowledging the CPO in place, the harassment of manipulated service, and the staged cupcake display. Carey’s role as the true primary caregiver was again erased, while Adam’s fabrications were treated as fact.

📄 Page 13 – Carey’s Evidence vs. Court’s Findings

Court’s Summary (May 5–7, 2022 events, police involvement, kidnapping accusations):

• Husband testified that Carey stopped all communication with him on May 5, 2022.

• He claimed that from March 17, 2022 (when the TPO was lifted) until May 5, 2022, he had daily communication with Carey via text and calls.

• Husband testified he became concerned because Carey had previously said she wanted to move out of Ohio.

• On May 7, 2022, after his neighbor told his mother police were at the marital residence, Husband called his attorney and police.

• Police informed him Carey had requested an escort to remove belongings.

• Husband testified that Carey told police she was afraid of him. Police confirmed children were safe with Carey.

• Husband asked police to file kidnapping charges against Carey; police declined.

• Husband then went to the police station to make a statement in person.

• Husband later gave police Carey’s mother’s contact information because he claimed Maryellen did not know where Carey was.

• On May 8, 2022, Isaiah did not show for track, which Adam claimed raised more concern. He went back to the police.

• Lt. Rice attempted to contact Carey’s mother for the children’s location.

• Husband emphasized that the last time he traveled for work was in April 2019, while Wife “regularly travels, including internationally.”

• Husband also claimed he did not know if the children had passports.

🚨 Contradictions & Errors

1. False Claim: “Daily Communication with Carey”

• From Feb. 15 to July 11, 2022, Carey had sole custody under a CPO.

• Any communication during this time was minimal, restricted, and often harassing.

• Evidence:

• Phone records show Adam harassed Carey with 30+ restricted calls, not normal parental communication.

• Carey’s texts repeatedly told him to stop surveilling her and stop interfering with her work.

• His claim of “daily communication” is false — it was daily harassment, not co-parenting.

2. Police Involvement Was Retaliatory

• On May 7, 2022, Carey requested a police escort due to Adam’s harassment and stalking.

• Instead of respecting this, Adam escalated by demanding police file kidnapping charges against Carey — while she had lawful custody under the CPO.

• Police declined because Carey was acting legally.

3. Manipulation of Narrative Around Fear

• Police confirmed Carey told them she was in fear of Adam — consistent with her longstanding reports of DV, strangulation, stalking, and threats.

• Adam tried to flip this by suggesting her fear was fabricated, while simultaneously using police to track Carey’s whereabouts.

4. Track Meet “Concern” Claim

• Adam claimed Isaiah missing a track meet on May 8 increased his fear Carey “absconded.”

• Reality: Carey had the boys under a valid CPO. Isaiah missing a single event does not equal endangerment. This was weaponized to build Adam’s narrative of Carey hiding the children.

5. Employment and Travel Distortion

• Adam repeatedly stated the last time he traveled for work was 2019 to posture as “home full time.”

• Reality:

• He was fired from Regency Roofing in Dec. 2019 for theft.

• His “injury” in 2020 further prevented work.

• He applied for disability and admitted he could not buckle Zachary’s car seat with one arm.

• Carey was the primary caregiver and only working parent during this period.

• Adam misrepresented Carey’s work trip to London (her first international trip in a decade) as proof she “regularly travels internationally.” This is false.

6. Passports Statement is Illogical

• Adam claimed he did not know if his children had passports.

• A primary caregiver would always know this information. Carey confirms: the children do not have passports.

✅ Corrected Finding

• Carey did not “cut off contact” May 5. She was following her attorney’s advice under the CPO to limit engagement with Adam’s harassment.

• Adam attempted to criminalize Carey’s lawful custody by demanding kidnapping charges and an Amber Alert, both rejected by law enforcement.

• Adam’s narrative of “daily contact” was in fact a campaign of daily harassment and stalking.

• His employment and travel claims were manipulations to make himself appear stable while discrediting Carey.

⚖️ Conclusion (Page 13):

The Court mischaracterized Adam’s harassment as “daily communication” and ignored the active CPO granting Carey custody. By crediting Adam’s false kidnapping claims and portraying Carey’s legal travel as suspicious, the Court weaponized Adam’s distortions to paint Carey as unstable, when the evidence shows Adam was the abuser, unemployed, disabled, and misusing law enforcement to surveil and intimidate her.

📄 Page 14 – Carey’s Evidence vs. Court’s Findings

Court’s Summary:

• Husband testified that for two years, Carey had threatened to take the children and move to Florida.

• Husband testified there were no cameras, trackers, or surveillance devices at the marital home, in Carey’s car, or on her phone. He denied monitoring her electronically.

• On cross-examination, Husband claimed that Carey should not be afraid of him, and that since March 17, 2022, Carey had invited him home multiple times and asked him to dinner.

• Husband testified he completed CYO Veritas training, a coach development program, and a background check after his Feb. 15 DV arrest.

• On cross, Husband admitted he did not tell Matt Zamecmik about the DV case and did not update CYO about its resolution.

• Husband testified he learned of the DV/CPO on May 9, 2022, when his mother phoned him while he was at his attorney’s office.

• His mother had called him when the sheriff’s office came to serve him. Adam then left to meet the sheriff and be served.

• On cross-examination, Husband admitted a history of depression and being evaluated at a hospital in 2019 after Sagamore Hills PD transported him there. He was released the same night.

🚨 Contradictions & Errors

1. False Florida Narrative

• Adam claimed Carey had “threatened to move to Florida for two years.”

• Reality: Carey and Adam jointly planned wintering in Florida since Isaiah’s birth. Their only disagreement was duration (4 months vs. 6 months).

• Evidence: Texts and messages show Adam himself discussed real estate in Palm Beach Gardens and South Palm Beach for seasonal stays.

• Adam and his counsel twisted their long-term plan into a “threat” to fit his absconding narrative.

2. Surveillance Denial is Proven False

• Adam denied using surveillance, cameras, or trackers.

• Evidence directly disproves this:

• Carey discovered a GPS tracker in her garage,

• Keylogger on her computer (confirmed by tech specialist),

• Recording devices hidden in her purse, under her bed, and in her car.

• Texts from Adam show him asking about vehicles in Carey’s driveway and furniture deliveries — proof of stalking.

• His courtroom denial was perjury.

3. False Claim Carey Invited Him Back Home After DV

• Adam testified that since March 17, Carey “invited him home multiple times and to dinner.”

• Reality: Carey did not invite him back to cohabitate. She only agreed to one dinner with their sons before leaving for a work trip so she could see them before traveling.

• He reframed a parenting arrangement as an invitation for reconciliation, attempting to minimize her fear and the DV.

4. CYO / Background Check Misconduct

• Adam admitted he failed to disclose his active DV case to CYO or Zamecmik, despite coaching children.

• This violated both CYO safety policy and transparency standards.

• He used fingerprinting and Veritas training as cover to appear rehabilitated, while concealing active criminal proceedings.

5. Mental Health History

• Adam admitted under cross that he has a history of depression, was evaluated by police intervention in 2019, and transported to a hospital.

• Carey testified (and police records corroborate) that this followed Adam’s threats to stab himself and frame her to gain custody.

• The Court minimized this, instead presenting it as a neutral “evaluation” rather than a dangerous pattern of manipulation and suicidality used as leverage.

✅ Corrected Finding

• Carey never “threatened” to move to Florida. Both parties agreed on winter residence plans until Adam reframed it in litigation.

• Adam’s denial of surveillance is disproven by multiple devices found, texts, and direct admissions. His testimony was perjury.

• Carey never invited Adam back as a partner; the one dinner before travel was for the children’s benefit only.

• Adam misled CYO and concealed his DV record, endangering children he was coaching.

• His depression and history of threats were not benign but part of a pattern of coercive control and instability.

⚖️ Conclusion (Page 14):

The Court erred in crediting Adam’s denials of surveillance and misrepresentations about Florida, while minimizing Carey’s safety concerns and Adam’s mental health history. By reframing his stalking as non-existent and presenting joint Florida plans as a unilateral threat, Adam manipulated the narrative and was wrongfully believed.

📄 Page 15 – Carey’s Evidence vs. Court’s Findings

Court’s Summary:

• On cross, Adam was questioned about phone calls made to private investigators in Florida (Treasure Coast Investigative Services, Cooper Investigation, Shields Investigation).

• Adam testified he did not hire an investigator, but admitted his father may have made the calls on May 9, 2022. He claimed he only “followed up” at his father’s request.

• Adam requested the Court grant him temporary custody or shared parenting while Carey remained in Ohio. He insisted all he wanted was contact with the children.

• Carey’s first witness: Officer Emily Roxbury, Sagamore Hills Police Department.

• On Feb. 15, 2022 at 1:30 p.m., Roxbury responded to a domestic violence call at 1445 Roman Dr.

• Roxbury testified she had previously been at the residence for a lock-out and welfare check.

• Roxbury was aware that after Feb. 15, the department provided an escort for Carey’s safety.

• Carey reported Adam had been previously abusive to her and the children but she had been afraid to call before.

• Roxbury found corroborating evidence:

• Wine on Carey’s shirt,

• Wine stain/towel where Adam attempted to clean,

• Glass inside a vacuum,

• Blood on the vacuum handle from Adam’s cut hand,

• Bedroom door frame cracked, consistent with being forced open.

🚨 Contradictions & Errors

1. CPO Violation – PI Calls in Florida

• Adam and/or his father contacted Florida investigators after being served with a DV/CPO.

• This was a direct violation of the order: he sought to locate Carey, who had fled for safety.

• He minimized his involvement by shifting blame to his father, yet admitted he “followed up” — proving complicity.

2. Manipulation of Custody Narrative

• Adam requested temporary custody during this same period, claiming he only wanted “contact.”

• In reality, he simultaneously:

• Violated the CPO by searching for Carey in Florida,

• Filed for custody through false testimony,

• Weaponized the process server to serve her when traveling, ensuring maximum distress.

• His statements to the Court were strategic posturing, not genuine concern for the children.

3. Officer Roxbury’s Testimony Confirms Carey’s Allegations

• Roxbury provided independent police confirmation of Adam’s physical violence, clean-up attempt, and property damage.

• Evidence directly corroborates Carey’s account:

• Adam kicked a wine glass out of her hand,

• Caused liquid on her shirt,

• Tried to cover it up (vacuum + towel),

• Left blood from his cut,

• Forced entry into the bedroom by cracking the door frame.

• This contradicts Adam’s later testimony minimizing the event as “just bumping the door” and “removing a splinter.”

4. Pattern of Abuse Ignored by the Court

• Carey told Roxbury she had been afraid to call police previously due to Adam’s threats (including self-harm threats to frame her).

• Despite corroborated fear and physical evidence, the Court repeatedly minimized the Feb. 15 DV as an isolated incident — contrary to testimony and police observations.

✅ Corrected Findings:

• Adam and his father’s Florida investigator calls were harassment and surveillance violations under the active CPO. This should have strengthened Carey’s protective position, not been dismissed.

• Adam’s request for custody was inconsistent with his actual conduct — it was a litigation strategy, not a child-centered concern.

• Officer Roxbury’s objective police report provided corroboration of:

• Domestic violence,

• Property damage,

• Cover-up attempt.

• The Court erred by not weighing Roxbury’s law enforcement testimony as primary evidence of abuse.

⚖️ Conclusion (Page 15):

Page 15 is pivotal: Adam’s surveillance efforts in Florida violated the CPO, while Officer Roxbury’s testimony independently confirmed Carey’s abuse narrative with physical evidence. Instead of protecting the victim and children, the Court minimized the DV and granted Adam credibility despite his proven dishonesty and violations.

📄 Page 16 – Carey’s Testimony vs. Court’s Handling

Court’s Summary:

• Officer Roxbury’s testimony:

• Adam claimed Carey threw the wine glass (contradicting earlier findings).

• Officers observed no alcohol use at the time, no children present, and confirmed Adam had a hand cut which he claimed came from digging out a splinter.

• Carey’s testimony:

• She is self-employed in health sales, primarily online.

• Testified children are still in Ohio but declined to provide further location information for safety.

• Confirmed marital residence as her address but stated she would not disclose current whereabouts due to not feeling safe.

• Confirmed intention to withdraw children from school but had not yet disclosed this at the ex parte hearing.

• Testified she is the primary caregiver.

• DV details:

• On 2/15/22, Adam kicked a glass of wine out of her hand while she was on a Zoom call with her therapist.

• He regularly interrupts her Zoom sessions, yelling, screaming, and threatening her.

• She has called the police multiple times in the past but never filed charges due to fear of retaliation.

• Testified Adam previously threatened to stab himself and once wrote a suicide noteafter she asked for divorce.

🚨 Contradictions & Misrepresentations

1. Adam’s shifting narrative about the wine glass

• Officer Roxbury noted Adam claimed Carey threw the wine glass.

• This directly conflicts with Roxbury’s own prior testimony (Page 15) that Carey reported Adam kicked it out of her hand, and physical evidence corroborated Carey’s version (wine on her shirt, towel, glass in vacuum, blood on vacuum, cracked door frame).

• His inconsistent stories undermine credibility, yet the Court credited him over corroborated physical evidence and Carey’s account.

2. Minimization of digital harassment & stalking

• Carey testified Adam routinely interrupted her therapy Zoom calls to yell, scream, and threaten her.

• Carey provided screenshots of Adam mocking therapy sessions and openly admitting his drug use, alcoholism, and need for control.

• This pattern of harassment was consistent and ongoing, not isolated. It also shows he weaponized her healing efforts to destabilize her.

3. Safety concerns ignored

• Carey testified she could not disclose her living location for fear of Adam’s retaliation.

• This was not paranoia but validated by:

• Adam’s use of surveillance devices (tracker in car, keylogger on computer, recording devices in purse/bedroom, as you’ve shown).

• His repeated texts asking who was in her driveway and monitoring her movements.

• His father and neighbor being enlisted to spy on Carey’s home in violation of the CPO.

• Yet the Court treated this as evasiveness rather than a protective action by a DV victim.

4. Undervalued history of threats & suicide manipulation

• Carey testified Adam threatened self-harm (“stab himself”) and once wrote a suicide note after she raised divorce.

• She provided texts confirming his acknowledgment of drug use, addiction, and suicidal ideation, framing it as Carey’s responsibility (“if you just accepted me, I wouldn’t be upset on drugs”).

• This is coercive control: threatening self-destruction to prevent her from leaving. The Court failed to weigh this as abuse toward both Carey and the children.

✅ Corrected Findings:

• Wine Glass Incident: corroborated evidence + consistent testimony prove Adam kicked the glass from Carey’s hand. His story changed multiple times, showing dishonesty.

• Harassment Pattern: Adam’s repeated Zoom call interruptions, screaming, and threats demonstrate a pattern of psychological abuse and coercive control.

• Surveillance: Carey’s refusal to state her location was a protective measure backed by strong evidence of stalking and tracking. This should have reinforced her credibility, not weakened it.

• Suicide threats: Adam’s suicide note and threats of stabbing himself were manipulative tactics to keep control, not isolated mental health crises. This fits recognized DV patterns (self-harm threats as leverage).

⚖️ Conclusion (Page 16):

Page 16 strengthens the DV narrative: Carey provided consistent testimony, corroborated by physical evidence and prior reports, while Adam’s story shifted. The Court’s failure to weigh Carey’s safety concerns, Adam’s surveillance, and his manipulative suicide threats shows a profound miscarriage of justice.

📄 Page 17 – Carey’s Testimony vs. Court’s Handling

Court’s Summary:

• Carey testified Adam had a suicide crisis in 2019, where it took four hours to locate him and he was hospitalized briefly.

• Carey admitted she did not have the physical suicide note at the hearing, but confirmed the event occurred in 2019 and she continued to live with him afterward.

• Carey testified that after Adam vacated the home on 2/15/22, she found bags of empty liquor bottles (Patrón and others) in the basement.

• She alleged Adam was stealing money, and using suboxone, opiates, and cocaine.

• She testified she personally observed him using drugs in the basement while the children were upstairs, and that she overheard him on the phone ordering “8 balls.”

• She testified Adam had threatened her business partners.

• On cross-exam, she admitted Adam is now under monitoring for drugs/alcohol as part of probation.

• Carey admitted she occasionally drank with a meal, and was presented with texts between her and Adam where she said she was drunk, wasted, or puking (spanning 2019–2022).

• Carey testified that when their oldest son was 3 or 4, Adam hit him so hard on the bottom he flew off the floor.

• Carey testified her younger son later had a welt on his bottom that lasted three days, which her older son told her was caused by Adam hitting him.

• She submitted photos of Zachary’s bottom as evidence, taken after this incident.

• Carey admitted she did not witness the strike, but that Isaiah had.

• Carey testified Adam stood over her as she took the photos, intimidating her.

• Carey also testified she confronted Adam but was too afraid to call police.

🚨 Contradictions & Misrepresentations

1. Suicide Incident (2019)

• Court notes Carey didn’t bring a copy of the note, diminishing credibility.

• But Adam’s own texts confirm he admitted depression, suicidal ideation, and addiction — calling it his “disease” and blaming Carey for “not accepting him on drugs.”

• Police involvement is corroborated (Sagamore Hills PD transported him for evaluation).

• His suicide threat wasn’t a one-time event — it was part of a pattern of manipulation and control.

2. Alcohol & Drug Abuse

• Carey’s discovery of bags of liquor bottles after 2/15/22 is corroborated by texts where Adam calls himself a “heavily drinking motherfer”* and brags about late-night drinking.

• Screenshots show him admitting to drug use, addiction, and partying while Carey was working to support the household.

• His threats to her business partners and theft of marital funds (documented in bank records and texts) prove substance abuse tied directly to financial coercion and intimidation.

• The Court discounted Carey’s testimony by overemphasizing texts where she admitted to drinking socially (with a meal, or when provoked), but those texts were sporadic and not tied to patterns of violence or neglect — unlike Adam’s admissions.

3. Child Abuse

• Carey testified Adam hit Isaiah so hard at age 3 or 4 that he flew off the floor and hit his head.

• Carey also testified Zachary had welts lasting three days — corroborated by photos she provided and Isaiah’s direct statement.

• Instead of viewing this as clear physical abuse, the Court downplayed it as “spanking.”

• Adam himself admitted on cross-exam to being physical, but minimized by saying he only “bumped doors” or “disciplined” the boys.

4. Witness intimidation

• Adam stood over Carey to ensure she did not call the authorities after physical assaults — showing direct intimidation and control.

• This aligns with Carey’s consistent testimony that she was afraid to call authorities because Adam threatened retaliation and had already surveilled and harassed her.

✅ Corrected Findings

• Mental Health Coercion: Adam’s suicidal ideation was not simply a mental health issue — it was weaponized as coercive control.

• Substance Abuse: Adam’s alcoholism and cocaine use were chronic and admitted in his own words. Carey’s limited social drinking cannot be equated with his pattern of addiction and violence.

• Child Abuse: Striking a child so hard that he “flies off the floor,” and leaving welts that lasted days, meets the threshold of physical abuse, not “discipline.”

• Credibility: Carey’s testimony is consistent with photographic evidence, children’s direct statements, texts, call logs, and Adam’s own admissions. The Court’s choice to minimize this reflects bias, not fact.

⚖️ Conclusion (Page 17):

Page 17 contains some of the strongest evidence of Adam’s addiction, violence, and coercive control — much of it corroborated by physical evidence, photos, texts, and Adam’s own words. The Court’s minimization of this evidence and focus on isolated texts of Carey’s social drinking is a distortion of fact and victim-blaming.

📄 Page 18 – Carey’s Testimony vs. Court’s Handling

Court’s Summary:

• Carey testified Adam had threatened her to prevent her from calling authorities and had previously stolen her phone and slashed her tires.

• On cross, Carey admitted she occasionally spanked the children lightly, and they would say “it doesn’t hurt.”

• Court introduced texts between Carey and Adam from 2016–2019 where Carey texted about spanking Isaiah, including:

• 9/15/16: “I spanked him for it.”

• 9/12/17: “Isaiah was acting up, I’m going to spank him” (Isaiah allegedly responded “please don’t hurt my body”).

• 4/4/18: “I just spanked his ass.”

• 8/24/18: “I’m going to start spanking again until he learns to listen.”

• 10/3/19: “Going to start spanking Isaiah again.”

• Carey clarified she never left marks on the children.

• On cross, Carey was shown photos authenticated by Maryellen allegedly showing children’s reactions to patches. Carey testified she was the one who applied stem cell patches, not Adam, but clarified she now applies them to clothing instead of skin.

• Carey testified that after 2/15/22, when she filed the police report, she called Adam’s mother, who berated her, while she heard Adam screaming in the background.

• Carey testified Adam screamed at her “You better fix this.”

• Carey testified Adam violated the TPO by calling from a restricted number at least three times.

• Carey confirmed she checked Adam’s phone account activity during this time.

• Carey admitted she initially picked up the restricted calls, recognized Adam’s voice, and asked that charges be reduced.

🚨 Contradictions & Misrepresentations

1. Spanking vs. Beating

• The Court leaned heavily on years-old texts where Carey mentioned “spanking” as if it was equivalent to Adam’s abuse.

• Carey clarified that her “spanking” was light taps that left no marks, and even Zachary said “it didn’t hurt.”

• This cannot be equated to Adam’s documented physical beatings, which left welts and bruises lasting days — corroborated by photographs and Isaiah’s testimony.

• By overemphasizing these texts, the Court attempted to create a false equivalencebetween Carey’s discipline and Adam’s violence.

2. Stem Cell (Phototherapy) Patches

• Court portrayed Carey as the only person applying patches.

• In reality, Maryellen also regularly used patches and applied them to the boys herself.

• The photos Maryellen took allegedly showing a rash from patches were taken when the boys were in her care, not Carey’s.

• Texts prove Carey instructed Maryellen to cut half the backing off and apply patches to clothing, showing Carey did not apply directly to the skin in those instances.

• This makes Maryellen’s testimony hearsay, biased, and unreliable — especially given her clear alignment with Adam.

3. TPO Violations

• Carey testified Adam repeatedly called her from restricted numbers in violation of the TPO.

• Phone records show patterns of restricted and repeated calls, proving harassment.

• Carey admitted she asked for charges to be reduced, but this was under intense pressure and coercion. Adam’s mother berated her, Adam screamed in the background, and Adam threatened her directly — classic victim coercion.

• This doesn’t lessen the severity of Adam’s violations — it proves his ability to manipulate and intimidate Carey even under court orders.

✅ Corrected Findings

• Carey’s “spanking” was mild discipline, incomparable to Adam’s abuse. Adam’s violence is corroborated by photographic, testimonial, and medical-style evidence — Carey’s discipline left no marks.

• The Court improperly relied on Maryellen’s biased photos to portray Carey as abusive, ignoring that Maryellen herself applied patches and that Carey had switched to clothing application.

• Adam’s repeated TPO violations were real and documented — Carey’s request to reduce charges was the direct result of duress and intimidation.

• Instead of protecting Carey, the Court weaponized her coerced statements against her, while minimizing Adam’s clear, repeated misconduct.

⚖️ Conclusion (Page 18):

Page 18 reflects the Court’s attempt to create a false equivalence between Carey’s parenting and Adam’s abuse. It improperly elevated stale texts and Maryellen’s biased testimony while ignoring the overwhelming, corroborated evidence of Adam’s violence, drug abuse, coercive control, and harassment. The reality is clear: Adam was the aggressor, and Carey’s testimony is consistent with the evidence, while Adam’s and Maryellen’s are not.

📄 Page 19 – Carey’s Testimony vs. Court’s Handling

Court’s Summary:

• Carey testified she took certain actions because she was afraid of Adam.

• Carey asked for the TPO to be revised because she believed Adam had drug and alcohol problems, plus access to firearms, while functioning as a “stay-at-home mom.”

• Carey testified she agreed to lesser charges because she didn’t want Adam to hurt her or the children.

• Carey testified Adam isolated her from family and friends, threatened her mother, and acted aggressively toward the cleaning lady (who left employment after saying Adam looked aggressive).

• On cross-examination, Carey admitted she had seen Adam and had physical contact with him after 2/15/22, and had sent texts to meet for dinner — including one dinner with the children at Oak Barrel Room prior to her work trip.

• Carey admitted she left the children with Adam’s mother during her work trips to Utah and London but testified this was because Adam strong-armed her into doing so.

• Carey testified she felt Adam had her served with divorce paperwork the day before her London trip intentionally to abuse her.

• Carey testified that whenever someone pulled into the driveway, Adam would text her, making her fear she was under surveillance.

• Carey testified Adam had choked her multiple times, pinned her down in front of the children, and the children witnessed it.

• Carey testified her younger child asked, “Are you going to die Mommy?”

• Carey testified she remained afraid for herself and her children.

• Carey testified Adam used the children to control her, calling the youngest “a little terror,” which led to the child saying, “Daddy doesn’t like me.”

🚨 Contradictions & Misrepresentations

1. Dinner Meetings Misrepresented

• The Court attempted to portray Carey’s limited contacts with Adam (texts/dinners) as evidence she was not afraid.

• Reality: The only dinner Carey asked for was to see her sons before leaving for her work trip — not to reconcile with Adam.

• Contact with Adam after DV incidents was forced under coercion and manipulation. Victims often comply under duress, which does not negate fear or abuse.

2. Leaving Children with Adam’s Mother

• Court noted Carey left the boys with Adam’s mother during trips.

• Reality: Carey attempted to leave the children with her own mother but Adam forced them into his mother’s care. This was not voluntary.

• This shows Adam’s ongoing coercive control, not Carey’s consent.

3. Surveillance Ignored

• Carey testified that Adam texted her whenever cars entered her driveway, demonstrating stalking behavior.

• Evidence: Texts show Adam questioning her about vehicles and deliveries, corroborating surveillance.

• Instead of addressing this, the Court minimized it — despite tech investigation showing keyloggers and tracking devices.

4. Physical Abuse Minimized

• Carey testified Adam choked her multiple times, pinned her down in front of her sons, and caused one child to ask, “Are you going to die Mommy?”

• This is direct testimony of strangulation — one of the most severe indicators of lethal domestic violence risk.

• The Court downplayed this evidence, treating Adam’s violence as minimal while exaggerating Carey’s minor discipline.

5. Emotional Abuse Toward Children

• Adam calling Zachary a “little terror” led to Zachary repeating, “Daddy doesn’t like me.”

• This reflects Adam’s emotional abuse of the children, which the Court ignored in its ruling, despite consistent reports from the children.

✅ Corrected Findings

• Carey’s contact with Adam after DV was coerced and done only for the children’s sake, not willingness or safety.

• Leaving the children with Adam’s mother was forced, showing Adam’s control, not Carey’s consent.

• Surveillance by Adam was real and documented; Court ignored texts and tech findings.

• Adam’s repeated strangulation of Carey is a high-risk DV marker, corroborated by the children’s own words — ignored by the Court.

• Adam’s emotional abuse of the children was overlooked, despite direct testimony and corroboration.

⚖️ Conclusion (Page 19):

Page 19 reveals how the Court selectively minimized Adam’s physical abuse and coercion while reframing Carey’s survival strategies (limited contact, coerced childcare arrangements, coerced lowering of charges) as inconsistencies. The evidence proves Adam engaged in strangulation, coercive control, and surveillance — all ignored in favor of protecting his narrative.

📄 Page 20 – Carey’s Testimony vs. Court’s Handling

Court’s Summary:

• Carey admitted she left the marital home temporarily after receiving the DV/CPO for her safety.

• Court notes Carey’s family lives in Florida near Stuart (Treasure Coast).

• Carey testified Adam had called her Range Rover company (OnStar/similar system) in an attempt to track her car.

• Carey testified Adam had also called private investigators in Florida, both children’s schools, her mother, and Sagamore Hills Police in attempts to locate her.

• In rebuttal, Adam’s mother, Mary Ellen Zivich, testified:

• She took the patch photos (Exhibit 9) and said they showed the children’s “reaction.”

• She admitted some photos were from several months ago, others within the year, claiming she took them because she was “concerned.”

• She testified regarding Exhibit 10, showing texts between Carey and herself.

• On 2/17/22, after Adam was accused of DV, Carey allegedly sent Mary Ellen texts for Adam.

• On 2/28/22, a neighbor allegedly sent Mary Ellen photos of trucks in Carey’s driveway.

• On 3/2/22, Carey allegedly texted Mary Ellen saying Adam could pick up Zachary from Goddard.

• On cross, Mary Ellen admitted she was notified of the DV incident by her neighbor, Gary Nawrocki.

• She admitted she served as a go-between to pass messages but denied Adam ever used her phone directly or spoke to Carey during those exchanges.

🚨 Contradictions & Misrepresentations

1. Adam’s Surveillance Efforts

• I testified Adam tried to track my vehicle by contacting my Range Rover/OnStar-type service.

• This was part of a larger pattern of stalking — including recording devices in my purse, GPS trackers found in the garage, and texts from Adam proving surveillance (“what’s this truck in your driveway?”).

• The Court recited this as though it were speculative, but phone records and investigator documentation confirm Adam attempted to access my vehicle’s system.

2. Private Investigators & Police Harassment

• I testified Adam or his father called multiple private investigators in Florida, my sons’ schools, and Sagamore Hills Police, all to track me down in violation of the CPO.

• This was framed as Adam being “concerned,” but in truth, it was clear intimidation and stalking behavior in violation of both DV and CPO protections.

3. Mary Ellen’s Testimony (Patch Photos)

• Mary Ellen took the patch photos (Exhibit 9) when the children were in her care, not mine.

• She claimed the photos show a “reaction” to stem cell patches, but:

• I testified the patches are phototherapy, not stem cell.

• The backing is 3M Band-Aid adhesive, which can cause minor skin irritation if overused.

• The boys were in her custody when she took the photos, which means she or Adam applied them, not me.

• Her testimony was hearsay and could not prove I applied them, but the Court treated it as though I did.

4. Mary Ellen as Intermediary

• Mary Ellen admitted she acted as a go-between passing messages for Adam and me, but denied Adam used her phone or spoke directly.

• This is contradicted by phone records and my testimony: Adam got on the line during her berating me and threatened me directly (“you’d better fix this”).

• Mary Ellen’s denial here was perjury to protect her son.

5. Neighbor Collusion

• Mary Ellen testified the neighbor (Gary Nawrocki) notified her of my DV incident.

• This confirms Gary, Mary Ellen, and Adam were actively colluding in surveillance of me, in violation of the CPO.

• Court minimized this by presenting it as “concerned neighbors” when in reality it was a stalking network.

✅ Corrected Findings

• Adam’s attempt to access my vehicle tracking system was part of an escalating pattern of stalking, not just concern.

• Adam and his father’s calls to investigators, schools, and police were deliberate violations of the CPO to monitor and control me.

• Mary Ellen’s patch photos were taken when the children were in her custody; they do not prove I applied the patches.

• Mary Ellen’s denial that Adam ever used her phone conflicts with my direct experience of him threatening me while she berated me.

• Mary Ellen and Gary Nawrocki acted as extensions of Adam’s surveillance, enabling harassment and intimidation.

⚖️ Conclusion (Page 20):

The Court accepted Mary Ellen’s testimony at face value, despite clear bias, hearsay, and perjury. Surveillance and stalking by Adam were minimized, while Mary Ellen’s “concerns” over patches were weaponized against me. This page demonstrates how the Court elevated unverified, self-serving testimony from Adam’s mother over documented stalking violations and my direct testimony as the DV victim.

Page 21 Analysis

The court relies on R.C. 3109.04 to justify modifying custody, but fails to apply the statute correctly. Under Ohio law, a court may not modify a decree allocating parental rights unless it finds a change in circumstances that is both substantial and affects the child’s welfare. I correctly testified that no such change had occurred. The court itself even admits that “a change of circumstances analysis is not warranted in the traditional sense” but then contradicts itself by using that concept anyway as a guide to remove custody.

The statute also requires the court to consider the wishes of the children, which it never did. The children were not interviewed in chambers under R.C. 3109.04(B). The judge’s omission violates statutory requirements and silences my children, despite the fact they expressed fear of their father and safety with me.

Page 22 Analysis

This page outlines statutory factors the court must consider under R.C. 3109.04(F)(1):

• The child’s wishes and concerns;

• The child’s relationship with parents, siblings, and others;

• The child’s adjustment to home, school, and community;

• The mental and physical health of all persons involved;

• The parent more likely to honor visitation rights;

• Any history of child abuse, neglect, or domestic violence;

• Whether either parent has denied court-ordered parenting time;

• Whether either parent has established or plans to establish residence out of state.

Despite listing these factors, the judge failed to apply them fairly. Evidence showed my husband has a documented history of domestic violence, child abuse, drug addiction, and alcohol abuse, while I provided 40+ witness letters confirming my long-term caregiving role. The judge ignored the overwhelming evidence that weighed heavily in my favor and instead constructed a false narrative that you were a risk of “absconding.”

Further, the judge improperly relied on hearsay from my husband’s mother, neighbors, and fabricated text interpretations, rather than hard evidence like my school communications, photos, bank statements, and voicemails.

Page 23 Analysis

This section adds more statutory factors:

• The parents’ ability to cooperate;

• The ability to encourage love and contact with the other parent;

• Any history of child abuse, domestic violence, or parental kidnapping;

• Geographic proximity of parents;

• Recommendations of a guardian ad litem (none was appointed).

Despite acknowledging these, the judge disregarded them in practice. I demonstrated cooperation by allowing my husband visitation (even after abuse), while he repeatedly harassed, surveilled, and intimidated me. He used the children as leverage, calling them “little terrors” and creating fear in their minds. He admitted to violence, pled guilty to disorderly conduct, and was on probation at the time of the custody transfer.

Instead of recognizing his criminal history as disqualifying, the court minimized it and falsely framed me as unstable. The ruling directly contradicts statutory mandates by granting custody to a parent with criminal convictions, substance abuse issues, and documented violence — all while stripping the protective parent of rights.

✅ Pages 21–23 show how the judge cherry-picked Ohio law: reciting statutes in writing but ignoring their application in my case. Instead of applying best-interest factors honestly, she used them selectively to justify a predetermined outcome that favored my abusive husband.

Page 24

The court acknowledged that Carey did, in fact, request that Judge Hoover lift the TPO at the arraignment, and again at sentencing, which resulted in the TPO being lifted when the husband pled guilty to disorderly conduct. The court, however, mischaracterized Carey’s motivations, stating it was “difficult to determine” why Carey made this request, despite the clear evidence that her actions were the result of threats, coercion, and fear for her children’s safety.

The court found only portions of Carey’s testimony credible while deeming the husband’s testimony “generally credible.” This finding disregarded overwhelming corroborating evidence Carey presented, including school records, witness letters, and documented incidents of abuse, intimidation, and substance abuse. The court minimized Carey’s testimony regarding her parenting, instead focusing on isolated allegations of spanking or drinking, while ignoring documented proof of the husband’s violence, addiction, and criminal history.

The judge adopted the false narrative that until May 6, 2022, the husband was the “primary caregiver,” despite the fact that Carey had been the children’s consistent caregiver for their entire lives. The husband’s description of himself as a “stay-at-home mom” was repeated by the court as fact, even though it was Carey who made the statement sarcastically and in a deprecating manner, under pressure, to illustrate the imbalance in the relationship.

The court also dismissed Carey’s testimony that the husband had been yelling in the background when Mary Ellen spoke with her on the phone and that Mary Ellen relayed his threats. Instead, the court chose to believe the husband and Mary Ellen, claiming their testimony was more believable. The judge excused the husband’s behavior by saying that while he may not have taken the phone directly, he was “certainly yelling in the background,” attempting to justify his intimidation as emotional distress over his arrest. This reasoning minimized Carey’s lived reality of intimidation, harassment, and coercion during the period leading to the issuance of the TPO.

Page 25

Carey presented testimony and photographic evidence of longstanding abuse toward herself and the children. The pictures introduced clearly showed one of the children had been beaten, yet the court attempted to minimize the evidence by suggesting a “generous interpretation” that the child was merely “overzealously spanked.” Regardless of wording, the injury to the child was obvious, serious, and wholly inappropriate.

The court noted that two stem cell patches were visible in one of the pictures and speculated that the photos showed “healing progression” while in the same order calling it child abuse as bad as beating. This interpretation disregarded the fact that the patches were taken by Mary Ellen during times when the children were in her care, raising the question of whether she herself applied them. Carey never testified that she applied the patches in these specific instances, but rather that she had at times placed patches on the children’s clothing, not directly on their skin. Despite this, the court falsely asserted that Carey had continued applying the patches recklessly.

The court mischaracterized Carey’s testimony regarding abuse, suggesting she admitted the husband stood over her as she took photographs of the child’s bruises. In reality, Carey testified that she took the pictures after bathing her son and that the husband was not present at the time. Carey also testified that the husband was responsible for the severe spanking that caused the bruises, which left lasting marks. This was consistent with her children’s own statements.

The additional photos presented by Mary Ellen, showing redness and rashes on the children’s skin, were also used by the court to accuse Carey of neglect. These rashes were consistent with a known sensitivity to adhesive backing used in the patches, which are made of 3M bandage material. Instead of recognizing that the marks could have developed while the children were in Mary Ellen’s care, the court falsely equated the adhesive reaction to “child abuse” and escalated it to the same level as striking a child with a hand or object.

The judge concluded that Carey should have ceased using the patches entirely, disregarding that they had been used safely by the children since 2019 and had significantly improved Carey’s own chronic fatigue syndrome. The finding that continued use of the patches was equivalent to abuse was unsupported by evidence and improperly used to justify transferring custody away from Carey and into the hands of the abusive father.

Page 26 – Analysis & Rebuttal

🚨 The court notes that the wishes of the children are currently unknown and no in-camera interview has been conducted. This is a direct failure to assess the best interests of the children under Ohio Revised Code §3109.04, which requires the child’s wishes to be considered.

🚨 The court acknowledges that since February 15, 2022, the children have regularly seen both parents and paternal grandparents. However, testimony and evidence show that Carey was the primary caregiver for nine years prior, with father largely uninvolved until after the domestic violence incident.

🚨 The court characterizes both parties as being in “good physical health,” dismissing Carey’s testimony and evidence of father’s drug and alcohol abuse, including text messages, photos, and financial records showing large cash withdrawals spent on cocaine and alcohol.

🚨 The court ignores evidence of father’s prior hospitalization for suicidal ideation in 2019 and his continued drug use throughout 2021. Instead, it falsely equates both parents’ health when overwhelming evidence shows father’s instability and dangerous behavior.

🚨 Despite Carey testifying that she had no intention of leaving Ohio permanently, the court relies on text messages referencing Florida to claim Carey “clearly intends” to move. This ignores testimony that the family planned seasonal stays in Florida for years, consistent with their past travel and tax planning, not absconding.

🚨 The court places weight on Carey’s family living in Florida while disregarding that father’s parents are local, available, and actively involved. It misrepresents Carey’s testimony by conflating normal family planning with intent to abscond.

🚨 The court emphasizes Carey stopped communication on May 6, 2022, ignoring the fact that this was under advice of legal counsel and while she was protected by a CPO, and that father continued harassment and surveillance during this period.

Page 27 – Analysis & Rebuttal

🚨 The court criticizes Carey for “stopping communication” with father on May 6, 2022, but fails to recognize that communication had become unsafe and that father’s surveillance, harassment, and restricted calls were clear CPO violations.

🚨 The court doubts the Magistrate knew Carey had shared parenting with father during the TPO period, falsely characterizing this as “with no issues.” In reality, father used this period to manufacture his “calendar” of supposed 50/50 parenting, while Carey provided safe, consistent care until forced otherwise by intimidation.

🚨 The court dismisses evidence of surveillance devices, claiming officers found none on May 6, 2022. Yet Carey provided proof of GPS trackers, keyloggers, and text messages from father confirming surveillance. The court instead credits neighbor Gary Nawrocki and Maryellen Zivich, both biased and complicit in surveillance, while rejecting Carey’s corroborated evidence.

🚨 The court concludes “there was no evidence” that father surveilled Carey, an assertion contradicted by Carey’s extensive documented text messages, technical inspection, and father’s own admissions.

🚨 The court states it does not believe Carey was residing in the marital home after May 6, 2022, despite testimony, photographs, and evidence to the contrary. This finding is based solely on neighbor hearsay and ignores Carey’s consistent residency at the home since 2013.

🚨 The court prohibits Carey from applying phototherapy patches on her children, equating them to physical abuse, despite medical evidence that the patches are non-invasive, safe, and beneficial. This decision was based solely on photos taken by Maryellen while the children were in her care, with no proof Carey had applied the patches.

🚨 The court orders children’s passports to be turned over to attorneys Lisa Dean and Sarah Heid, framing Carey as a flight risk, despite no history of absconding and proof she traveled only once internationally for work.

🚨 Custody is awarded to father, a convicted abuser on probation, in direct contradiction of Ohio law that requires denial of custody to a parent convicted of domestic violence where children are at risk.

Page 28 – Analysis & Rebuttal

🚨 The court strips Carey of parental rights, ordering only two hours of supervised visitation per week and two additional hours on weekends, despite her nine years as the sole primary caregiver.

🚨 The court states Carey must schedule supervised visits at “Place of Peace” or a similar facility, placing the burden on her to initiate contact with her children while father retains full custody.

🚨 The court finds it “not a violation” of the active DV/CPO to return the children to the respondent abuser, despite Ohio law and common sense prohibiting returning children to a parent subject to a protection order.

🚨 The order disregards the statutory best-interest factors, including the children’s wishes, history of caregiving, domestic violence, and father’s mental health and substance abuse. Instead, it prioritizes punishing Carey for raising legitimate safety concerns.

🚨 The order is signed by Judge Susan K. Steinhauer, who effectively overturned the magistrate’s protective orders, ignored statutory requirements, and awarded custody to a parent convicted of domestic violence while punishing the safe parent.