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I, , under penalty of perjury of the laws of the State of Washington, certify and declare the following to be true and correct:

I have known The Father/Respondent since June, 1999, when he became a student at the college where I am employed.  He also became a college work-study student employee sometime during his 2nd quarter of attendance at the college.  Prior to the November 10, 2000, incident, I had, on several occasions witnessed The Father/Respondent interacting with his son, at various school functions.  The Father/Respondent always appeared to be very relaxed, patient, loving and communicative with his son.  The Child liked to come into my office and play, turning around on the office swivel chairs, and playing peek-a-boo with me from behind his Dad’s legs.  He always remembered in which drawer to find the treats! As I manage the records office, and am responsible for maintaining the attendance records at the college, I became aware that The Father/Respondent did not attend school on Monday, November 13, 2000.  This was very unusual, as he rarely ever misses school, unless his son was ill.  On Wednesday, November 15, 2000, several students came to me and explained what they knew of what had happened to The Father/Respondent on November 10, 2000.  They voiced their concern regarding The Father/Respondent, and informed me that, as far as they knew, he had nowhere to live, and was possibly living on the streets.  They were concerned that he would have to drop out of school. As in the past I have often offered the vacant upstairs of my home as a rental to other students and employees, I sought out The Father/Respondent, discussed the situation with him, and offered these living quarters to him.  He accepted, and has been living there since November 15, 2000. Since that time we have carpooled to and from work as The Father/Respondent has a suspended driver’s license.  I have provided his transportation to court appearances, interviews and necessary trips so he can do research and file papers, while fighting this case. I also provide his transportation to pick-up and return his son for weekend visits.  His first visitation with his son began on January 19, 2001; it was the first time he was able to see his son since November 10, 2000.

Approximately five days after the November 27, 2000, hearing, and after contacting the Federal Way Police for an escort to the family home for a civil standby, I drove The Father/Respondent to pick up some of his belongings.  We were met by a police officer at the Safeway near his home.  The officer informed us that once we arrived at the home, we would have only twenty minutes to remove everything he was allowed to take.  We were also informed that the decision about what he was allowed to have rested with The Petitioner/Mother.  There would be only one civil standby allowed, so what we could remove that evening was all he was going to receive.  When we arrived at the family home, the officer went to the door and knocked.  The Mother's Accomplice answered it and informed the officer that The Petitioner/Mother was not at home.  He informed the officer that The Father/Respondent’s belongings had been packed, and were in the van in the driveway, and in the backyard storage shed.  The Mother's Accomplice allowed The Child to walk out onto the front porch, and as soon as he saw his Father, he began signing to him, saying, “I love you” and “come in”.  At that time, The Mother's Accomplice physically restrained The Child from running to his father.  The Mother's Accomplice was excessively rough with The Child, bodily picking him up by putting his arm around The Child’s waist and setting him back inside the house.  It was obvious that The Child was confused, and did not understand why he could not go to his Father, who was standing in the street by my car.  He continued to try to come back out onto the front porch.  The Mother's Accomplice raised his voice, and started telling The Child - speaking, not signing – to stay in the house.  Please remember that The Child is deaf.  As The Child still continued to try to come back outside and talk to his Father, The Mother's Accomplice again began forcibly pushing the child back inside the house.  Once The Mother's Accomplice had pushed The Child completely back inside the house, he closed and locked the door from the outside, with a key.  The Mother's Accomplice kept telling The Child, who, of course, could not hear him, to stay in the house and be quiet.  I was extremely concerned that he had locked a four-year-old deaf child inside the house – alone, confused and unsupervised. 

Understandably, The Father/Respondent was also upset, having just witnessed The Mother's Accomplice man-handling his son, bodily picking him up, pushing him through the door, and locking him in the house alone.  The Mother's Accomplice had made no attempt to console The Child, or explain to him why he was not allowed to see his Father.  Of course, The Mother's Accomplice cannot sign.  The Father/Respondent asked the officer if he would please tell The Mother's Accomplice to stop treating his child in this manner.  The officer refused; he stated that he saw nothing inappropriate in the way The Mother's Accomplice had handled and treated the child.  The Father/Respondent pointed out to the officer that The Child is deaf, and did not understand what was happening.  The officer did not care.  The Father/Respondent then asked the officer if he would write a statement as to what had just happened, and the officer flatly refused.

After locking The Child in the house alone, The Mother's Accomplice unlocked the van and the backyard shed, and began carrying items out and putting them in the driveway.  One of those items was The Child’s computer, which The Father/Respondent had previously built for his son.  This was so that he could learn visually, that which he could not learn audibly and verbally.  The Father/Respondent wanted The Child to have his computer to aid in his education, but The Mother's Accomplice decided he would not allow it to remain in the home.  He insisted that The Father/Respondent remove the computer.  Further, of the other computers that he was allowed to remove, those that had been fully operational when he had been forced from his home, had been opened, and it was immediately apparent that they showed obvious signs of malicious and intentional tampering.  The cases had been removed and were still loose; one actually fell off in the driveway.  Coincidentally, this happened to be the computer that The Petitioner/Mother knew The Father/Respondent had just finished rebuilding and planned on selling.  He was not allowed to have most of his personal belongings.  We loaded what we could into my small car in the short time allowed, and left.  Items that he still needs for school; tools, which he needs for his job, computer parts and software; as well as many other personal belongings and vehicles still remain at the family home. 

I have also witnessed several incidents at the Kent Regional Justice Center.  The Father/Respondent tried on several occasions, both on the phone in my office at the college, and in-person at the RJC, trying to obtain copies of the Family Court Services file on the investigation which was being performed.  He began immediately after the December 18, 2000, interview with Ms. Rosie Anderson, Social Worker, Family Court Services, which was nearly four weeks prior to the January 17, 2001, hearing, so that he could have an opportunity to properly prepare for the upcoming hearing.  He completed the mandatory application necessary to receive the documentation on three separate occasions before he finally received the documents.  Each time, he was told that they had never received the application.  I was present during all of these phone calls and visits to Family Court Services.

I was also witness to the fact that he submitted all his personal reference statements, as well as his declaration and supporting documentation as requested to Family Court Services, in my presence, when he arrived for his appointment with Ms. Rosie Anderson on December 18, 2000.  I witnessed The Father/Respondent asking Ms. Anderson if he should submit these documents to the court himself, and she assured him that it was not necessary, and they she would see to it that they would be properly submitted. When we later went to the Court Clerk’s office to obtain copies of everything, these reference statements were conspicuously missing from the file in the Court Clerk’s office.  These records were never submitted to the court as promised by Ms. Anderson, and were apparently never taken into account in the assessment which was prepared by Family Court Services, and submitted to the court on January 17, 2001.  This assessment was obviously biased, and contained none of the items submitted on by and on behalf of The Father/Respondent.

I have also witnessed The Father/Respondent receiving statements from his references stating that Ms. Anderson never contacted them at any time during her “investigation”.  I have been present on numerous occasions when The Father/Respondent has filed papers in the Court Clerk’s office.  On January 26, 2001, he filed papers for his upcoming hearing on his Motion of Revision, which was originally scheduled to be heard on February 9, 2001.  That same day, he delivered judge’s working copies to Room 2D at RJC.  On February 2, 2001, additional papers were filed which were to be included in the record, and these were also delivered to Room 2D.  I was present when he arrived for his hearing on the Motion of Revision on February 9, 2001.  The bailiff informed us that the judge had not yet looked at the videotapes of the two prior hearings, and so The Father/Respondent surrendered his copies of the videotapes to the bailiff for the judge’s review.  The hearing was then postponed until February 20, 2001.  At that hearing the judge stated that The Father/Respondent’s Motion for Revision had not been properly filed, that there was nothing in the court clerk’s file relating to this motion, and that no judge’s working copies had ever been delivered for his review.  All of this is untrue.  I was witness to the filing of the motion in the RJC Court Clerk’s Office within the 10 day deadline following the January 17, 2001, hearing, and to the delivery of the judge’s working copies being delivered to Room 2D in the RJC.  When the judge stated that nothing was in the file, The Father/Respondent asked to be allowed to provide the court with another set of dated copies of everything that had been filed.  The judge refused, and denied the motion.

I have also been present when The Father/Respondent placed calls from my home to The Paternal Uncle.  In The Paternal Uncle’s statement to Family Court Services, he falsely states that The Father/Respondent threatened to make The Petitioner/Mother’s life “a living hell”. There was never any such statement made.  At one point, The Father/Respondent did state that he had to end the conversation.  He said, “ I have to go now.  I’m really upset about all this…I don’t understand why she’s doing this.  It’s making my life hell.”  The Father/Respondent was understandably upset; his entire life had just been torn apart.  As of that time, he had not been allowed to see his son.  He didn’t understand what was happening, or why.  But at no time did he ever make any threatening statements towards anyone. I have now known The Father/Respondent for nearly two years, and he has been living in my home since November 15, 2000 - for four months.  I have seen him extremely upset at times, over the obviously well planned, cruel and calculated attempts to tear him from his son’s life.  The very night The Father/Respondent was forced from his home, the mother moved The Mother's Accomplice, her lover of two years, into the family home. In the beginning, The Father/Respondent was broken-hearted at the thought that he was never going to see The Child again.  But, even during all of this, when most people would have given up and lost control, I have never seen any sign of unmanageable anger or violence.  I doubt many parents could have handled this horrendous situation any better than he if they thought that they had lost their child forever.

I have been present when The Child comes home for his weekend visits with his father.  During the drive from The Child’s daycare to home, he, literally, never stops talking/signing to his Dad.  His little hands are going 100 miles per hour.  The Father/Respondent spends every minute of those weekend visits with The Child.  They read together, go for walks to the grocery store or 7-11 together, walk to the park and the ice-cream parlor together, play video and computer games together and watch TV together.  Sometimes, they just sit and snuggle and talk to one another.  They even play baseball games in the living room!  They are starting to meet other families with children in the neighborhood, and have been invited to go to story-time for children at Border’s books, where the stories are signed, and The Child can interact with other children his age – both hearing and deaf.  They never get more than ten feet apart during the entire visit.  Where you find one, you find the other.  They are very affectionate with one another.  With the exception of sleeping time, I am present for nearly all of the time they spend together.  I have rarely seen a father be more loving and gentle with a child.  The Child has never seemed upset or even anxious during these visits.  In fact, the only times when he becomes upset, is when we drop him off at the daycare when the visits are over.  He clings to his father, and does not want to let him go.

I have been a parent for 25 years, a grandparent for 21 years, and a licensed foster parent in Pierce County in the State of Washington.  I have dealt personally with the issue of domestic violence and abuse of every imaginable kind for many years, including that which I suffered during my own childhood, and, unfortunately, that which my children and I suffered during my marriage from 1974 until 1992.  Personally, I have dealt with violence in the home most of my life.  As a survivor of abuse, a mother of three children that are also survivors of abuse and a volunteer with Good Samaritan Mental Health Center in Puyallup, Washington, I have worked diligently to help put an end to domestic violence.  In my experience, violent people react to even the most trivial and insignificant things in a violent way.  Even though The Father/Respondent has been forced from his son’s daily life and spent Thanksgiving, Christmas and New Years –ten full weeks without even being allowed to visit his son - I have seen pain, but no violence, and no loss of self-control.  He has shown my family and me nothing but the utmost respect in the nearly two years that I have known him.  And in turn, I have given him the respect and trust to allow him to live in my home and spend time with my 12-year-old daughter and my 21-year-old granddaughter, both when I am home, and when I am not.  I would have never invited The Father/Respondent into my home if I suspected there was even the slightest possibility that he might be a violent or abusive person.

The Father/Respondent is attending college, and doing everything possible to make a better life for The Child.  In the two years that I have known him, it has become obvious that he has devoted his life to loving, caring for, and providing a better life for his son. The Child attends school in the Puyallup School District near my home.  The Father/Respondent has been instrumental in convincing the District to provide necessary services, such as sign language classes, to the parents of deaf children. His schedule at work and school can be very flexible, and it appears that he has far more time to spend with The Child than does the mother.  He has only The Child to think about, and is totally devoted to him.  He is not involved in any other relationships, as is the mother.  The Father/Respondent has made caring for The Child and finishing college his only priorities.  Please don’t let the mother’s attempt to destroy the relationship between this Father and son, just so that she can be with her lover, be condoned by the Court. There should be no hesitancy; The Father/Respondent and The Child deserve to be together. In my expert opinion, The Father/Respondent is a wonderfully loving parent.  The Child needs as much time with his Father as possible so that he can grow up to be a strong, independent and self-sufficient young man.  He and The Child obviously love each other very much and should not be kept apart any longer. 

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