PO Box 100212
Arlington, VA 22210
202 657 5793
509 356 2789 (Fax)
Roy Morris@alum.mit.edu
Member of the Bars of the:
District of Columbia and
United States Supreme Court
(Not a member of the Virginia Bar)
December 20, 2010
Donald Curry,
Counsel
Judicial Inquiry and Review Commission
P.O. Box 367
Richmond, Virginia 23218-0367
Re: Documentation Regarding Opposition to Reappointment of Judge Esther Wiggins (JDR Arlington)
Thank you for the privilege of speaking at the annual Judicial Interviews in Richmond on December 10,
2010 before the Courts of Justice Committees of the Senate and the House. As the Committees requested, I am
supplementing my remarks opposing the reappointment of Arlington JDR Judge Esther Wiggins with additional
supporting documentation,1 specific transcripts from hearings before Judge Esther Wiggins, recent local newspaper
articles publicizing the problems caused by Judge Wiggins [Wiggins-COJ-19 through 26] 2, corrections to some of
the misstatements of Judge Wiggins in her answers before the Committee, and documentation of the damages
caused by the serious failures and misdeeds of Judge Wiggins – namely one seriously ill seven year old child, and
the destruction of her family in her JDR Court (even though the husband and wife remain married to this day)..
A copy of my remarks from December 10, 2010, “Judge Wiggins: Deriving Pleasure from the Pain of
Mothers,” is found attached to this letter as Attachment I. As pointed out in my remarks, Judge Wiggin’s cases
1
List of the 437 pages of Exhibits and Page References can be found at Attachment II.
2 References to Exhibits to this Letter are noted as “Wiggins-COJ-XX”.
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
follow a pattern of devaluing the mother, and then using that degraded characterization to justify her actions of com-
pletely eliminating the mother from the child’s life. Her genocide approach to natural mothers is systematic, and
was followed in the well-publicized cases of Naomi Parrish, Nancy Hey, Benita Washington, and Dr. Ariel King.
I will focus here on the nine month long case, Michael Pfeiffer (Husband/Father) v Dr. Ariel King
(Wife/Mother), which was before Judge Wiggins. I personally attended all the hearings except the one on June 6,
2008 (however, I have reviewed and provided the transcript for that hearing, thus my knowledge is complete regard-
ing all matters that occurred in that case). In that proceeding, Judge Wiggins awarded full legal and physical custo-
dy to the father in an ex parte hearing, even though:
a) Judge Wiggins had not heard any testimony from the Husband/Father in the nine months of hearings,
yet still gave him full legal and physical custody of the child,
b) Judge Wiggins had not received a full psychological from the Husband/Father (even though he was or-
dered to provide one),
c) Judge Wiggins never talked to the child or had seen the child or seen the child with the Hus-
band/Father,
d) Judge Wiggins gave full legal and physical custody to the Father on June 6, 2008 even though a Mary-
land Circuit Court Judge on June 2, 2008, who was the only Judge who had interviewed both the child
and the mother in a hearing, had entered a Temporary Protective Order where he found evidence to
suspect sexual and physical abuse, and medical neglect of the 5 year old daughter, and stalking by the
Husband/Father of his Wife,
e) Judge Wiggins took no testimony or evidence on whether such an award of custody to the Father had
met the statutory requirements for awarding custody under Virginia law; and, as demonstrated by her
having to be corrected in the June 6, 2008 hearing, Judge Wiggins clearly did not know what that
standard was.
f) Judge Wiggins award of custody to the unknown father ignored the only custody study done by the
Court officer, Michele Woods. In that custody study Ms. Woods recommended that custody be jointly
awarded to both the Wife/Mother and the Husband/Father, and that full physical custody of the little
girl to remain with the wife/mother – who had been the primary caregiver of the child up until that
point in time,
g) Judge Wiggins never looked into the concerns raised by Michele Woods that the father was living in a
one bedroom apartment, sleeping with the small five year old child in a queen sized bed that the Father
bought especially for the child,
h) Judge Wiggins allowed the unconstitutional malicious questioning of a Nancy Hey, who was in the au-
dience at the June 6, 2008 hearing, as an impromptu witness even though that Ms. Hey, whose child
was previously taken away by Judge Wiggins, demanded that she have an attorney present, and
i) Judge Wiggins entered two conflicting custody orders on the same day (June 6, 2008), marking one as
“final” while the other is “temporary”.
j) Judge Wiggins was given information in the docket that the Wife/Mother had met the conditions of
both conflicting orders but Judge Wiggins took no action to resume the Mother’s physical custody of
her then 5 year old daughter and has taken no action to reunite the child with the only mother she has
ever known, even though there has never been a finding by Judge Wiggins (or any other judge) that the
Mother poses any harm or potential harm to the child.
k) Judge Wiggins took the case in JDR court, and failed throughout to take into consideration that the
parents were and remain married.
l) Judge Wiggins failed to take into consideration that, at the time of his being awarded full legal and
physical custody, the Father was unemployed, had been denied a medical license in Washington DC
for inability to provide a valid medical school transcript from Germany. Judge Wiggins did not know
these material facts because when she granted the Father custody, she had never placed the Father on
the witness stand nor allowed the taking of his testimony.
In sum, Judge Wiggins routinely operates outside the law in a closed courtroom. She consistently and
systematically devalues and then eliminates nurturing loving mothers from their children’s lives. In the case of
Pfeiffer v King, Judge Wiggin’s actions have caused the child to be in the custody of a Father who has had several
protection orders against him because of concerns of safety of the child, and has been highly suspected by a Mary-
land Circuit Court Judge of sexual and physical abuse. Moreover ever since the child came into the Father’s physical
custody the child has suffered from the potentially fatal severe chronic neutropenia (i.e., critically low immunity,
2
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
like that suffered by those with AIDS) that experts now believe, based on test results to date, is “induced by tox-
ins”/drugs used to facilitate and cover up abuse. The child’s untreated condition is life-threatening and so severe
that the German Embassy has appealed to the father (who is a German citizen) to get an independent medical exam-
ination of the child (who also holds German citizenship) to get her a proper diagnosis and GCSF, the only lifesaving
medicine for severe chronic neutropenia, The aberrant Father has refused the pleas of his own German government,
and thanks to Judge Wiggins, he feels immune in the US from having to answer to his own Government. The Fa-
ther continues to do defy his own German government to the detriment to the health and well being of a now-7 year
old little girl. [Wiggins-COJ-430]
The Pfeiffer v King case suffered from irregularities of Judge Wiggins Court from the very beginning. The
case was filed in Virginia in August 2007 by Michael Pfeiffer (a German citizen on a visa that expires 2012). At
that time and to this day, Dr. Pfeiffer was and continues to be the husband of child’s natural mother, Dr. Ariel King.
The couple had lived in Maryland until Dr. Pfeiffer had abandoned the marital home and moved to Washington DC.
Michael Pfeiffer left Dr. King and their child, Ariana-Leilani, penniless and without a home in June 2007.
Before filing his Virginia custody case in August 2007, a temporary protection order was issued in July 2007
in Washington DC against Michael Pfeiffer as a result of his attack on both Dr. King and their daughter at a recep-
tion held at the Zambian Embassy for the Ariel Foundation International (See, TPO at Exhibits at Wiggins-COJ-
54).3 In retaliation in July 2007, Pfeiffer filed in Washington DC for divorce and full custody of their then 4 year
old daughter. Pfeiffer had falsely claimed in his Washington DC custody/divorce complaint that his wife, Dr. King
was a resident at the Zambian Embassy. The DC Superior court dismissed Pfeiffer’s case for lack of subject matter
jurisdiction because no party had lived in Washington DC for the required six months. [Exhibits at Wiggins-COJ-
34] At the dismissal hearing, both parties agreed that Maryland was the child’s “home state.” 4
While Pfeiffer had his Maryland counsel negotiating a “parental agreement”, Pfeiffer hired a Virginia attor-
ney to secretly file a custody complaint in Virginia in August 2007, only 29 days after Dr. King had sought emer-
gency housing and safety (that did not require a substantial deposit) for herself and her daughter in Arlington Virgin-
ia. As of the date Father’s filing in Virginia, neither party had satisfied the six month residency requirement for ei-
ther divorce or custody jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA).
[Exhibits at Wiggins-COJ-27, - 30, and - 59] Dr. King, the Mother, and her child had remained legal residents of
Maryland, where she returned with her child less than three months later (October 2007).
Ignoring the Lack of “Subject Matter Jurisdiction,” Judge Wiggins Refused to Dismiss the Custody Case in
JDR Court of this Married Couple, None of Whom Had Lived in Virginia for the Required Six Months.
Judge Wiggins never had a hearing to take evidence as to whether Virginia had jurisdiction to hear the case.
Instead, Judge Wiggins prematurely held an impromptu premature hearing on September 5, 2007 prior to the date
set by the Petition of September 6, 2007 (See, Original Summons, attached hereto at Wiggins-COJ-27 and compare
to date of September 5, 2007 Initial Custody Order, attached hereto at Wiggins-COJ-37, which contains no finding
of subject matter jurisdiction). The parties were led to believe that the September 5, 2007 hearing was solely for the
purpose of postponing the September 6, 2007 hearing date (which was unilaterally set by the Father in his Petition)
to provide more time to respond. As a result of the premature hearing, the Mother and her attorney were not pre-
pared to respond to the Husband’s custody petition at the September 5, 2007 hearing, to make proper argument, nor
to prepare testimony or give evidence that Virginia did not have jurisdiction.5 Subject matter jurisdiction can nei-
3
As a result of the violent incident on July 7, 2007 at the Zambian Embassy, in Washington, DC the US Se-
cret Service (who had responded to the incident) advised Dr. King to obtain a Temporary Protective Order for their
daughter and herself against her husband, Michael Pfeiffer.
4
Dr. King’s counsel told the DC Superior Court that the couple could not be divorced in Virginia, because
"nobody has been there for six months." DC Aug. 1, 2007 Transcript at 19 and 23. He also pointed out that six
months is also required for establishing Virginia as the "home state" for subject matter custody jurisdiction under the
UCCJEA. Counsel for both parties agreed that six months was required for Virginia to be the home state, and that
the child's home state was Maryland. DC Aug 1, 2007 Transcript at 18-19, -23.
5
See, e.g., Burdick v. Brooks, III, 160 Md. App. 519; 864 A.2d 300 (2004).
3
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
ther be consented to nor waived by the parties or the court.6 Thus, it is a fundamental rule that no custody case
can proceed until jurisdiction is established, which Judge Wiggins clearly failed to do.7
Judge Wiggins Failed to Recognized that, Even if Original Jurisdiction were Present in August 2007, Virginia
Lost Continuing Jurisdiction Automatically in October 2007 When All Parties No longer Lived in Virginia”
Furthermore, even though the Wife/Mother and child quickly returned to Maryland in October 2007, and the
Father was still living in Washington DC, Judge Wiggins refused to recognize that under Virginia law it automati-
cally lost “continuing jurisdiction” when all parties had left the state in October 2007. In February 2008, the Wife/
Mother’s attorney, Mr. Miller, brought this legal fact to Judge Wiggin’s attention, and the Court refused to address
its lack of continuing jurisdiction:.
MR. MILLER: Before we get into that, though, Your Honor, we kind of eased into this visitation matter.
This Court, under 20-146.13 has lost exclusive continuing jurisdiction.
THE COURT: I’m not hearing a jurisdiction motion here. I ordered the mother to return the child to the fa-
ther.
MR. MILLER: And the previous motion was regard to subject matter jurisdiction, whether or not --
THE COURT: I’m not hearing a motion to dismiss. That’s not before the Court. I’m not going to hear it.
MR. MILLER: But the Court has modified its visitation and custody order, which it can’t do because under
146.13 when the parties left the Commonwealth of Virginia lost continuing exclusive jurisdiction.
…
MR. MILLER: But the statute doesn’t --
THE COURT: I’m not arguing with you about this. I’ve already ruled. The case is still pending here. The
Court ruled that the Court had jurisdiction to hear the case. The case is still pending; we have not come to a
conclusion in this case. This Court is going to maintain jurisdiction in the case.
Judge Wiggins ruling was not only substantively wrong, it was procedurally incorrect because, by law, ques-
tions of jurisdiction are required to take precedence over all other matters. 8
[Note For Correction to Judge Wiggins Representation at the December 10, 2010 Judicial Interviews:
The Court’s initial custody order specifically permitted the free movement of the Mother and child anywhere in the
Washington DC metropolitan area. No permission of the Court was required for her to move back across the river to
Maryland. Thus, the Mother and child were free to move back to their “home state” of Maryland without violating
any order or rule.]
Judge Wiggins Ignored the Father’s Sleeping in the then Five Year Old Child’s Bed in her Windowless “Bed-
room” in His Cramped Walkup “ Small Student Apartment” in Washington, DC
Soon after overnight visitation with the Father began, the child started to show severe behavioral changes
(peeing in pants, biting herself, seeing “bumble bees”, stating she was scared at her father’s house). The then four-
year-old child disclosed to the Court’s appointed social worker Michele Woods that the father was sleeping in the
child’s queen sized bed (an oversized bed that the father had specially bought for the small five year old child to
sleep in [see, photo at Wiggins-COJ-33]) over the protests of the child.9 Michele Woods documented in a reported
signed on October 24, 2007 the child’s disclosure in her report to the Court:
“This counselor feels it is also important to relay to the Court that [the child] has also made several com-
ments to this counselor that her father [Dr. Pfeiffer] comes into her bed at night….this counselor would
6
[T]he record is never conclusive as to the recital of a jurisdictional fact, and the defendant is always at liber-
ty to show a want of jurisdiction, although the record avers the contrary. If the court had no jurisdiction, it had no
power to make a record, and the supposed record is not in truth a record." Slaughter v. Commonwealth, 222 Va.
787, 793, 284 S.E.2d 824, 827 (1981) (citation omitted). "[A]ny subsequent proceeding based on . . . a [jurisdiction-
ally] defective judgment is void or a nullity." - Morrison v. Bestler, 387 S.E.2d 753, 755-56 (1990)
7
The UCCJEA requires that any petition for custody have in its certain sworn statements establishing custody
jurisdiction. The Father’s custody petition specifically stated facts that prima facie established Maryland as the
child’s home state.
8
Virginia Code § 20-146.6. Priority. If a question of existence or exercise of jurisdiction under this act is
raised in a child custody proceeding, the question, upon request of a party, must be given priority on the calendar
and handled expeditiously.
9
According to Michele Woods reports, “This counselor feels it is also important to relay to the Court that [the
child] has also made several comments to this counselor that her father [Dr. Pfeiffer] comes into her bed at
night….this counselor would hope the Dr. Pfeiffer would stop this behavior and understand that it is not appropriate
considering his daughter's age.” See, Report of Michele Woods, November 8, 2007 (Wiggins-COJ-01)
4
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
hope the Dr. Pfeiffer would stop this behavior and understand that it is not appropriate considering his
daughter's age.”
The child gave information to a pediatrician that corroborated the independent disclosure of the child to the Michele
Woods. The Mother asked the Court to address this problem immediately through reconsideration of the initial
“overnight visitation” schedule in an Emergency Motion, filed on October 3, 2007. (See Emergency Motion
Petition, (See, Wiggins-COJ-40)). Subsequent forensic interviews confirmed the father continued his practice as a
result of Judge Wiggins failing to take action. [See, Maryland Forensic Interview, Wiggins-COJ-329A] Judge
Wiggins refused to schedule a hearing on the Mother’s Emergency Motion despite the compelling evidence that the
Father was sleeping in the child’s bed, and was suffering severely from the arrangements set forth in Judge Wiggins
Initial Custody Order. As a result, the child has unnecessarily suffered years of great psychological stress , and is
now diagnosed with Post Traumatic Stress Disorder, from the father regularly entering her bed, suffered from
nightmares, wetting her pants, biting herself and seeing “bumble bees.”
Judge Wiggins Spent All of the Hearing Sessions Focusing on the Mother, Ignoring the Father, and Never
Meeting the Child, as Illustrated by the February 8, 2008 Hearing, Where The Mother Is Found In Contempt
of the Mother Without Taking Evidence, and Refusing to Allow Evidence:
On February 8, 2008, Judge Wiggins refused to take evidence before finding the mother in contempt based
on the ambiguous accusation of being “uncooperative” with the GAL, based solely on proffers of the GAL. The
Mother’s attorney protested that the law required an evidentiary hearing.
THE COURT: All right, let me advise the mother of the rules. All right, Ma’am, would you please stand?
It’s alleged that you are in contempt of Court by failing to comply with a specific visitation schedule. It’s
also alleged that you are in contempt of Court for not cooperating with the Guardian ad Litem and that you
are in contempt of Court for not cooperating with the custody evaluation. Why shouldn’t you go to jail
today?
MR. MILLER: Your Honor, she shouldn’t go to jail until we’ve had evidence on the matter and up until
now we haven’t had any evidence.
THE COURT: The Court can do a summary contempt.
MR. MILLER: No, they can’t, Your Honor.
THE COURT: Why not?
MR. MILLER: Because summary contempt is only on several specific instances.
THE COURT: Yes.
MR. MILLER: Summary contempt is authorized and
we do not have that today.
THE COURT: Violating a Court order.
MR. MILLER: Looking at Virginia Code 18.2-456.
THE COURT: Right.
MR. MILLER: It says cases in which Courts and judges may summarily, or may punish summarily for con-
tempt is Courts and judges may issue attachments for contempt and punish them summarily only in the fol-
lowing cases: misbehavior in the presence of the Court, violence or threats of violence to a judge or
office of the Court, vile, contemptuous or insulting language addressed to a judge, misbehavior of an of-
ficer of the Court, or disobedience or resistance of an officer of the Court. Violation of a Court order is not
within those statutory factors under 18.2-456.
THE COURT: Well, what about disobedience and resistance of an officer of the Court, jury, witness or
other persons of any lawful process, judgment, decree or order of the Court? You left that part out.
MR. MILLER: It’s a disobedience to the person.
THE COURT: It’s a disobedience of the order of the Court.
MR. OLIN: I would just say that I am an officer of the Court and --
THE COURT: Right, so I don’t think that I couldn’t, under the statute, find her summarily in contempt of
Court.
MR. MILLER: Well, with --
THE COURT: I mean, that’s what the statute says.
MR. MILLER: Well, no, it’s a disobedience or resistance of an officer of the Court, a juror or a witness or
other person to lawful process. She hasn’t --
THE COURT: To lawful process or order, judgment, decree or order of the Court.
MR. MILLER: Right.
THE COURT: You leave out that part.
MR. MILLER: Right, but it has to be the person or other lawful person.
THE COURT: I guess I’m not understanding your point.
MR. MILLER: Well, how can you find that there’s been disobedience or resistance to an officer of
5
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
Despite being presented with the statutory language and citation otherwise that the Court cannot hold the
Wife/Mother in contempt based solely on ambiguous proffers of the GAL, Judge Wiggins stood by her unlawful and
illogical conclusion that she could find summary contempt for actions that took place outside the courtroom without
taking any evidence. Such actions by Judge Wiggins illustrate her disregard for the rights of the parties and the law
of Virginia.
In an adulterated order with a typed in ordering clause, Judge Wiggins transferred primary physical custody
to the Father, away from the Mother. [Wiggins-COJ-123] Judge Wiggins made this change to punish the Mother
(an only child) for going to the ICU hospital bedside for two weeks of her own gravely ill mother (who had a poten-
tially fatal brain hemorrhage) in Atlanta, Georgia. Judge Wiggins condemned the Mother for taking this loving,
responsible and humanitarian action. Judge Wiggins falsely claimed that it violated the Initial Custody order even
though that order specifically provided that the Mother was allowed to take the child to Atlanta, Georgia, even in
non-emergency situations. [See, Initial Custody Order, Wiggins-COJ-37]
Judge Wiggins stated in the hearing that the child would be returned to the previous arrangement of primary
physical custody with the Mother when the Mother a) returned from caring for her own sick mother in Atlanta,
Georgia and b) began a psychological exam (which both parents were required to undergo). However, the adulter-
ated order issued by Judge Wiggins failed to state that fact, making it sound more permanent. Compare the “typed-
over” ordering clause of the February 8, 2008 Order [Wiggins-COJ-123] which is clearly inconsistent with Judge’s
oral directives in the February 8, 2008 Transcript at 53 (Wiggins-COJ-115) [“Like I said, if the Mother comes back
to the area and can provide verification as to where she is going to be living and she started a psychological, I will
6
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
Arbitrarily Transferring Custody Again to the Father (Who Continued to Sleep In the Child’s Bed)
Based on Bogus Claims of Failure to Properly Inform the Court Several Days Earlier that Conditions Were
Met. After the Mother met all the conditions and brought her own mother back to Maryland to provide her with
24-hour care, and rehabilitation, the Wife/Mother, with advice of her counsel, picked up their daughter. On Febru-
ary 21, 2008, Judge Wiggins would not even allow the mother to testify on her own behalf about how she satisfied
the conditions imposed on February 8, 2008. Judge Wiggins even entered an order that date that falsely stated she
had taken evidence at the hearing, when in fact she clearly had not. [Transcript, February 21, 2008 at 48-49 [Wig-
gins-COJ-173-174]] When this discrepancy was brought to Judge Wiggin’s attention, she laughed but did not cor-
rect it.
Judge Wiggins again – without allowing witnesses or taking any evidence, including the recording of the 911
call and the missing of several days of the German School, once again transferred “Temporary Full Custody” back
to the Father. Judge Wiggins gave custody back to the Father even though Judge Wiggins still had not taken up the
October 2007 Emergency Motion, which raised questions about the Father sleeping in the child’s bed, and taking her
to men’s bathrooms, Ms. Wood’s November 8, 2007 report reported that such sleeping in the child’s bed by the
father was taking place. (See, Transcript, February 21, 2008 Hearing, Wiggins-COJ-126)
Judge Wiggins Was Not a Neutral, but Took Sides, Including Coaching the Father’s Attorney On How
to Question the Wife/Mother on the Witness Stand During Rules to Show Cause Hearing and Allowing the
Same Attorney to Dismiss the Father from the Hearing to Prevent Him From Taking the Witness Stand: On
April 8, 2008, the Judge Wiggins aided and guided the Father’s counsel on how to question the Mother on the wit-
ness stand. [See, April 8, 2008 Transcript, Wiggins-COJ-189] The trial judge refused to listen to or allow the
Mother to present a police 911 emergency call tape of the incident (where the child is screaming, crying and banging
to escape from the fathers one bedroom apartment). Without hearing the tape, Judge Wiggins concluded the 911
tape did not come within the business records exception to the “hearsay rule,” and nor did it contain an “excited ut-
terance” of the child as she desperately tried to get away from her Father who unexplainably kept the child at home
on a day that was both a work day for him and school day for the child:
Judge Wiggins also ignored that the Father had inappropriately kept the child captive at home for three
school days, when she was supposed to be at school. In addition, Judge Wiggins after swearing her in on the wit-
ness stand, refused to allow the child’s Grandmother (Dr. Margo King) testify about the seriousness of her own ill-
ness and hospitalization in Atlanta, Georgia; which was the focus of the rules to show cause that were at issue
against the Wife/Mother. (See, Transcript, April 8, 2008 Hearing, e.g. at 84-93, and 97-105, Wiggins-COJ-272
through - 293)
Once again, as she did throughout the case, Judge Wiggins did not require the Father to take the stand to
testify as to why it would be in the best interests of the 4-year-old girl that he have custody of the child.
7
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
Four Days After A Temporary Protection Order Was Issued By a Maryland Circuit Court Against the
Father for Evidence that gave Suspicion of Sexual Abuse, Physical Abuse and Medical Neglect of the Child
and for Stalking of the Mother/Wife, Judge Wiggins Issued Two Conflicting Orders, Based Solely On Prof-
fers of the Father’s Attorney), Unlawfully Giving Full Legal and Physical Custody to the Husband/Father
(Who Had Never Testified) and Prohibited the Wife/Mother’s Contact with Her Child:
i) Judge Wiggins held an ex parte hearing despite two motions for continuance filed by the Mother (Pro Se),
and the Court failing to issue subpoenas for the Mother’s witnesses, [See, Motions to Continue, Wiggins-COJ-340
ant Wiggins-COJ-346]
ii) Judge Wiggins showed her bias when she stated her unequivocal prejudicial belief – based on nothing in
the record that she believed that Mother was a member of a “bashing Judge Wiggins group.”10 Judge Wiggin’s in-
terjection of this bizarre fact was not supported by any evidence presented in the case, nor did she suggest she came
to that conclusion based on any evidence in the record in the case. (See, Transcript, June 6, 2008 Hearing at 28-
33, Wiggins-COJ-365 through -368)
iii) without legal authority, Judge Wiggins vindictively gave legal and physical custody of the five-year-old
child to the Husband/Father (who still had not testified in Judge Wiggin’s court, and for whom the sleeping in the
daughter’s bed had not been addressed by the Court) and barred all communications with the Wife/Mother. Judge
Wiggins came to this draconian outcome based solely on proffers of the Father’s attorney and hearsay testimony
from the only one person in the JDR court (Michele Wood), whose testimony was limited to hearsay statements
about what she heard at another hearing in a Maryland court the prior day. At the time of the hearing, Judge Wig-
gins clearly did not know what provisions of the statute applied to the determination of custody, nor had she taken
evidence to support any of the “factors” that the statute sets forth. (See, Transcript, June 6, 2008 Hearing at 52-59,
especially 59, Wiggins-COJ-395)
iv) Judge Wiggins entered two conflicting custody orders, (with one noted as being “final”) despite the fact
that no notice was given that a “final” custody hearing was to take place on June 6, 2008. [Wiggins-COJ-397
through -398] The only prior notices for a hearing on June 6, 2007 received by Wife/Mother (who was pro se) were
for two motions filed by the Wife/Mother (a motion for mediation, and a motion for reconsideration of the February
18, 2008 temporary custody order) to be heard on June 6, 2008. The notices did not indicate that any “final” custo-
dy order was to be entered on that date.
v) Judge Wiggins entered the two conflicting orders, even though Judge Wiggins had never spoken to or met
the 5 year old child, or had never heard the Husband/Father on the witness stand at any time during the nine months
of hearing (none of which focused on either the 5 year old child, or the qualifications of the Husband/Father). In
addition, the Father had never completed the co-parenting classes, or produced a full psychological exam that she
ordered (while the Wife/Mother had completed both). In addition, only days before, a Maryland Circuit Judge, who
is the only Judge who had seen and spoken to the child, concluded that there was strong evidence to believe the
father was sexually and physically abusing and medically neglecting the 5-year-old girl. Judge Wiggins ignored
that the Maryland Court had ordered a full Child Protection Investigation, which was blocked by the Father through
his attorney before the CPS of Montgomery County Maryland had an opportunity to interview the father.
5) Judge Wiggins never scheduled a hearing for the Motion for Sanctions filed against the Father’s attorney
and the GAL for their direct violation of Dr. Margo Kings (child’s grandmother) Medical Information and the Illegal
Manipulation of the Family Tragedy. (See, Motion For Sanctions And To Strike Pleadings By Petitioner, Motion
For Sanctions Against The Guardian Ad Litem, Motion To Dismiss The Guardian Ad Litem, Motion To Reopen
Motion To Show Causes Regarding Dr. Christopher Lane, The Guardian Ad Litem And February 8 2008 Order,
filed with the clerk of the JDR Court on June 9, 2008, Wiggins-COJ-399.)
6) Judge Wiggins was requested to recuse herself from the case, but ignored that motion and never ruled on
it. [Wiggins-COJ-418]
7) Judge Wiggins vindictively allowed the spur of the moment calling of Nancy Hey (who was simply in the
10
MS. OLIN: Tell me, was this sort of a custody support group, or what kind of support group was it?
THE COURT: It was a bashing Judge Wiggins group is what it was.
MS. OLIN: Oh, really?
THE COURT: Yes. It's a fan club to me. Isn't that what it was?
- Transcript June 6, 2008, See, Wiggins-COJ-365 through -368
8
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
audience to observe the hearing) to the witness stand at the June 6, 2008 hearing in violation of her constitutional
rights to an attorney, Judge Wiggins spitefully ignoring her objections to have her counsel present, and allowed her
to be maliciously questioned on private and potentially incriminating matters unrelated to the case. [See, June 6,
2008 Transcript at 18-44]
MR. O'CONNELL: Can we put her on the stand and you ask her some questions?
MS. OLIN: Absolutely. Ma'am, please take -- with the Court's permission.
THE COURT: Is this a witness?
MS. OLIN: Yes.
MS. HEY: Okay. Well, I wasn't scheduled to be on the stand. I was just here as a friend of the mother.
MS. OLIN: You're here, and we're requesting you to take the stand.
MS. HEY: Well, I don't have a lawyer here.
MS. OLIN: You don't need a lawyer to be a witness.
THE COURT: All right. Ma'am, will you raise your right hand.
Whereupon --
NANCY HEY,
a witness, called for examination, having been first duly sworn, was examined and testified as follows:
[Judge Wiggins then allowed Nancy Hey to be questioned for approximately 15 more pages]
In the December 10, 2010 Judicial Interviews, Judge Wiggins attempted to justify her disregard for the right
to an attorney for Nancy Hey because “she was a witness.” However, Judge Wiggins’ erroneous legal conclusion is
not supported in law and is in violation of the US Constitution. Ms. Hey clearly asked to be represented by an at-
torney and that Ms. Hey already had an adversarial relationship with Judge Wiggins. Furthermore, Judge Wiggins
had already questioned the mental competence Nancy Hey when she took Ms. Hay’s child away from her in another
proceeding. Thus, Judge Wiggins should have been particularly scrupulous in assuring that Ms. Hey was represent-
ed by counsel when questioned.
***
In sum, there was ample evidence in the record supporting a conclusion that Judge Wiggins, consciously or
subconsciously, harbored bias and prejudice against the child’s Mother and disregarded the evidence and record.
There was no evidence to support a finding that the Father was fit to have custody. The father had not provided a
full psychological exam to the court, nor completed a parenting class, and never provided any testimony at any time
in the proceeding. Yet, Judge Wiggins, without having taken any evidence to establish subject matter jurisdiction,
gave full legal and physical custody to the Husband/Father while ignoring the legal rights of the child, the Moth-
er/Wife, and Nancy Hey (an innocent court observer).
In this case, the effects of Judge Wiggin’s malice and negligence have been particularly devastating to this
now 7-year-old child. The child is now confined to the same a small one bedroom apartment living with her father,
who still sleeps in her bed. She is now suffering from the diagnosed but untreated posttraumatic stress disorder and
an untreated very rare life-threatening severe chronic neutropenia. According to written opinions of world experts,
who reviewed all the medical evidence, her life threatening severe chronic neutropenia condition is most likely tox-
in/drug-induced. [Wiggins-COJ- 430] The Husband /Father refuses to give her the only medical treatment for the
condition (GCSF) to avoid unnecessary risk of untreated severe chronic neutropenia of “toxic shock, loss of limbs
or loss of life.” Id. He also refused to have a toxicology test done. The Husband/Father, who is a German citizen,
is so mentally ill and narcissistic that he has defied his German Embassy’s request that their daughter receive an
independent psychological and medical examination (she is also a German Citizen with only a Germany passport) –
requiring an appeal to the President of the United States to Intervene in this, now, international matter. [Wiggins-
COJ-427 through -432] As evidenced by recent articles in the Washington DC area, Judge Wiggin’s irregularities
in this case follow a pattern of her seeking to break the natural and loving bonds of children with their natural moth-
ers. (See, Wiggins-COJ-19 through -24)
I would be happy to come to Richmond to go over these materials and answer any more of your questions.
Again, I urge that you deny Judge Wiggin’s reappointment to the JDR Court. She does not have the qualities neces-
sary for being an effective and fair JDR Court judge.
Sincerely,
Roy Morris
9
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
Attachment I
Judge Wiggins: Deriving Pleasure from the Pain of Children and their Mothers
Comments of Roy Morris, Arlington Virginia
December 10, 2010
The list of cases of children and mother’s wrongly denied their rights in Judge Wiggins court keeps mounting, in-
cluding: Naomi Parish, Nancy Hey, Benita Washington, Dr. Ariel King, and (now) threatening Tiffany Johnson.
They all follow the same pattern: the court treats the mothers as subhuman, everything they do is wrong, and nothing
they do is right. This sets the stage for bogus justification for permanently cutting off the child from their mother and
her families’ normal ties and time with the child. It is, in effect, genocide of relationships of children to their natu-
ral mothers from their lives.
The facts of the case of the still 10-year married couple, Dr. Michael Pfeiffer v. Dr. Ariel King, shows the injustice
and lack of judicial rigor of Judge Wiggins courtroom. First is the obvious, the parents are married and were ineli-
gible to file for divorce in Virginia, but Judge Wiggins allowed a custody-only proceeding to be held in her Virginia
JDR court. Second, the case should not have been heard at all in Virginia, since it did not have “subject matter ju-
risdiction” as none of the parties had lived in Virginia for the six months required by the UCCJEA. In addition,
when all parties had left Virginia after only 3 months, Virginia lost continuing jurisdiction. Yet Judge Wiggins in-
sisted on keeping the case of a married couple where one parent was living in DC and the other in Maryland respec-
tively. In the only official custody evaluation report issued in the case, the Court assigned social worker, Michele
Woods, warned: “This counselor feels it is also important to relay to the Court that [the child] has also made sever-
al comments to this counselor that her father [Dr. Pfeiffer] comes into her bed at night….this counselor would hope
the Dr. Pfeiffer would stop this behavior and understand that it is not appropriate considering his daughter's age.”
Ms. Woods strongly recommended physical custody remain with her mother, Dr. King and shared joint legal custo-
dy with the father. However, Judge Wiggins chose to: a) ignore the recommendations of the Court’s own social
worker’s reports, and b) did not insist on the completion and submission of the full psychological exam she ordered
from the father, and c) never asked questions to or placed the father on the witness stand in the ten months of pro-
ceedings..
On June 6, 2008, in an ex parte hearing without proper notice, Judge Wiggins entered two separate “custody” orders
with distinctly different wording addressing custody of the 5-year-old girl, but marking only one a “final order.” In
the version marked “final order,” the Court without “subject matter jurisdiction” and “continuing jurisdiction” gave
Michael Pfeiffer (who lived in DC) full legal and physical custody without any evidence or demonstration that the
requirements for awarding custody had been met. Judge Wiggin’s orders also cut off all contact with the Wife/
mother (who lived in Maryland). However, the second order (which was never served on the parties), did not give
Michael Pfeiffer a “final order” for legal and physical custody and, by materially different sentence structure and
working, imposed a conflicting meaning and significance. Thus, each order invalidated the other order. To date the
Virginia order has not been registered in either Washington, DC or Germany.
Also, at that hearing, Judge Wiggins denied the request of a person sitting in the audience, Nancy Hey, to be
represented by an attorney while she was vindictively called as an impromptu witness at that June 6, 2008 hearing.
Judge Wiggins allowed the father’s attorney and the GAL to question Ms. Hey despite her protests. Judge Wiggins,
who for years had overseen Ms. Hey’s child case, that led to the permanent separation of Ms. Hey from her daugh-
ter, participated in a “feeding frenzy” of interrogation of Ms. Hey on her various personal and potentially legal mat-
ters that were mostly irrelevant to Pfeiffer v King case, in violation of Ms. Hey’s constitutional rights to an attorney.
Adding to this legal impropriety and ambiguity, Judge Wiggins made this ruling despite the fact that a Montgomery
County Maryland Circuit Court Judge , after a one hour hearing on June 2, 2008 with the 5- year old child and her
mother, had found evidence to suspect sexual and physical abuse and medical neglect and harm by the father. Un-
like Judge Wiggins, that Judge was the only judge who had ever seen or spoken to little girl, about the father sleep-
ing in her bed, seeing “Mr. Piggy’s Penis,” that the “popo that gets harder and harder,” being “kissed on the mouth”,
and the father’s administration of “green medicine to make me sick.”
After showing clear bias, Judge Wiggins refused to rule on the Motion to Recuse herself. She also failed to rule on
the motions to sanction the GAL and opposing counsel for clearly collaborating against the Mother, and making
knowingly false representations to the Court.
10
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
The consequences of Judge Wiggin’s unauthorized and uninformed rulings and biases were that there is evidence
that the child has been sexually and physically abused and medically neglected and harmed for over two years.
Since the father has had physical custody of the little girl, she has unexplainably suffered from a very rare severely
compromised immune system referred to as “severe chronic neutropenia.” Tests indicate the condition is likely
being caused by toxins/drugs that the husband/father has free access to at his work. Thanks to Judge Wiggins ille-
gally mandated, ambiguous and conflicting orders, the father has used her orders to manipulate others without even
registering the orders outside of Virginia. In addition, he as used the orders to prevent the child from getting life-
saving GCSF medicine, appropriate medical care or have any contact with her mother, all other family members, her
Jewish religion and her African and German heritage. He has used those illegal and conflicting orders to isolate,
abuse, and harm their daughter. Even though the father is a German citizen, he has defied his own Embassy’s re-
quest to get medicine for the child and an independent medical and psychological examination for her in order to
save her life [the child is also a German citizen]. Wiggins-COJ-430 Thus Judge Wiggins has created a safe haven
for abuse and neglect of a child, while she has made no effort to address or correct the damage that she has caused to
this seven-year-old child – who she never met.
***
The closest a court can come to physically torturing a mother and her child is to cut off their ability to communicate
with each other, while allowing safety for the other parent to abuse and harm the child to the point of possible death.
Judge Wiggins clearly hates biological mothers, and she appears to derive pleasure from making them and their
children miserable (as evidenced by Judge Wiggins common bouts of histrionic episodes of laughter in the court-
room when doling out insults to the mother and her attorney).
Judge Wiggins need to be immediately retired from the very important role of a family court judge. She has neither
the psychological profile (e.g., empathy for parents and their children), respect for following the law of the Com-
monwealth of Virginia, nor expertise required. Judge Wiggins is harmful to children and families. She must be not
be reappointed to prevent any further harm to those children and families. .
11
Morris Letter to COJ
Re: Denial of Rappointment of JDR Judge Wiggins
Attachment II
List of Exhibits to Opposition to Judge Wiggins Reappointment
12
CUSTODY INVESTIGATION
ARLINGTON JUVENILE AND DOMESTIC RELATIONS DISTRICT COURT
ARLINGTON, VIRGINIA
MOTHER: DR. ARIEL ROSITA KING ADDRESS: 4001 9TH ST. NORTH #824
ARLINGTON, VA 22203
CURRENT COURT SITUATION: The child's father, Dr. Michael Pfeiffer, filed a petition
with this Court on August 9,2007, requesting that he be granted legal and
physical custody of his daughter, Ariana-Leilani King-Pfeiffer, pursuant to Section
16.1-241 of the 1950 Code of Virginia, as amended.
COURT ACTION: On September 5,2007, Dr. King and Dr. Pfeiffer appeared
before the Honorable Judge Wiggins Lyles for an Advisory Hearing, in which the
petitioner, Dr. Pfeiffer filed a petition requesting full custody of his daughter,
Ariana-Leilani King-Pfeiffer. At that time, both parties were advised and mutual
discovery was ordered. The Court also ordered the Court Service Unit to
conduct a Custody Evaluation. In addition, the Court ordered that both parents
take a parenting class and participate in a Custody Evaluation by a qualified
expert.
The Court also entered an Initial Order addressing custody and visitation
pending the next Court hearing that included the following conditions:
D.O.B.: 2/18/63
Education: Dr. Pfeiffer reported that he earned his M.D. and PhD. in
Germany. He also completed a Post Doctorate Program at Baylor
University.
It is important to note that Dr. Pfeiffer had signed a contract on 4/15/07, with
Englewood Community Hospital, Inc. that on or before September 1, 2007, he
would "engage in full-time private medicine as a Neurologist in the community".
His said salary would be approximately $340,000 annually plus additional signing
bonus he would receive. In total, Dr. Pfeiffer was looking at a monthly salary of
approximately $28,000 a month. Al plans had been made by Dr. King in order
for her husband to secure this job. Dr. King reported that she was going to
manage his private practice and provided documentation in which Dr. Pfeiffer
signed a notarized letter on 3/25/07, appointing his wife to represent him in the
administrative processes of establishing a solo Neurology Practice in Englewood,
Florida". By all indications, the family was scheduled to move to their home in
Florida around June 15, 2007. Dr. King reported that a week prior to their move
Dr. Pfeiffer was scheduled to attend a ten day conference in which he informed
his wife just prior to his departure that he would not be taking the job in Florida.
According to Dr. Pfeiffer, he reported to this counselor that he felt his wife has
forced the job upon them because of their financial situation stating that he felt
this was his only way out. He stated that he did not want to accept the job but
felt it was the only way to keep his family together. He further stated that
accepting this job would have been a "huge sacrifice" for him.
S a w : $52,000 annually
RECORD CHECKS:
Criminal Record Check: Dr. Pfeiffer has only legal contact in the
District of Columbia for a Protective Order filed by Dr. King against Dr.
Pfeiffer. Records indicate that on July 6,2007, Dr. Pfeiffer appeared at Dr.
King's place of work at the Zambian Embassy in Washington, D.C. He
reportedly tried to put his daughter in his car, in which Ariana-Leilani then
ran inside the Embassy to her mother crying. Dr. King was reportedly
holding her daughter when Sr. Pfeiffer approached her and grabbed at
their daughter. Dr, King reportedly ran with her daughter and locked
herself in a room. The Embassy staff reportedly asked Dr. Pfeiffer to leave,
at which time he refused to leave. Reportedly, Dr. Pfeiffer was yelling and
being disruptive, which was observed by many people. As soon as the
room was opened again, Dr. Pfeiffer reportedly pushed his way back into
the room. The Secret Service was called and had advised Dr. Pfeiffer to
leave the premises. Police advised Dr. King to file for a potection order. In
addition, one of Dr. King's colleagues who witnessed the incident, also
advised Dr. King to obtain a protective order. Records indicate that a
temporary Protective Order was granted on 7/9/07, for 14 days in which
Dr. Pfeiffer was order to stay away from Dr. King, her home and also her
place of work. He was also ordered to stay away from their child's school.
Temporary custody of their daughter was also given to Dr. King pending
the next court hearing on July 20th. At this hearing, Dr. King requested that
the protection order be extended for up to twelve months but was
reportedly denied by the Judge on the technical grounds that the event
occurred on international grounds of the Embassy and therefore was not
within the jurisdication of the District of Columbia Courts.
Child Protective Services Record Check: Dr. Pfeiffer does not have a
record with Child Protective Services.
Lenath of Residence: Dr. Pfeiffer has resided in this home since July
of 2007.
FAMILY FINANCES:
Health Insurance: Dr. Pfeiffer currently pays for health insurance for
the family (Blue Cross and Blue Shield). He pays approximately
10.63, bi-weekly. It is unclear as to whether his insurance has vision
benefits and apparently his dental benefits do not provide
coverage for children.
D.O.B.: 6/25/62
Education: Dr. King earned her Bachelor of Arts degree from the
University of Hawaii in 1988, and obtained a Master's of Public
Health in International Health Management, from the Texas School
Health: Dr. King reported that she is in good health. However, she
did state that she has lost a lot of weight due to the stress of her
separation and current custody case. She further stated that she is
in need of dental work, but does not have the money to pay for the
expensive dental work that needs to be done.
EMPLOYMENT: Dr. King reported that she has not been employed for the past
several years as she has primarily been a house-wife taking care of her and her
husband's now four year old daughter. During the past few years, Dr. King has
been involved in many projects and is the founder and CEO of Ariel Consulting
Internation, Inc (ACI). ACI is worldwide and works with private and public
sectors in implementing public policy and public health programs that primarily
focuses on developing countries such as Africa, the Middle East, Latin America,
the Caribbean, and the Pacific Islands.
Dr. King is also involved in many projects through her non-profit organization. In
2004, Dr. King was appointed by the National Council of Women (NCW) as the
representative in Washington, D.C., and also for the United Nations in Geneva.
Dr. King also founded The Ariel Foundation International in 2002, which is a non-
profit organization focusing on improving the lives of youth and their families in
developing countries.
Salarv: Dr. King's reported income for 2007 has been less than
$4,000. Dr. King will be able to earn a reasonable salary once she is
able to devote her time to her consulting business.
RECORD CHECKS:
Criminal Record Check: A criminal record check for Dr. King was
negative.
Child Protective Services Record Check: Dr. King does not have a
record with Child Protective Services.
MARITAL HISTORY: Dr. Pfeiffer and Dr. King met in Europe approximately ten
years ago where they were both living and working. The relationship progressed
in which they became engaged for two years before marrying in the United
States on September 16,2000. Both parties reported that they decided to come
to the United States so that Dr. Pfeiffer could complete his medical residency in
neurology in the United States. Dr. King stated that she had made all of the
arrangements for Dr. Pfeiffer to come to the United States including, sponsoring
of his Visa, purchasing a place for them to live, and also buying them a car. Dr.
King reported that she placed her career on hold in order to support her
husband's education and to raise their child. It was understood that the move
to the United States was only temporary in order for Dr. Pfeiffer to complete his
residency. Dr. King reported that her husband had promised her that once he
received his medical training in the United States, he would work as a medical
doctor wherever Dr. King's international career would take her.
After their marriage, Dr. Pfeiffer and Dr. King moved to Houston, Texas so that Dr.
Pfeiffer could complete his internship at Baylor University. It was during this time
that Dr. King became pregnant eventually gave birth to their daughter, Ariana-
Leilani King-Pfeiffer. After completing his first internship, the family then
relocated to Levittown, Pennsylvania so that Dr. Pfeiffer could complete his one
year residency. Upon completion, the family then moved to the Washington,
D.C. area in order for Dr. Pfeiffer to complete his three year residency at
Georgetown University Hospital. On June 9, 2007, Dr. Pfeiffer graduated from
the Georgetown University Residency program and shortly thereafter, received
licensure.
Dr. King reported that during her husband's last year of residency at
Georgetown, her husband decided that the family would remain in the United
States upon completion of his education. Dr. King reported that her husband
promised to obtain a job as a practicing neurologist and earn a full salary, and
that he would work "locus tenens" (hospital rounds) in the interim to supplement
the family's income and cover their expenses. She also stated that he her
husband agreed to attend family counseling in order to improve their
relationship. Dr. King stated that her husband had been earning an income of
about $50,000 per year. She stated that their income was also supplemented by
Dr. Pfeiffer's parents and her limited work income. Dr. King reported that in
January of 2007, her husband began to pursue high paying physician jobs in
Florida. As previously reported, Dr. Pfeiffer signed a contract in April of 2007,
accepting a position to run a private neurology practice in the community of
Englewood, Florida. The couple also purchased a home in Florida. These plans
were then shattered when Dr. Pfeiffer reported to his wife days prior to
relocating that he no longer wanted the job in Florida. This appears to be the
last major incident that ultimately led to the couple's separation.
Dr. King reported a difficult marriage that showed signs of distress in October of
2006 when the family moved to their rental home in Bethesda, Maryland. Dr.
King reported that the family moved from the Georgetown area to be closer to
their daughter's German School. Dr. King had been transporting Ariani-Leilani to
school daily but it was taking a lot of time due to traffic. Instead, the family
decided to move closer to the German School. Dr. King reported that upon
moving to their home in Bethesda, Dr. Pfeiffer separated himself from the family
by residing in the downstairs bedroom with its own door to the outside. Dr. King
stated that her husband would leave early in the morning and return home late
at night. She reported that he had little to no contact with her and their
daughter. Dr. Pfeiffer also confirmed to this counselor that he had distanced
himself from the family during this time.
One of the major disputes that continues to be an issue is the situation regarding
the couples seven months rent that was paid during the time the family resided
in their rented Bethesda home. Dr. Pfeiffer reported that his wife was in charge
of handling and ensuring that all of their bills were paid. Dr. Pfeiffer alleged that
he later learned that his wife did not pay the couples rent each month and
relayed concerns to this counselor about whether he will be held liable for the
$27,000 in unpaid rent. Dr. King reported and provided documentation to this
writer that indicated that while she paid the rent each month, the landlord in
turn did not make monthly mortgage payments to the lender. According to
court documents it appears that the landlord filed for Chapter 13 Bankruptcy
and the house went into foreclosure. Dr. Pfeiffer reported that he was unaware
of their housing situation, despite Dr. King's claims that her husband was well
aware of the situation. Dr. King reported that a considerable amount of her
time was spent securing storage pods for the family's personal property as an
eviction notice had been filed.
The stories regarding the couple's official separation is significantly different from
one another. Dr. Pfeiffer reported that upon returning home from his ten day
conference he found his wife and child gone. He reported that he did not know
where they were and had to hire a private investigator to locate them. Dr.
Pfeiffer claims that he did not know where his wife and child were for about five
to six weeks. He further reported that out of eleven weeks he saw his daughter
only six times that were two hour visits on each occasion. Dr. Pfeiffer reported
that this separation was very traumatizing for him and his daughter. Dr. Pfeiffer
reported that he feels his wife is financially irresponsible and unstable and feels
that this is what ultimately drove them apart. He stated that his wife ran him into
debt and that this was very draining. He stated that he was also tired of his
wife's false promises to obtain employment. Dr. Pfeiffer feels that he has been
the primary caretaker of their daughter, although there does not appear to be
much evidence to support this. This also contradicts Dr. Pfeiffer's statement in
which he admittedly reported that he separated himself from the family when
the family resided in their Bethesda home where he lived in a separate bedroom
in the home.
Dr. King reported that the couple came to the conclusion that they would
separate and ultimately divorce. She stated that Dr. Pfeiffer agreed to
contribute 50% of his income to support her and their daughter in order to help
them to obtain housing. She reported that her husband left her and her child
homeless and that they were forced to temporarily stay with different family
friends until she was able to secure housing for her and her daughter in July of
2007. She reported that Dr. Pfeiffer secured a one bedroom apartment in
Washington D.C. in which he had to put down at least $6,000 for three months
rent as a deposit. Dr. King believes that Dr. Pfeiffer used the last of the family's
cash assets in order to obtain housing for himself. Dr. King reported that she
asked her husband if she and her daughter could temporarily reside in his home
until she was able to obtain housing for them. She reported that Dr. Pfeiffer
refused to allow them to temporarily stay in his home. Dr. King further reported
that without her knowledge, Dr. Pfeiffer had removed her name from their
German Bank Account on or about June 1 1,2007. Dr. King further advised that
during the time of their marriage she was directed by Dr. Pfeiffer to deposit
substantial funds into a German back account which was used to pay and
collect expenses associated with their homes in Germany that were held in his
name. Dr. King further reported that the money in her daughter's back account
was also withdrawn at some point without her knowledge or consent.
FAMILY FINANCES:
Income: Dr. King has no source of income at this time. She has not
had steady employment since the birth of the couple's child in
which she has been the primary caretaker. Dr. King reported that
prior to their separation Dr. Pfeiffer removed her name from all of
their financial accounts without her knowledge. According to her
reports, she and their daughter were left homeless by Dr. Pfeiffer
with only a few hundred dollars left in the couple's joint account.
Dr. King reported that her husband obtained housing for himself
Household Bills: Dr. King reported that her household bills are
approximately $800 per month.
Ariana-Leilani is very familiar with her German roots and is a fluent in English and
German. She has books, music and videos that are written and spoken in
German. In addition, both Dr. King and Dr. Pfeiffer speak to Ariana-Leilani in
German, as well as English.
Ariana-Leilani is very culturally diverse. She has been given the nickname "Little
Miss Ambassador" by family and friends as she has traveled along with her
mother to over ten different countries. As previously stated, Dr. King performs
international work focusing on public health policy in third-world countries and
has traveled extensively to countries like Lesotho, Zambia and the Zambian
safari. These areas have been the primary focus of Dr. King's work in the past
few years. Ariana-Leilani has rarely spent a night without her mother, as she has
traveled everywhere with her mother. It is quite amazing when you look at the
places Ariana-Leilani has traveled to and the many different cultural
communities that she has experienced during her short lifetime. Ariana-Leilani is
quite comfortable traveling to these countries along with her mother and is very
"hands-on" during these trips as she interacts with the deprived children and
people in these countries.
Dr. King has done an exceptional job putting into place a Home School
schedule for Ariana-Leilani. The following is an example of her daily activities:
Since their separation, Dr. King has continued to be the primary caregiver of
Ariana-Leilani. Dr. King has spent every day with her daughter as she has been
unable to work because she is basically providing 24 hours supervision and care
of her daughter, with the exception of the two timesper week her daughter has
visitation with her father.
This court was brought to the Court's attention as a result of Dr. Michael Pfeiffer
filing a petition requesting sole custody of his daughter, Ariana-Leilani,
Through this counselor's interactions and observations of the child and each
parent, it is apparent to this writer that Ariana-Leilani has a strong attachment
with her mother in which her mother's presence provides her with a sense of
security and comfort. It is of this writer's opinion that Dr. King has been the
primary caregiver of Ariana-Leilani. Since the time of her birth, Ariana-Leilani has
been in the care of her mother and has virtually spent every night by her
mother's side. This is evident through the many photos and videos documenting
Ariana-Leilani's extensive travels throughout the world with her mother. While Dr.
Pfeiffer claims that he was the primary caregiver of his daughter, it does not
seem realistic when he reported working 80 hours per week in order to complete
his residencies. It does seem plausible that Dr. King placed her career on hold in
order to support her husband's aspirations to complete his residency for
neurology in the United States. While Dr. King is a citizen in the United States the
majority of her life and career has been spent outside of the United States as her
degrees and studies are in International Health and Policy. Both parents are in
agreement that the couple's original plan was to come to the United States in
order for Dr. Pfeiffer to complete his studies. At some point in time, Dr. Pfeiffer
changed his mind and relayed his desire to stay in the United States in order to
advance his studies. It is appears that Dr. Pfeiffer was misleading, whether
intentionally or not, about his reluctance to have a private practice of his own.
Instead, his reluctance was relayed to the family just days prior to the family's
relocation to Florida. This could not have come at a more inopportune time in
which the family was being evicted from their current home leaving them
without stable housing in the meantime. The family appears to have devoted
the last few years supporting Dr. Pfeiffer's medical studies. That eventually led to
his signing of a contract in April of 2005, agreeing to have his own private
practice in Englewood, Florida. As a result, the family invested a lot of time in
order to do things like finding and purchasing a home in Florida. In addition, Dr.
King had the understanding that she would be handling the administrative
duties that goes along with running a private practice. Dr. King expressed
excitement about her husband's achievement in obtaining his own private
practice and also expressed her relief that the family would finally have a sense
of financial stability after years of financial struggles in order to support her
husband's career.
While Dr. Pfeiffer is asking for full custody of his daughter, there does not appear
to be concrete plans in place for her if he obtains full custody. When Dr. Pfeiffer
was questioned about what he would do with his daughter on a daily basis
while he is working, he simply stated that she could go to the YMCA all day or
one of the local schools. Since the primary goal of each parent is to maintain as
much stability as possible for their daughter, it does not seem appropriate to
remove her from her present environment where she is very happy and
comfortable with all of her classes and activities each day. Although Dr.
Pfeiffer's home is in close proximity to Dr. King's home, this counselor is leery
about Dr. Pfeiffer's ability to maintain his daughter's schedule considering his
current work schedule. It seems more appropriate for Ariani-Leilani to continue
with her current status instead of forcing her to adapt to a new environment.
This counselor would like to comment on the concerns Dr. King has reported to
this counselor regarding Ariana-Leilani's overnight visitations with her father. Dr.
King has reported to this counselor the behavioral problems Ariana-Leilani has
been experiencing since the overnight visitations were started. Dr. King has
reported that her daughter has been displaying behaviors such as throwing
temper tantrums, scratching and biting herself and having accidents
surrounding the times prior to and after overnight visitations with her father.
These behaviors are evidently recent behaviors that have never occurred in the
past. This counselor is aware of Dr. King's attempt to relay her concerns to her
husband and asking for some type of alternative visitations until Ariana-Leilani
becomes more comfortable with her parents' new living arrangements. It
appears that Dr. Pfeiffer is unwilling to temporarily suspend his overnight visitation
which is clearly understandable since he wants to spend time with his daughter.
Whether this is right or wrong this counselor can only report that there has been
a decline in Ariana-Leilani's behavior during the time of this counselor's first and
last visitation with Ariana-Leilani. It is difficult to determine whether her behavior
is a result of the emotional distress she is experiencing regarding her parents'
separation; nor does this counselor have the expertise to make any accurate
conclusions. Due to her age, she probably does not have the capacity to fully
understand her parents' situation as she has made comments to this counselor
that she wants to sleep with both her parents in her home. She is also confused
about what is her home. This counselor can only report that Ariana-Leilani has
made comments to this writer that while she enjoys visits with her father she has
stated that she is scared in her father's home and wants to spend the night with
her mother. Perhaps Ariana-Leilani needs more time to become familiar with
her father's home so that she feels more comfortable with overnight visitations
with her father. After all, Arian-Leilani has virtually spent every night with her
mother throughout her lifetime thus far. This counselor feels it is also important to
relay to the Court that she has also made several comments to this counselor
that her father comes into her bed a night. In addition, Dr. King has tried to
address this issue with her husband requesting that it stop. This counselor cannot
confirm whether this is occurring, but if it is, this counselor would hope the Dr.
Pfeiffer would stop this behavior and understand that it is not appropriate
considering his daughter's age.
Lastly, this counselor would like to relay to the court Dr. King's worries that she
expressed about her concerns that Dr. Pfeiffer will flee the country with their
daughter. This counselor would defer to the court in that this counselor does not
know the possible legal actions, if any that are available to ensure the safety of
her daughter.
Overall, all is not lost in this case in which this counselor strongly feels that both
parents are capable of maintaining a positive relationship in a positive manner
for the purposes of their daughter. It is felt that there will be less conflict
between both parents once resolutions have been made in terms of living
arrangements, child support, financial responsibilities, etc. It appears that these
issues are causing conflict between both parents in which a final resolution
needs to be established.
RECOMMENDATION:
It is respectfully recommended that the parents, Dr. Ariel King and Dr. Michael
Pfeiffer, share joint custody of their daughter, Ariana Leilani, with physical
custody being given to Dr. Ariel King.
-
~ichele Wood Christopher Edmonds
Probation Counselor Probation Supervisor
Date: /pip0-1, Date: 1 0 / z//o 7
By Barbara Hollingsworth
Created Dec 9 2010 - 5:04pm
Tomorrow in Richmond, members of the General Assemblyʼs Courts of Justice Committees will
hear public testimony to help them decide whether a group of Virginia judges should be
recommended for reappointment to the bench. One of those judges, whose term expires Jan.
31, 2011, is Arlington Domestic and Juvenile Relations Court Judge Esther Wiggins Lyles, the
same judge who terminated the parental rights of Nancy Hey and Benita Washington despite the
fact that neither of these mothers were ever charged - let alone convicted - of child abuse or
neglect. After their children were snatched by Arlington social workers, Judge Wiggins Lyles
rubber-stamped their legal kidnapping.
Next Tuesday at 10:20 am, Judge Wiggins Lyles has scheduled a hearing to terminate the
parental rights of Tiffany Johnson, whose one-and-a-half-year-old daughter, Talayah, has been
in the countyʼs custody since she was three months old.
Court documents filed by the county on Nov. 30 and obtained by The Examiner admit that “at
the time of the removal…Talayah appeared physically healthy,” and do not list any evidence of
abuse or neglect on Johnsonʼs part beyond vague “concerns surrounding Ms. Johnsonʼs basic
parenting skills.” Yet the 26-year-old mom, herself a former foster child who has a job and is
living in subsidized housing, is within days of losing her daughter forever.
On July 20, guardian ad litem Ellen Dague submitted another document to the court noting that
Talayeh was returned to her mother for a brief period in September, 2009 but “was removed a
second time because mother was too overwhelmed with her commitments.”
Is being frazzled the new standard for having your child taken away by Arlingtonʼs Child
Protective Services, whose own website says that children are only removed from their homes if
they are “at risk of serious harm”? If being “overwhelmed with commitments” is the new definition
of neglect, nobodyʼs kids are safe.
Last year, before the same legislative panel, veteran attorney Roy Morris blasted then Chief
Judge Wiggins Lylesʼ handling of a custody case in which she completely terminated a motherʼs
contact with her five-year-old daughter. “Iʼve never seen a worst run court in all my years of
[litigation] experience,” Morris told legislators on Dec. 21, 2009. “My client was dragged into the
Virginia court even though Virginia didnʼt have jurisdiction… Why would a judge have taken a
case that they didnʼt even have jurisdiction to hear?”
And in a Dec. 8 letter to Arlington Chief Circuit Court Judge William Newman, Dr. Sheila Mannix,
co-founder of Illinois Family Court Accountability Advocates, noted that Johnsonʼs case “evinces
the patterns of practice of alleged offenses against the criminal laws of the United States” that is
the subject of a Sept. 14 federal court order in Chicago, warning that “Freedom of Information
Act requests will be forthcoming to investigate if the misappropriation of federal funds has fueled
the removal of this child from her mother without just cause.”
This is more than enough reasonable doubt for legislators to decide that this judge needs to
step down.
Beltway Confidential Arlington Domestic and Juvenile Relations Court Chid Protection
Services Courts of Justice Ellen Dague Esther Wiggins Lyles Freedom of Information
Act Illinois Family Court Accountability Advocates Judge William Newman Roy Morris
Sheila Mannix Tiffany Johnson Virginia General Assembly
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,
Arlington officials ignore jurisdiction 12/15/2010 6:29 AM
By Barbara Hollingsworth
Created Dec 14 2010 - 8:05pm
But the girl and her granddaughter were living in Stafford County at the time, not Arlington. And
their "home state" as defined by the Virginia statute was Maryland, not Virginia.
Arlington social workers obliquely acknowledged their lack of jurisdiction when they took the
child to Chevy Chase on Aug. 31 and used her state of Maryland "Healthy Smiles" Medicaid card
and her former Bethesda address to get the girl's teeth cleaned, X-rays taken and two small
cavities filled. But jurisdiction wasn't the only legal requirement Arlington decided to ignore.
In a five-page rebuttal filed with the Juvenile and Domestic Relations Court, Delores Heffernan-
O'Brien testified that she had never been served with the 2009 removal order, and only saw it for
the first time on July 26, 2010 -- four days after her granddaughter was taken into foster care.
As a result, she could not defend herself against any of the charges against her in an apparent
violation of her constitutional due process rights.
Then it happened again. "I never received written notice of the most important hearing of my
life," O'Brien, a Mormon, former model and widow of a prosecutor, said of the Aug. 19 hearing
she missed as a result.
Arlington JDR Chief Judge George Varoutsos found her guilty of neglect and abuse in absentia,
and suspended her one-hour-per-week visitation with the child she had raised from infancy. The
only contact she was allowed was a once-a-week phone call monitored by the foster parents so
O'Brien would not upset her granddaughter with her "adult" problems.
Yet just two days later, she says, her granddaughter's court-appointed guardian ad litem allowed
the same Montgomery County detective investigating check-kiting charges against her (which
have since been dropped) to interrogate her granddaughter until she became hysterical.
Calls to the guardian ad litem, the Arlington commonwealth's attorney's office, and the social
worker involved were not returned.
This was not the first time that violations of defendants' due process rights in Arlington's JDR
Court have been reported. In September, attorney Roy Morris petitioned President Obama,
Secretary of State Hillary Clinton and Attorney General Eric Holder to intervene on behalf of Ariel
King, who not only lost custody of her then 5-year-old daughter but was barred from any future
contact with her seriously ill child even though King, like O'Brien, was not an Arlington resident.
Another anomaly: Morris received two slightly different final court orders, both dated June 6,
2008, and both signed by Judge Esther Wiggins Lyles.
That same day, court transcripts show, Judge Wiggins Lyles forced a woman who had not been
subpoenaed as a witness to testify on the stand without benefit of the legal representation she
clearly requested. A federal investigation into such violations of due process rights should be
next.
Close Window
Tuesday, April 8, 2008, I accompanied Dr. Ariel King, Founder and President of the Ariel Foundation, to the family court
of Judge Esther Wiggins Lyles in Arlington, VA.
I have heard about this Judge, but had never had, what I now consider to be, the displeasure of sitting in on one of her
hearings. It was an eye opener for me that such a judge continues to dispense her self interpreted brand of justice
from the bench. And, I am left wondering who is in charge of that courtroom and why she continues to be paid for
occupying the position of judge.
I had spoken to Dr. Ariel King for only a few minutes the night before court and we mostly spoke of my own situation,
not hers. I arrived at her home in Maryland after 9AM on April 8th, while she was out on an errand. When she arrived
home close to 9:30 or so, it was time for her to get ready for court, showering dressing and doing her hair. As soon as
she was ready, we left in separate cars. I mention all this so that you understand that we had no time together to
discuss her case. I had little if any background available to me until the end of the court day. As happened, this was
positive for being an observer. I had little or no information on which to base my observations.
We were accompanied to court by Dr. King's mother, who had suffered a massive stroke in February, 2008. Along the
way, we stopped to pick a friend of Dr. King's who is a lawyer, but does not practice in the family court system, nor in
the Commonwealth. He was simply along for the "legal ride" and has taken an interest in her case.
Prior to court, we met her lawyer, the latest in a string of attorneys to represent Dr. King. The others had been
dismissed by her for inaction and mishandling of her case. This lawyer had failed to bring with him a set of documents
Dr. King felt was important to the case. He had completely jumbled other papers that were to be presented to the
court. As Dr. King and her friend made attempts to set the paperwork right, the lawyer representing her acted as if
these were natural mistakes. After about a half hour or so, we headed toward the courthouse.
As we exited the elevator on the fourth floor, Dr. King mentioned something that is vital to her case. I had heard her
mention at least twice during the just prior meeting and the lawyer had reassured her that everything was in order. As
if it were completely normal, the new lawyer tossed out "We're not filing that today." No explanation, no reasoning, not
a further word was said by him.
I was the only observer in the courtroom. Judge Wiggins Lyles attempted to delay the case even further, saying that
none of the four contempt charges stemming from Show Cause Orders were due to be heard that day. I can only
surmise that this tactic was a lame attempt to possibly delay the case until I exited the courtroom. After all, no one
knew who I was, and later, I would not be sworn in as a witness, which was visually noted by the judge with an intense
stare toward me while everyone else raised their right hand. The only person to leave the courtroom was Dr. King's
mother, frail and frightened.
The Guardian ad Litem was the first to speak. She offered, though Dr. King was cooperating with the courts at this
time, she had a history of being very uncooperative. After court, I asked Dr. King what this was in reference to. Dr.
King replied that she did not know why this was being said. This, I am again surmising from hearing a good part of the
story, stemmed from the original phone call she received from the GAL in Virginia. She was living in Maryland, after
only living in Virginia for twenty-nine days. At the time of the abandonment, her husband moved to DC for two months
and then returned to Maryland, but filled for full custody in Virginia. Her husband was living in DC, when he filed for
full custody in Virginia. This was directly following the abandonment by her husband of her and her than 4 year old
child without money or a place to live one week after completing a Neurology Residency. Upon receiving the call, Dr.
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Another Case of Judicial Abuse by Mother Toad (Gail, Love th... http://www.gather.com/viewArticlePF.action?articleId=281474...
King sought advice from counsel. She was told not to talk to anyone, and so she followed the advice her then lawyer
gave her. At the point in time the call was received, the child was living with Dr. King in Maryland.
The fact that she and her child had only spent twenty-nine days in Virginia before the husband filed for full custody in
Virginia and returned to Maryland following that period, and with the husband living in Washington, DC, again, not
Virginia, begs one to ask why a custody case is being heard in a courtroom in Arlington, VA. The law is very specific
on this point and leaves no room for interpretation. In order for custody to be heard in a Virginia courtroom, at least
one of the litigants has to have lived within the borders of this state for no less than six months. Neither of the litigants
involved, nor the child, meets that stipulation. With the child living in Maryland with her mother at the time the case
was filed, and the father living in DC, a civil case should have been filed in one of those jurisdictions. From my
understanding, Dr. King has pointed this out to the judge in the past. When there was an attempt to bring it up again
on Tuesday, Wiggins Lyles abruptly cut her off and informed her that she did not want to hear it. The judge had based
the jurisdictional issue on the fact that Dr. King had, at one point, signed a one year lease on an apartment, which she
admits to having done at the time of the abandonment, but only used the apartment for a total of three months during
the lease period. Their daughter's private school, place of worship, extra-curricular activities, pediatrician, playmates all
remained in Maryland the entire time.
As court proceeded, Dr. King was put on the stand. As is now my understanding, though she was ready and willing,
Judge Wiggins Lyles had not allowed her to speak in court since the case had started. In that vein, the judge refused
to see offers of evidence presented on Tuesday. One by one, she ruled that they were of no relevance or not
admissible as hearsay, without examining most of the documents herself and basing it solely on the word of Mr.
O'Connell.
Time after time, the lawyer for the other side, Mike O'Connell, pounded on the podium in an attempt to upset Dr. King.
During first of the two recesses in the five and one half hours we spent in the courthouse, I informed her lawyer that the
act of the pounding was a deliberate badgering of Dr. King and an attempt to upset her. He spoke to the husband's
lawyer during that recess, and following that, although not present for the conversation, I have to believe that he
informed Mr. O'Connell that I was there to observe the proceedings as a possible future witness to the happenings in
the courtroom, as he discontinued the practice. At one point, however, Mr. O'Connell, raised his voice and in an angry
tone asked Dr. King if she knew what the penalty was of perjury. This is lawyer speak for "You are lying", something
they are forbidden from saying to anyone on the witness stand without being able to back it up. Again, this is used as
an intimidation technique.
During the entire time that her husband was present in the courtroom, and having full view of him, I noted an
uncontrollable and constant facial twitching. He held his hands tightly together and below the table level where the
judge could not see them. Now knowing that he is a Neurologist, I have to question the cause of the twitching. These
types of bodily behaviors would give me concern in a medical environment. On the other hand, when people lie,
whether themselves or through a third party, they will often display such behaviors, as do people with certain organic
brain disorders ranging from Tourette's syndrome to Generalized Anxiety disorder with any number of serious brain
disorders in between, including untreated or with the off label use of Lexapro for Bipolar disorder as reported by
patients who are using the drug for it's unintended use.
When the subject of Dr. King's mother came up, Judge Wiggins Lyles choose to offer, in what can best be described as
editorializing, that Dr. King had made a bad choice in bringing her to Maryland from Atlanta. With no support system in
Atlanta for her mother, no insurance to cover further hospital bills (her mother was stablized and released due to lack of
insurance at 3 AM) and her mother having the physical capacity of a six month old, the judge said that she would not
have moved her mother to the DC area via car (the mother was not allowed to fly due to a bleed condition in the brain)
and that Dr. King should have remained in Atlanta, away from her child, her employment and two other people to help
care for her mother. In essence, the judge was telling her that she should have made the choice between her child and
her near death mother and that the act of bringing her mother here, where she could receive proper care, was an
unthinking act on Dr. King's part.
From the beginning, I question the abilities or willingness of Dr. King's new lawyer. One of the first things he told her
was that a key witness, living a few miles away in Maryland, could not be subpoenaed to testify. It is my understanding
that if a person is within a 1200 mile radius, they can be called. Further than that, they can be deposed.
When asked about notifying the courts upon her return from Atlanta (the husband had been given temporary custody
while she was away), Dr. King said that she notified her lawyer, the GAL and her CPS probation officer, a Ms. Woods,
by email just after 1 PM Tuesday, after returning on Monday and amassing the proof that the CPS worker required.
Ms. Woods stated from the observers seating, "Oh, yeah, a week later." Dr. King was able to produce a copy of that
email. Judge Wiggins Lyles responded that it was after the attempt by Dr. King to retrieve her child and ruled a
contempt charge be upheld.
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Another Case of Judicial Abuse by Mother Toad (Gail, Love th... http://www.gather.com/viewArticlePF.action?articleId=281474...
Dr. King is in possession of a tape of a 911 call placed on the Tuesday morning and stemming from the attempt to pick
up her child upon her return from Atlanta and upon amassing the required documents for the court. The father refused
to hand the child over. On that tape, the child can clearly be heard screaming, banging on a door and crying for her
mother. The judge refused to hear that tape.
The husband was allowed to leave the courtroom early. Mr. O'Connell outwardly stated that he could leave to pick up
the child from school, although he was fully aware that Dr. King had arranged for the child to be picked up by the
nanny. It should be noted that it was not the judge who excused the husband, but his own lawyer. I believe this is an
indication of the judge's propensity to just go along with one lawyer over the concerns of the entire courtroom and the
rules of said courtroom. When his lawyer was on track to make a statement or ask a question that would be objected
to, Judge Wiggins Lyles told him how to phrase them so that they would not be overruled. She did this time and again,
yet did not extend the same courtesy to Dr. King's lawyer. At one point, Mr. O'Connell ordered that a disallowed
question be stricken from the record while no such utterance came from the judge.
When it came to the matter of Dr. Lane, it was noted by the courts that Dr. King had discontinued seeing him. In what I
believe to be a deliberate set-up for failure, Dr. Lane would initiate the appointments with a call or email her with times
and dates he could see her. She kept all but one appointment with him. Eventually, for reasons I have yet to learn, Dr.
King was forced to contact the medical board about Dr. Lane. When the attorney for the husband asserted that Dr.
King had missed several appointments, she again informed him that she had only missed one. Mr. O'Connell than
stated that no one would ever know that for sure because Dr. King exercised her right to make what she thought and
continues to feel, was a valid complaint. Dr. Lane has had complaints filed against him in the past. Dr. McFarlane, an
associate of Dr. Lane's, has now been appointed by the judgeto do the evaluations.
When Dr. King's mother came into the courtroom to testify, Judge Wiggins Lyles refused to allow the testimony to take
place. In a previous hearing, the father's lawyer had asserted that Dr King exaggerated the mother's illness in order
not to attend a previously schedule full custody hearing. They asserted that Dr. King had gone to Atlanta to venue
shop, a fact that could have been disputed by the mother.
The cruelest part of the day came about a half hour before bringing the gavel down for the day. Dr. King was found
guilty on two counts of contempt of court. Mr. O'Connell, citing the Dr. King's alleged noncooperation, angrily insisted
that Dr. King be jailed. Judge Wiggins Lyles, in what appears to me to be a deliberate attempt to destabilize Dr. King,
informed those present that she "needed to think" about the punishment until the next hearing date, once again leaving
Dr. King in a state of limbo.
Court was dismissed for the day when Dr. King's mother began to feel ill with what is believed to be, based on her
blood pressure and medical history, a mini stroke and had to be removed from the courtroom. Ms. Woods, the CPS
probation officer, assisted us in getting her down stairs. When doing so, she stated to Dr. King that she thought the
husband could use help with parenting by taking "a few parenting classes."
Submitted by
Gail Lakritz April 10, 2008
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VIRGINIA:
IN THE JUVENILE AND DOMESTIC RELATIONS DISTRICT COURT
FOR THE COUNTY OF ARLINGTON
1) If prior court orders exist which determine custody and support of the minor chil.d(ren),
the parents are required to abide by such prior court orders
2) Unless specifically contradicted by prior court orders both parents are the joint custodians
of the child(ren) are ordered to conduct themselves as follows until further order o f this
Wiggins - COJ - 000037
court:
a. Each parent shall keep the other parent notified of his or her address and
telephone number and permit the other party to have reasonable contact with the
child(ren) unless it is absolutely necessary to prevent the chitd(renj or a party from
harm. If either parent denies the other access to the child(ren) and the Court finds
such denial to be unreasonable, this will be a strong factor against that parent
retaining custody of the child(ren).
b. The child(renj shall continue to attend their usual school and childcare provide1
unless there exists a compelling reason to do otherwise.
c. The parties shall continue in effect all insurance policies, including, but not limited
to, health, life, automobile, and homeowner's insurance for the duration of the
proceedings or further order o f Court.
d. Each parent shall consult the other, if possible, of important health care or
educational issues involving the child(ren). Both parents may have access to the
child(ren)'s school and medical records.
the court enters a child support order, both parents shall to the child(ren's)
su port to the best of thei a il~ty.'F'a^-tr- Or &^f
A)& 5i^-,,pi^-f IXUiu, a.'<^^x^^^^- $4 -$I
*~ft^r^^i
Neither party shall harass the other party, call or appear at the other parties' place of
employment except as necessary for the well being of the child(ren). All parties are required
by law to refrain from any abuse against each other or the child(ren).
The parties or their attorneys are hereby directed to promptly notify the Court in writing of a
reconciliation.
Michael H. Pfeiffer
Petitioner
Ariel R. King
Respondent
COMES NOW Respondent, ARIEL R. KING, by counsel, and moves this Court for an
emergency hearing to modify pendente lite custody. The Initial Order entered in this case
directed the parties to allow Petitioner to have visitation that included overnight stays with the
parties’ four year old child, twice a week. As demonstrated below, overnight stays have created
untold amount of stress on the child, taking its toll and manifesting itself psychologically and
physiologically.
Respondent respectfully requests that the Initial Order be modified to not require
overnight stays with Petitioner until it can be shown that overnight visits will not negatively
5, 2007, the Court issued an Initial Order on Petitioner's pendente lite request for custody.
In its Initial Order, the Court required Petitioner, a German citizen, to surrender the
child's German passport to the Court prior to allowing any extended visitation with
two overnight visits per week were allowed with Petitioner -- one on each Wednesday
night and one associated with alternating Saturday and Sunday visits. Petitioner had a
history of attempted snatching of the child while she and Respondent had attended an
event at the Zambian Embassy on July 6, 2007. The incident was serious enough to
prompt the US Secret Service (which guards the embassies) to be called to the Embassy.
The US Secret Service agent -- after interviewing the Petitioner -- recommended that the
Respondent seek a restraining order against Petitioner, which she successfully did. (See,
Exhibit II, Temporary Protective Order Issued by the District of Columbia, July 9, 2007).
In addition, the DC police escorted the Respondent out of the District to the Virginia
border to afford her protection. The child stated on the escorted ride home that: "Papa
tried to take me." "I'm gonna be broken." "I don't want to be broken." "Papa's not my
friend."
2. This Court has scheduled for November 8, 2007 the hearing on the Petitioner's Petition
for Custody.
3. Since entry of the September 5 Initial Order, the child has gone on two weekday visits
to the Petitioner's home and three weekend days to the Petitioner's home. The Petitioner's
"home" is a one bedroom apartment, where the father has from time to time slept with the
child in the child's "queen size" bed. The bedroom that houses the child provides no
privacy, as one wall contains a series of large window-like openings into the kitchen of
the apartment. Those window-like openings to the adjacent room were misrepresented
by Petitioner's attorney in the September 5th hearing as being solid glass windows to the
outside.
5. The child has also stated directly to Petitioner that she is scared and that she does not
want to stay overnight. In addition, the child has asked Petitioner to bring her home from
the visits, but Petitioner has refused -- insisting that she stay the entire time.
6. The frequency and nature of the overnight visits have been disruptive the child's life,
causing her to either miss out on, or be sleepy or irritated on the day following one of the
overnight visits to Petitioner's home during the many home-school program activities that
have been regularly scheduled on the day of her return to Respondent's Arlington home,
including gymnastics, piano, art, dance, ice skating, sciences, and volunteer activities at a
7. Respondent has attempted to work with Petitioner to work out arrangements that
would be less stressful, however, Petitioner refuses to acknowledge that there are any
problems, and continues to demand that he take the four year child to visit his home
under any circumstances -- even when the four year old is sick and running a
temperature, and even when the four year old is in a deep sleep (which has the negative
8. Petitioner’s behavior has become more erratic, showing little empathy for the child.
For example, in a recent overnight visitation on the evening of Thursday, September 27,
Petitioner showed up at Respondent's building and demanded to take the child even
though the child was sound asleep. Petitioner became irate in the lobby of Respondent's
apartment building and harassed the employees at the front desk, taking their pictures
when they objected, and threatened to call the police. His behavior was extreme enough
to prompt the building’s management to bar him from the building. Similarly, when
Respondent invited Petitioner to attend the Saturday morning (September 8) first day of
the child's class at the German School, Petitioner disrupted the child's classroom and
refusing to leave the room after all the other parents had left, causing the head of the
Petitioner's behavior, in turn causing several parents to call the head of the school to
complain about Petitioner's behavior. The next week, the director of the school (of 600
students) asked the Respondent take measures to prevent such an incident from
happening again. (See, Exhibit III, Email of Kerstin Hopkins to Ariel King, dated
9. Respondent has tried to cooperate with Petitioner, including making a plea with him to
work together, in a non-adversarial way to resolve the custody and visitation, to reduce
the stress on the child, and other issues, and that the money spent on litigation would be
better spent on the child's future. Petitioner has wasted judicial resources by seeking full
custody, only to admit to Respondent and third parties that he did not really want full
Michael Pfeiffer, dated June 25, 2007, September 20, 2007, September 25, 2007, and
10. Historically, Petitioner has been mostly uninvolved in the daily and long-term care and
11. Petitioner is not a fit and proper person to have custody of the child. Petitioner is not
care for the child on an extended basis overnight. Petitioner has little, if any, extended
experience in taking care of the child for periods longer than a few hours. Even when in
his custody for a short period of time, Petitioner has failed to properly feed the child
(instead feeding the child candy and other sweets which sweets have resulted in a
mouthful of cavity), protect the child, and protect the health and safety of the child, failed
to keep to bedtime schedules required for a growing four year old, and routinely and
bizarrely taken the female child into the men's bathroom (even when other women are
available who can take her into the women's bathroom, and even though the four year old
is capable of taking care of herself in a public women's bathroom if let in the door).
12. Petitioner has displayed an inability to maintain the child's safety when the child is
under Petitioner's control and properly set boundaries in terms of how he handles the
14. The child is only four years old and has special needs, including having a need to have
special physical contact with the mother as a way of coping with stress and an inability to
fall asleep.
antisocial behavior, creating an unhealthy environment for any extended stay by the child
until the Court can be convinced that Petitioner has addressed the underlying cause of
these behaviors.
16. The Arlington County Child Services Unit has visited Respondent's home and
interviewed the child, has confirmed the stress the child is undergoing from the visits
with Petitioner, and, according to court records, has requested the appointment of a
Guardian Ad Litum.
17. The Court needs to prescribe a visitation schedule that minimizes stress on the child,
provides a free weekend when the child can take a trip to visit relatives in the allowed
areas set forth in the Initial Order, accommodates the German School's request that
Petitioner's behavior not be repeated, and accommodates the child's normal evening 7 pm
bedtime.
WHEREFORE, for the reasons stated herein and for such other and further reasons as will be
presented before this Court, Respondent respectfully requests the following relief:
A. The Court order that Respondent be awarded sole custody pending the final outcome
of these proceedings;
any overnight);
Saturday (after the German School classes on Saturday morning) of the visitation
D. The Court award Respondent her attorney’s fees and costs incurred in connection
E. The Court award Respondent such other and further relief as this Court deems just
and appropriate.
_______________________________
Daniel G. Dannenbaum, VSB # 34621
1331 H Street, NW
Suite 500
Washington, DC 20005
Tel: 703-405-4899
Fax: 202-347-8607
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing was sent by facsimile to Sean W. O’Connell,
4113 Lee Highway, Arlington, VA. 22207, fax number: 703-522-07865, counsel for
Petitioner, on this ____day of October, 2007.
_____________________
Daniel G. Dannenbaum
Dear Michael:
First and foremost, you and I need try to maintain a relationship that
will promote the health and welfare of our four year old child, Ariana-
Leiani. Towards this end, open communications and a collaborative
attitude towards addressing her needs and assuring that she has
access to all resources, both now and later, are critical to meeting
those needs, including all rights due her under both US and German
law, as she is a citizen of both.
The following is what I heard you say or understood that you have
done, and I have relied upon your representations:
Prior to your moving out, you promised that you would give us
50% of your income, which would include your salary and extra on-
call work. When I asked you to write a letter to a prospective landlord
to tell them of this promise, you did not dispute that this was your
representation to me and Ariana-Leilani. However, you did not follow
through with writing the letter, instead saying that I should relocate to
New Jersey and try to move in the one bedroom apartment of my
elderly grandmother or friends in Pennsylvania.
I also asked if we could come live with you at your new address,
but you refused.
You have previously taken out most of the money from our
child's German bank account (which was several thousand Euros), and
have failed to replace it. Please replace the money of our child
immediately.
Michael, I hope you will reconsider how you are approaching this. All
indications are that you have abandoned us and left us to fend for
ourselves, without adequate resources to even maintain a roof over
our heads. I hope this was not your intention, and that you will
immediately take action to correct the situation. I think you would
agree that a highly skilled medical physician (MD/PhD) who is a
Fellow of Neurology at one the leading hospitals in the United States
should not be or would want to be known to the legal system of the
United States or to Germany as a "dead beat dad" who will not take
the steps necessary to provide the financial and emotional support of
his daughter and wife. I hope that is not what you want or intend, as
it is not what I wish either.
Sincerely,
Ariel
Cell: 202-730-5111
Moody friends. Drama queens. Your life? Nope! - their life, your story.
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CUSTODY
T e of Case: ------.-----------------------------------------------------------.-----------------------------
8Felony a
Misdemeanor 0CHINS Custody Visitation Support Foster Care Other a
Type of Hearing:
IT IS ORDERED THAT:
MOTION TO DISMISS IS DENIED. CONTINUED FOR FULL HEARING.
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0111-712008
Wiggins - COJ
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a000062 -*-. -*-----------
DATE
OF ARLINGTON COUNTY
* * * * * * * * * * * * * *
MICHAEL. H. PFEIFFER,
Petitioner,
ARIEL R. KING,
Respondent.
IN RE: XXXXXXXXXXXXX
DOB: 05/07/2003
* * * * * * * * * * * * * *
Arlington, Virginia
a.m.
- - - - - - - - - - -
1
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000063
APPEARANCES:
Guardian Ad Litem:
P R O C E E D I N
G S :
Raymond Benzinger.
substitution of counsel?
week.
2
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000064
MR. REICHHARDT: I’m here, if you do not have a
morning.
motion up to you --
copy.
evaluator?
3
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000065
Your Honor, very briefly, as the Court well
evaluations in children.
that.
would intend.
me.
know.
And then, you know, you would never get, how could you
5
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000067
MR. REICHHARDT: Well, let me address it
6
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000068
MR. REICHHARDT: Your Honor, that’s not for the
party.
person. I’ve known him for a long time. The Court has
would have that result. That would mean that anyone, and
8
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000070
I keep saying this, who didn’t like what an evaluator
would say would just file a complaint and then that’s the
end of it.
cooperation --
morning.
9
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000071
On the question of what, the Court’s concern
in the case.
this Court.
other fashion.
opposing party.
12
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000074
But the profession is not governed by these
Lane to withdraw.
remark.
of the mother --
just said.
lack of cooperation --
issue of --
right.
14
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000076
MR. O’CONNELL: I’m saying the issue of whether
reasons.
of the contempt.
you don’t return the phone calls. Then you lie about
and I’m not an expert in that field that says, you know,
on it.
yet.
16
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000078
respect to where that leaves Dr. Lane. Thank you, Your
Honor.
filing.
17
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000079
the report. And this is a custody evaluation that’s been
ordered.
violation.
is a double-edged sword.
to him.
18
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000080
MS. OLIN: What?
does this mean that somebody can just come in and get
different matter.
those sanctions.
people did this, what prevents them from doing it? Well,
occurs.
20
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000082
governs the ethical standards of psychologists. If
interest.
conflict here?
irrelevant. He is a defendant.
21
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000083
MR. REICHHARDT: They do. And I just, I hate
to say to the Court take my word for it, but, you know,
Your Honor, we’ve been involved with the state board and,
to make a ruling.
rationale.
please.
may I be excused?
would like to, rather than list all the things that might
contempt.
24
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000086
MR. MILLER: Summary contempt is authorized and
the Court.
25
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000087
MR. OLIN: I would just say that I am an
contempt of Court.
says.
point.
Guardian ad Litem.
26
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000088
MR. MILLER: Okay, and I disagree with that
then she can come forward and put that evidence before
the Court.
did not respond saying, okay, come out tonight, come out
27
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000089
tomorrow, when can you come out. I do understand that
weeks.
me.
moment.
Jurisprudence --
orders?
cooperated?
I have a home visit and the response is, number one, no,
Litem has to do. She knows what she had to do. That
would be cooperate.
cooperating?
that’s it. The GAL has had access to Dr. King. Now, she
may not like that she didn’t have all the access that she
wanted.
today.
also ask that any jail time be put off until such time as
question.
Litem one.
speaking to.
anything else.
33
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000095
MR. MILLER: Okay. But again, all we have is
what factors --
cause. So is --
her.
affidavit of service.
there is nothing?
filed.
Litem’s investigation?
that there’s --
summons.
35
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000097
THE COURT: Okay. A rule was issued, but the
it without it.
hear that --
of any kind.
child?
could go to Atlanta?
38
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000100
allowed to go down and collect the child. All these were
while--
today.
for --
sorry.
can go back and pull the copy of it. I believe it’s file
really --
believe the --
today.
paid $10,200 of Dr. Lane’s fee and that’s not all of his
fee. And --
together.
here.
41
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000103
MS. OLIN: Your Honor, I don’t know if you had
of, the Clerk had told me there was so many motions filed
either father can get her or mother can bring her back,
don’t know about the timing of this, but before the next
42
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000104
bias is less of an accusation and I will stop there
be, and I’m not an expert in this field, but perhaps the
43
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000105
THE COURT: Because I don’t know if she can do
it.
talking about.
saying.
day?
9th?
jurisdiction.
the father.
hear it.
46
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000108
Virginia the Court lost continuing exclusive
jurisdiction.
determination --
made it yet.
established.
the Court.
figures out is better for the child than what the mother
is presently doing?
48
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000110
THE COURT: She has to bring the child back and
hearing on this.
time?
Honor, I’ve been handling this case for about four months
address the timing and the dates for other issues, the
49
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000111
visitation, everything. The Court is going to order both
filed a --
the other two rules for the contempt on that date too.
I’ll sit down and be quiet about it. The issue of that
50
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000112
mother hasn’t provided any documents. I have no copies
hearing for.
was requested because she has not. And that has been
to comply.
custody only.
would be a JA something.
see support.
action.
stating it.
Honor?
52
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000114
THE COURT: When she comes back, when is she
back?
to Maryland or --
issue would come up for the visitation. She can have the
visit the child I think the father should make the child
history of traveling.
53
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000115
THE COURT: The passport?
these things.
Honor.
passport surrendered.
point.
new one.
country.
Clerk.)
55
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000117
MS. OLIN: Judge, you’ve heard so much we
to the mother.
56
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000118
THE COURT: I just made a ruling that may
custody.
the area, where’s she’s living, and that she started the
psychological evaluation.
Your Honor?
before.
57
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000119
MR. O’CONNELL: Very well.
death.
the GAL.
that?
on the custody.
compel.
to compel early in the case, excuse me, some time ago and
cooperate and Mr. Miller has just said that he’s going to
better.
59
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000121
CERTIFICATE OF COURT REPORTER
CAROLYN J. TIMKO
Court Reporter
60
TIMKO & ASSOCIATES
9007 Windflower Lane
Annandale, VA 22003
(703) 25-8147
Wiggins - COJ - 000122
ORDER .
Case No JJ03 1848-01-00
Commonwealth of Virginia
COMMONWEALTH OF VA
--...-T--ee--.--T-.---.---.m------.-.---.
V.I la re: ARIANA
- LEILANI
.~---.---.-.-.--.---~KING-PFEIFFER
~.m---.----~--.-.~.---~--..-~......--.-.------
THE FOLLOWING PARTIES WERE PKESENT:
T e of Case: CUSTODY
8 Felony Misdemeanor a CHINS Custody Visitation a Support Foster Care Other
Type of Hearing:
DeteminatiodAppointment of Counsel Detention Hearing Transfer Hearing
Adjudicatory Hearing Disposition Hearing Continuance Review Preliminary Hearing
Show Cause Trial 0Motion .-.------.----..---.-.--.--.-----.-----*--.-.-.
0
IT IS ORDERED THAT:
CASE CONTINUED BECAUSE CHILD IS OUT OF THE STATE AND THE PSYCHOLOGICAL EVALUATION WAS
NOT COMPLETED AND MOTHER DID NOT COOPERATE WITH THE GAL.
Wiggins
-*.....---" - COJ 02/08/2008
- 000123
--...*.-.---..-.*.---.--.-....--e-.----.--..-.--..-.p.-*-..---.-.-.
DATE
V I R G I N I A
* * * * * * * * * * * * * *
MICHAEL H. PFEIFFER, :
Petitioner, :
ARIEL R. KING, :
Respondent. :
DOB: 05/07/2003
* * * * * * * * * * * * * *
Arlington, Virginia
- - - - - - - - - - -
APPEARANCES:
Guardian Ad Litem:
1 P R O C E E D I N G S :
5 Honor?
9 Your Honor?
1 all about. We were just here not even what, two weeks
2 ago?
5 hearing something.
7 last --
16 about.
22 evaluation.
11 order --
16 to, and I think what, you know, I was in here not a week
1 are well founded and I think this has just got to stop.
14 for a hearing.
21 question.
18 this out.
3 any more trauma than this woman has already and we let
8 which the Court said it would do, but she wasn’t doing it
11 the child.
15 testify.
21 February 15th.
1 the Court.
7 play this game. We went over this when she was here
10 when the child came back, when the mother came back from
12 the Court and proof that she had started counseling, then
15 and take the child without first giving the Court notice
16 that she had done this. But she did it and she filed the
19 of your order --
21 Court.
1 happened.
7 together.
10 that, by all means, file the rule on that. This is, I’m
1 Court.
8 one.
14 transcript or --
16 Honor.
20 moment.
22 according to my document.
6 just gave me. I’m just trying to follow along with what
12 this copy, the Court would just bear with me, I will --
16 the area, where she’s living, and that she’s started the
17 psychological evaluation.
4 this?
8 That’s unquestioned.
3 the area.
12 talking about?
15 house and take the child without the Court even knowing
22 -
2 thought that I meant that she just let him know and that
6 Mr. Miller, and said here’s what I’m going to do, I’m out
8 Maryland case.
14 the Rule to Show Cause and order that she return the
17 client to testify?
19 rules here. We can set the rules with the rest of the
20 case.
9 with her.
14 appreciate it because --
17 her the benefit of the doubt with all these things coming
21 to the Court?
10 at the hearing.
16 and even when she was coming up here and I thought about
17 it and I was like, well, you know, the mother has been
21 the mother has been the primary care giver. If she comes
2 physical custody.
4 but --
19 violation.
22 find for a rule today. But let me, let me ask that the
4 --
9 the Court?
1 interest.
16 interest.
18 we’re just lucky that, you know, that I’m not going to
3 the Court the opinion that the mother was very, very ill.
11 the rule and set it down for the same day everything else
12 is set.
21 to her health?
10 because --
15 April 18th for that rule? It will take some time I think.
20 now.
1 one that we have before the Court now? How long do you
4 rule will be part and parcel of the case that we’re going
6 just --
14 Services Unit.
16 selection --
18 mind?
21 determination.
7 evaluator.
18 do. You can submit three names. You can submit three
19 names and you can submit three names, and the Court will
6 -
19 mother.
21 pleasure --
18 And when the case initially came in, the initial report,
1 hearsay.
9 that --
13 Unit?
20 psychological.
3 psychological evaluator.
6 pick her, I don’t have a problem with her picking her own
8 different story.
11 psychological evaluations.
16 evaluation.
3 my defense is.
6 important.
8 as well.
10 that?
15 just say if it was good enough for the father, then it’s
18 father would --
9 weekends.
12 THE COURT: I --
21 weekend.
5 can take them back to the house the day runs from 8:00
6 until 6:00?
19 year.
2 is --
8 right?
11 moon.
14 Passover?
19 all --
2 sundown.
6 service.
15 --
5 weeks?
8 every Sunday.
12 Court?
17 by the mother --
1 order.
8 discuss, number one, when the mother and how the mother
21 result --
10 we had not withdrawn the child from the German school and
15 day’s visitation.
3 the child would have been in two day cares during the
4 day. And that wouldn’t have been good for the child and
7 Litem what the best thing to do for the child was at that
8 point.
20 respond.
12 the fact --
18 afternoon.
4 I’m not --
8 comments.
11 have emails that are placed on the YMCA website that say
21 11th.
2 issue.
4 down.
17 Mr. Drury.
19 pleasure.
9 with you?
11 that, Your Honor, but I won’t bore Your Honor with that
16 out the date. Every, this has happened every time we’ve
17 been in Court.
20 then.
2 Honor.
10 you.
16 Honor.
22 amendment?
6 the Court’s --
18 Court.
7 to --
15 to each other.
5 appearance.
8 order back?
17 orders?
2 name.
14 was ordered.
17 Unit.
20 report, but then we came back to Court and they asked for
22 Wood.
19 here --
21 you --
16 Services Unit.
19 saying.
4 There’s no difference.
15 prayers. She’s done it from the time that she was born.
6 Honor.
10 be --
16 order?
19 Friday at 6:00 --
17 is.
5 MR. O’CONNELL: No --
15 this --
20 Honor?
18 mother’s expense?
2 You can go back, Mr. Drury, and read the transcript, but
6 been accepted.
4 the rule that I was asking for in my rule, but we’ve been
CAROLYN J. TIMKO
Court Reporter
The basis for the decision determining custody or visitation has been communicated to the panics orally or in writing.
3. A supplemental sheet with additional findings andlor orders is attached and incorporated,
4. Relocation. Each party intending a change of address shall give 30 days advance written notice ufsuch change of address to the
murt and ottier party, pursuant to Virginia Code 5 20-124.5. Unless otherwise provided in this order, this notice shall contain, the
child's fall name, the case number of this case, the party's new telephone number and new street address and, if different, the
party's new mailing address. Unless otherwise provided in thia order,the uvlicc shall be mailed by first-class or delivered to this
court and to the other party.
5. Access to Records. In accordance with Virginia Code 3.0 124.6, neither paicnt, regardless of whether such parent has custody,
shall he denied access to the academic or health records of that parent's minor child, unless otherwise provided in this order or, in
the case ofhealth records, if the minor's treating physician or clinical psychologist has made a part of the child's health record a
written statement that furni-hing to or review by the parait ufsuch health records would he reasonably likely to cause substantial
harm to the minor or another person,
6. This Order is FINAL TEMPORARY md a final hcaiing on this matter will be held on
Wiggins - COJ
FORM DC-573 - 000187
(MASTERS REVISED 11W
Wiggins - COJ - 000188
C O P Y
V I R G I N I A
* * * * * * * * * * * * * *
MICHAEL H. PFEIFFER, :
Petitioner, :
ARIEL R. KING, :
Respondent. :
IN RE: XXXXXXXXXXXX
DOB: 05/07/2003
* * * * * * * * * * * * * *
Arlington, Virginia
- - - - - - - - - - -
APPEARANCES:
Guardian Ad Litem:
C O N T E N T S :
E X H I B I T S :
IDENTIFICATION EVIDENCE
1 P R O C E E D I N G S :
5 Your Honor.
20 say?
1 for.
4 cause.
8 for contempt.
14 from the father’s custody and you didn’t like the way I
17 one that she was found in contempt for but was set for
22 comment on that.
14 18th but I thought that the Court said that we were going
18 for?
2 same day.
4 a custody evaluator.
7 tell you.
11 contacted her.
23 just found out last week who the Court had selected. Of
5 actually --
11 to submit three names and then the Court would pick the
14 person.
23 the clerk to call you and she told me she called you and
3 checked with the Court to see what the hold up was with
4 the person.
6 finally did get hold of Michelle Wood and she told me Dr.
7 Pfeiffer last week, excuse me, not Dr. Pfeiffer, Dr. Eban
12 you filed.
15 correct.
17 what I did.
23 well and she needs to leave. So let’s deal with that and
11 hearing date.
13 with Dr. Lane were a lot about his frustration about not
15 canceled.
11 the trial for the 18th to a date, I’d like to think it’s
12 not going to take much more than six weeks, I would like
21 when the trial date was. She said she was too busy. But
12 -
14 McFarland.
7 --
9 school.
11 know.
3 don’t understand.
6 continued.
8 Honor?
10 sure I’m off that day, that week I think I’m off.
12 Judge?
17 you want me to hear it, then find another date. June 9th
6 day.
10 to take?
20 4th?
8 custody evaluator?
20 new date?
7 been taken off the docket for the 18th, I’m going to
2 February 8th?
8 Court.
16 to the father?
12 who asked what I’m asking now. She just wants the Court
18 testify?
20 Yes.
4 long?
19 circumstances.
21 rule to show cause and she didn’t cooperate with Dr. Lane
3 first.
11 information.
17 does she admit or deny those two rules, that she didn’t
18 cooperate --
3 that then. Will all the witnesses please stand and raise
7 please.
9 outside.
11 point?
14 that.
17 Whereupon,
22 DIRECT EXAMINATION
23 BY MR. CALLAHAN:
13 BY MR. CALLAHAN:
17 Q All right.
19 separated?
21 Q All right.
23 separation.
4 foreclosed on --
6 relevant.
21 BY MR. CALLAHAN:
4 Honor.
5 BY MR. CALLAHAN:
13 hear it.
15 question.
16 BY MR. CALLAHAN:
4 about the fact that even though the Court gave that
16 BY MR. CALLAHAN:
2 today.
3 Q All right. So --
7 BY MR. CALLAHAN:
9 your child that Dr. Pfeiffer had that was not ordered?
10 A Of course.
11 Q Okay.
15 the German School had a bout, one of the worst years the
16 teachers said --
19 BY MR. CALLAHAN:
13 wheezing.
14 Q Uh huh.
20 Q All right.
1 said to me, you know, I’m not really sure about this, I
4 up. And it wasn’t just those days. She was actually out
6 the school has a policy that when the child is sick, you
8 Q All right.
11 A Yes.
13 that your husband has primary custody and you have the
15 A Yes.
19 Q Okay.
6 understand that.
13 Q Right.
14 A But no name.
17 Q All right.
19 by Dr. Lane?
20 A That’s correct.
21 Q Okay.
1 Q Okay.
4 Q Okay.
14 BY MR. CALLAHAN:
16 A Yes, I did.
17 Q How many?
20 appointments?
11 with him.
15 Q Okay.
17 participate in.
18 Q All right.
21 A Yes, I do.
23 cooperate in that?
1 A Yes, I do.
2 Q Okay.
4 going to be today?
5 A Yes, I did.
8 BY MR. CALLAHAN:
11 A Yes, of course.
16 BY MR. CALLAHAN:
18 A Yes, of course.
19 Q Okay.
1 6:00, but she goes to school but my last counsel and his
5 from 8:00 a.m. until about 7:00 or 7:30. And then three
11 Your Honor.
16 every day. The parents are bringing the child back and
22 Honor?
7 filings regarding --
11 BY MR. CALLAHAN:
13 ordered, why was that, back when you had custody of your
14 daughter?
22 Q Medical records?
23 A Yes, of course.
2 CROSS EXAMINATION
3 BY MR. O’CONNELL:
9 BY MR. O’CONNELL:
21 November 8th?
12 take.
20 on a particular day --
22 you.
1 question?
2 BY MR. O’CONNELL:
12 BY MR. O’CONNELL:
23 BY MR. O’CONNELL:
2 Board?
7 the rule. It’s exactly that act that removed him from
22 were here.
16 or something.
21 irrelevant.
23 BY MR. O’CONNELL:
3 BY MR. O’CONNELL:
6 A Yes.
7 Q When?
18 give the Court the proper information and give them the
19 exact date.
23 here on.
5 February 8th.
7 14th.
1 BY MR. O’CONNELL:
4 dates.
7 February 8th is the rule on that, the date that the rule
10 mixed up. Well, another rule that was here today, you
16 custody change.
10 testimony.
19 lack of cooperation.
22 it if I might.
2 to this line?
8 further documentation.
10 time I’m sharing my order with Your Honor. No, I’m just
16 think.
20 BY MR. O’CONNELL:
23 doctor?
1 A Yes.
5 please?
6 BY MR. O’CONNELL:
16 cooperate?
18 BY MR. O’CONNELL:
19 Q Why not?
1 Lane has called me, emailed me and told me what dates and
6 no?
9 BY MR. O’CONNELL:
20 told her.
22 BY MR. O’CONNELL:
2 t this period?
3 A Yes, of course.
10 rule.
13 don’t answer.
18 BY MR. O’CONNELL:
4 BY MR. O’CONNELL:
6 Dr. Lane?
16 to do it?
19 date.
3 BY MR. O’CONNELL:
17 therefore --
19 3:00.
21 (Recess.)
23 BY MR. O’CONNELL:
18 BY MR. O’CONNELL:
3 BY MR. O’CONNELL:
6 lived.
7 Q Really?
9 cooperate with Dr. Lane to tell him where you were living
14 her.
15 BY MR. O’CONNELL:
18 A Yes.
2 BY MR. O’CONNELL:
5 A No, I didn’t.
14 advises me.
1 me.
5 instruct my lawyer.
8 He instructs me.
11 BY MR. O’CONNELL:
15 document.
16 Q Is it your testimony --
19 when he stated that you told him not to proceed, not to,
1 No.
2 BY MR. O’CONNELL:
5 Before, no, did you ever tell Dr. Lane that you
10 true that on several days that are set out in the rule to
12 daughter but you said you may not take our daughter on
15 physician I told him what was wrong with our daughter and
19 to take the child, did you or not, did you refuse him
22 visitation.
6 question. Did you allow him to take the child out of the
7 house?
13 BY MR. O’CONNELL:
16 Q All right.
18 temperature?
22 came over, I --
4 BY MR. O’CONNELL:
8 temperature.
17 that she had bronchitis and she was wheezing. It was the
22 1.
3 exception.
8 a business record.
10 it in.
14 exception?
15 BY MR. O’CONNELL:
19 A No.
22 A No.
3 of those things?
15 the child get picked up. There has been an offer to have
17 us.
4 witness?
6 she could go take care of her mom and leave the child
12 the mother said she was, but it really is not why we’re
18 today, right?
21 Court --
16 orders.
3 and --
5 cooperation, yes.
21 three rules, but how does this relate to the three rules?
2 those --
5 left the child with the father while she went to take
8 and needed her help, then why not leave the child here
9 for the father to take care of the child while she takes
11 do.
13 explain that.
22 life.
7 MR. CALLAHAN: So --
18 stated.
23 to be a witness.
9 BY MR. CALLAHAN:
12 advance, correct?
13 A Yes.
15 date of Court?
18 hearing.
21 correct?
22 A Correct.
3 my husband.
6 Q Uh huh.
12 Q Okay.
14 heard that Friday? What was the next thing you did?
16 Honor. We can stipulate that she came all the way back
23 question.
1 BY MR. CALLAHAN:
3 the next thing you did when you left the Court that’s
5 A Right, okay.
8 us since July --
9 Q Okay.
11 time that I would be dropping her off and dropped her off
14 Atlanta?
16 Friday.
17 Q Friday, okay.
20 mother.
23 Q Okay.
1 A With my daughter.
6 Q Okay.
7 What time?
9 Q Okay.
12 Q Uh huh.
19 BY MR. CALLAHAN:
20 Q Flew back to --
22 Q Okay.
2 attending physician --
8 home.
9 Q And okay.
11 her daughter --
13 even though she was stable, she wasn’t able to sit up,
16 Q Right.
18 Q Right.
22 Q Okay.
1 A That’s correct.
2 Q Okay.
4 clinics.
5 Q Okay.
8 Q Okay.
10 A It was necessary --
15 Q Okay.
19 --
20 Q Uh huh.
23 Q Okay.
8 Q Uh huh.
10 Q Okay.
14 A Uh --
16 A No.
21 back and also attached a copy of the lease for our home
22 in Potomac, Maryland.
23 Q Okay.
3 psychological testing?
7 to an appropriate person.
8 Q Okay.
11 beyond --
13 when I came back and knew that I had sent the information
15 psychological.
16 Q Okay.
22 daughter on Monday?
23 A No.
4 night.
5 Q Okay.
6 Did you, well, where did you, did you say she
7 was at school?
9 10:00 actually I called him to say how was her first day
11 Q A.m. or p.m?
13 while.
14 Q Right.
17 Q Okay.
21 was her day and she said she didn’t go to school. She
23 Q Okay.
4 Q Okay.
8 school.
9 Q Okay.
12 Q Okay.
14 anything?
16 didn’t even know right away that she wasn’t there. The
22 letter that --
13 here today?
20 been?
23 would be relevant.
10 twice and then she went there. It’s offered to show why
22 that.
1 BY MR. CALLAHAN:
4 A Yes, I did.
9 find her.
10 Q Okay.
11 All right.
23 there. Why doesn’t she just call the father and find out
4 didn’t.
8 BY MR. CALLAHAN:
16 Q Okay.
19 counsel?
21 Tuesday.
3 Q Okay.
11 BY MR. CALLAHAN:
15 Q Okay.
16 A At the time --
1 to go there.
9 BY MR. CALLAHAN:
15 A February 12th.
18 call?
20 --
1 BY MR. CALLAHAN:
2 Q Okay.
4 Q Okay.
7 Q Okay.
8 All right.
12 --
18 Tuesday.
22 A Yes, I did.
5 Q Okay.
14 it.
10 show cause.
21 recorded.
19 --
5 happened.
8 BY MR. CALLAHAN:
18 exception.
5 that effect.
13 for yourself, Your Honor. And I will say this, it’s only
17 know --
1 couple of days.
7 don’t know --
9 wasn’t open.
13 BY MR. CALLAHAN:
15 hear?
18 Q Uh huh.
21 Q Okay.
1 didn’t open the door for me. I always open the door for
2 him.
3 Q Okay.
6 Q Okay.
10 hear it. She said walk down the stairs and wait outside.
13 Q Okay.
15 Q All right.
18 Q Okay.
22 Q Okay.
1 the order.
5 Q All right.
10 Q Okay.
21 you failed to tell them the whole story? You gave them
3 that?
9 the counsel asked to come back to Court and you said, no.
10 You said, when she comes back show us where she’s living
15 question was, did you tell the police the whole story and
16 the answer is no. You didn’t tell them the whole story,
17 that I had ruled that the child stay with the father
2 with the father up until, you know, stay with you, no,
3 stay with the father until we have the hearing and then I
10 to do.
14 BY MR. CALLAHAN:
16 by this time?
19 take a moment.
20 (Brief interruption.)
22 BY MR. CALLAHAN:
3 correct?
6 A Right.
17 BY MR. CALLAHAN:
2 Q Right.
3 So then --
18 BY MR. O’CONNELL:
20 did you?
7 Q When?
8 A On the 12th.
9 Q What time?
13 had to --
16 A Yes.
17 Q And who else did you notify, well, who did you
18 notify before you picked up the child that you were back?
19 A My counsel.
21 A I notified my husband.
23 in town?
8 records, please?
10 to look at it.
17 BY MR. O’CONNELL:
19 him when you called him and told him you were back
22 A That is true.
2 going to, I was very afraid that he was going to take her
8 A Yes, he did.
11 A Yes, he did.
21 BY MR. O’CONNELL:
1 the things that you thought that the Court wanted you to
2 complete?
3 A I called my attorney --
9 She’s the lay person and I don’t know what her answer
13 answer.
17 BY MR. O’CONNELL:
22 child yourself?
2 attorney/client privilege.
4 BY MR. O’CONNELL:
12 talked to him.
16 BY MR. O’CONNELL:
18 minutes?
20 front of me.
21 Q Okay.
9 the morning.
13 not she’s still pretty sick, but I thank god that she’s
14 alive.
17 and drive her all the way here on a 12-hour trip in the
21 together.
3 circumstances.
11 do you think?
22 away.
7 BY MR. O’CONNELL:
10 of the child?
15 have to be --
17 just went and picked the child up. I mean, I don’t know
18 what else do you want her to say? Didn’t she say, she
21 BY MR. O’CONNELL:
23 A I spoke to my counsel.
3 BY MR. O’CONNELL:
11 questions he asked.
6 REDIRECT EXAMINATION
7 BY MR. CALLAHAN:
17 child.
22 BY MR. CALLAHAN:
5 Miller.
19 Your Honor.
21 BY MR. CALLAHAN:
2 living.
5 admitted.
7 the fact, after she had already taken the child, then the
17 rule?
2 evidence.)
4 BY MR. CALLAHAN:
7 A Yes.
12 BY MR. CALLAHAN:
15 problems. She still has problems with her heart and her
22 Q Okay.
3 A I did --
7 material again.
15 that.
18 cross exam her about what she says about it. I’ll be
20 BY MR. CALLAHAN:
3 BY MR. CALLAHAN:
5 A No.
10 Your Honor.
4 family emergency.
9 emergency.
12 emergency.
17 Atlanta and get the child and bring her back here. She’s
19 Atlanta.
3 failure. She was here that day. She flew back, she flew
4 back, she flew down, I’ll say down and up. She flew down
7 mother.
11 she’s followed all your orders. Now what does she have
13 and show that she’s back in the area. Okay. And then
16 She didn’t file the praecipe, she didn’t wait. But, Your
17 Honor, can you find that’s willful? I mean, that was the
18 easy part. That was the easy part. She did the hard
19 part.
23 comes back into town, she doesn’t tell the father she’s
6 house, calling the police and having the police come out,
7 showing them the order that the Court had entered without
21 best interest.
1 thing that her mother had just got out of the hospital, I
2 don’t understand why she would drag her mother, who just
5 being with her mother in Georgia and help her get better
7 with the father. And that was, with her with the father
12 of her.
17 She had to come back and she had to bring her mother.
20 Atlanta?
23 her mother was not released from the hospital that day?
4 the information; she just went and was just going to take
5 the child.
14 complied with it. And she had to also let the Court know
15 that she did, that she was going to do this. She didn’t
19 in time.
3 Court order.
10 and the father agreed not to take the child out. So the
16 Lane to, you know, arrange a visit, and also by her own
17 testimony that she moved and did not even inform Dr. Lane
22 to you and come to the home and visit you with the child.
7 moved and did not contact Dr. Lane and that, that she
11 make the moves, to make the appointment. She was the one
17 didn’t call; she didn’t write. She thought Dr. Lane was
21 definitely --
3 completed.
21 contempt of Court.
5 And --
12 that she was going to wait for Dr. Lane to contact her.
19 even with that, I still let her, you know, when I make my
20 ruling about the child going with the father, I was still
4 she doesn’t feel like she has to follow the Court orders
5 or what, I mean --
3 parent when you’re going to see her and when you’re not.
14 O’Connell?
16 her that she’s not going to get the message. I’m not
22 after --
5 Honor.
10 if her daughter was not being taken care of, but this
15 had, I think I made it clear that the fact that the child
3 it.
7 care for her here, for her mother here. She lives, three
19 that she had to bring her back that day because she had
20 to work because that wasn’t the plan when the motion for
10 with that.
13 child with you is the point. Let the child stay here in
14 her environment while she goes and deals with her sick
17 needs, leave her with her father and let her father take
19 with that.
22 This Court ordered her to bring her daughter back and she
3 She did the stuff that costs time, money and stress.
8 Judge.
2 Court.
4 you like to say as far as what you think the Court should
5 do as far as disposition?
13 way.
18 too.
21 place many times in our lives and I’m just saying that --
5 Dr. King, Ms. King, I just don’t know what to make of it.
7 Court, you know, and Ms. Olin says that now you’re
11 the Court, even though, there are orders of the Court and
19 18th?
10 6:00 p.m.
12 Your Honor.
15 is.
22 visitation.
4 much of that time because she feeds her too late. But in
5 any case, this is not the time to bring that up. Your
20 she should carry on with what she has and she has
10 actually the first week and then Mondays and Fridays the
1 Honor.
5 weekends --
15 weekend --
11 idea that somehow we’re not being the giving people that
19 the other.
4 can consider.
7 problem.
21 that we’ve had. Mr. Drury first contacted me, asked for
9 using video tape, the transfers and it’s caused the child
13 this clear. Okay. You should make this easy for your
19 see you, you know. Just make it easier for the child to
1 coming, but we’ll be back here June 6th before the summer
8 come back --
11 picks her up, I mean, 7:00 is too late for this child.
4 pajamas on or not.
13 respond to it.
18 morning.
22 on Thursday.
14 have visitation.
18 can make it that it’s the weeks that she does not have
1 them --
9 fifth week.
19 change of custody.
21 I?
CAROLYN J. TIMKO
Court Reporter
FORENSIC INTERVIEW
Adana-Leilani King-Pfeiffar
DOB: O5//07/2003
Interview Date: 02/28/08
Interview Time: 1428 - 1547 hours
Interviewer: Daryl B, Leach, LCSW-C
Allegation: Sexual ahuse
CONTENT:
Ariana talks about Mr. Piggy at her father's house. She identifies Mr. Piggy as a "toy" that
"wears a purple hat, shirt, and a tie". Mr. Piggy eats and has a voice. He says "oink, oink, oink".
She characterizes Mr. Piggy's voice as having a very high pitch. She tells the interviewer that
Mr. Piggy "has seen my underpants" with an action explanation showing that she covered herself
as Mr. Piggy looked over his shoulder at her. Mr. Piggy i s in the "big bed" at Papa's house. Mr.
Piggy says, "I'm so tired". There is no further information on Mr. Piggy in the big bed.
Ariana identifies herself as a girl. She gives the interviewer her names of body parts for both
male and fcariiale figures during the body inventory inquiry.
Ariana identifies kisses that are okay come from mommy, grandma, sister, and daddy. Hugs that
are okay with Ariana come from mommy and daddy, Ariana denies that her body has been
touched when it was not okay with her.
Ariana identifies the back, pop0 (derriere) gina (vagina) and feet as places on females that are
not to be touched. Ariana denies that anyone has touched these areas on her body. Ariana does
talk about the pop0 in terms that did not make sense and Ariana did not explain further. Ariana
says, "Popo just hurt and harderand hmdcr----it just gets harder".
R"h,en Ariana goes to Papa's house, she reports "he smiles...he kissed me on my head, eyes nose,
my mouth". This is okay with Ariana, She also talks about their activities together, "we
play.. .we eat...we sleep...we brush our teeth.. .we read stories". When Ariana cannot fall
asleep, Papa holds her like a baby and smiles at her.
Ariana reports she sleeps "in a big bed". Mr. Piggy is in the bed with no further information.
"Papa in the bed ant that's all.. .we read a story.. .Papa sleeps and then he went to his bed.. .that's
all I have."
Fttmily Crimes Division
7300 Callioun Place, Suite 300 .
Rockville, Maryland 20855 240-773-5400 TTY 240-773-5465
Wiggins-COJ-329A w\vw,nion~go~~~i:ryco~ui~~~~d.gov
Mother taught M a n a the name penis for the male genital. She further explained that she uses
only the girl's bathroom, not the boy's bathroom.
Ariana reports that she has seen her father's penis. She peeked into the bathroom when Papa had
closed the door and saw him urinating
Ariana says, "I don't touch penis.. .no touch gina.. .you don't touch them (pope). ..never touched
a popo.. .no, Mr. Piggy doesn't touch (my) body.. .anybody doesn't touch.. .1don't touch
anybody's things".
CONSISTENCY:
Ariaha is consistent in her denial that she has been touched and that she has not touched
anyone's body. Areas of the female body that arc not to be tuuuhcd were identified by Ariana as
the vagina, derriere, feet and back.
Ariana was consistent about Mr. Piggy being a toy that she gives human characteristics.
According to Ariana, Mr. Piggy has not touched her body.
CONTEXT:
Ariana describes her visits to her father's house with smiles and laughter. The activities Ariana
talks about at her father's house appear to be ordinary; eating, sleeping, reading stories at
bedtime.
ABILITY:
Ariana appeared to be developmentally appropriate in the interview. She is able to make the
representational shift from the female body inventory drawing to her own body when discussing
touch. She ably identified herself as female and was able to say that her body was like the
female picture.
Ariana was not able to tell about events in her life in an organized manner, with a beginning,
middle and end. This is another example of being developmentally appropriate. Ariana knew
and verbalized many details. Being able to organize facts will naturally come later in her
cogitative development. The result is that Adriana can appear to be confused or lack knowledge
about her life activities, which she is not.
AFFECT: -
Ariana engaged with the interviewer immediately. She was cooperative as she was working hard
to convey be; hiowl~dgcabuul the various subjects that were discussed. Adriana corrected the
interviewer on several occasions as well as giving details that were not asked about. An example
was in the beginning of the interview, when Adriana took the marker to properly draw her
Wiggins-COJ-329B
father's large face and her details about his appearance. h e n Adriana was certain about her
information, her voice would become stronger and stem.
-
On an emotional level, Adriana did not show fear or feeling scared with the significant adults in
her life. She displayedjust the opposite, feelings of love and happiness when talking about
either of her parents.
Many statements made by Adriana were spontaneous. She had little trouble understanding the
focused open-ended questions. If there was a problem, it was the interviewer not asking clear
and concise questions. It appeared to the interviewer that Adriana had more thoughts in her head
than she had language to use in explanations.
Adriana appeared to have difficulty staying focused on any subject matter for more than a few
minutes. She was physically active during the entire interview, not sitting for longer than a few
minutes. Staying active parallels focusing time frames for Adriana, It appeared to the
interviewer that Adriana thinks and speaks more clearly when physically active.
Wiggins-COJ-329C
CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND
50 Maryland Avo, Rockville, MD 20350
Located at
Telephone No. 240-777-9402 case N o . r Y o m o ~ ~ 1
TEMPORARY PROTECTIVE ORDER
PETITIONERIPLAINTIFF
ARIEL KING ...
First Middle Last Data of Birth
and any minoris) or minor child(ren) on whose behalf the OTHERS TO BE PROTECTED:
petition was filed. (List names and date(s) nf birth.)
ARIANA LEILANI KING-PFEIFFER 05/07/2003
Name DOE Name DOEX
Relationshipto Petitioner
Spouse Former Spouse Vulnerable Adult
Cohabitant Children In Common n Parent
Other relationship
4836 RESERVOIR RD..3
Address DRIVER'S LICENSE if
I
-
I
WASHINGTON, DC 20007 202-427-4009
Cily, Slailw, Zip ~elephone -- - -
CAUTION: 0 Weapon Involved VEHICLE DESCRIPTION TAG NO.
Violation of this Order may result in criminal prosecution, imprisonment and/or fine, and contempt of court. Law
enforcement shall arrest a person whom the officer has probable cause to believe is in violation of this Order, as
required by Maryland Code. Family Law Article, 5 4-5n8. This'Protective Order shall be recognized and enforced
by the courts of any state, the District of Columbia, any U.S.Territory, tribal lands (18 U.S.C. $2265) or
Department of Defense installations. (10 U.S.C. 5 1561a) Crossing state, territorial or tribal boundaries to violate
this Order may result in federal imprisonment. (18 U.S.C. g 2262)
Federal law provides penalties of up to $250,000 fine and 10 years in prison for possessing, transporting, shipping or
receiving any firearm or ammunition while subject to a protective order or after being convicted of a misdamaanor crime
of domestic violence (18 U.S.C. 5 922(g)(8)) or knowingly transferring a firearm after a conviction of a misdemeanor
,-,. .'
Crime of domestic violence (18 U.S.C. 6 922faY91).
Questions regarding this notice should be directed to your allomey, law
State Police Firearms Enforcement Section at 410-290-0050.
--
Wiggins - COJ - 000330 Page Iof a
JUN 02 2008
Clerk of
nh,.*---- -
the,Circuit Court
Case No. 70620FL Date: 06/02/2008 5:34 p m
After the appearance of the PETITIONER, and in consideration of the Petition and evidence, the Court makes
the following findings:
A. That ARIANA LEILANI KING-PFEIFFER , who is a Person(s) Eligible for Relief, is:
The current spouse of the Respondent.
An individual who has a chlld(ren) in common with the Respondent: ARIANA LEILANI KING-PFEIFFER .
C. That there are reasonable grounds to believe that Respondent committed the following abuse@):
Statutory abuse of a child (Physical, Sexual) (Forward to DSS for investigation)
5. That custody of ARIANA LEILANI KING-PFEIFFER is awarded to ARIEL KING until the hearing provided for
in Paragraph 6 below.
6. THAT A FINAL PROTECTIVE ORDER HEARING SHALL BE HELD ON June 9,2008 AT 09:30AM A1
CIRCUIT COURT AT 50 Maryland Ave, Rockville, MD 20850.
7. This Order supersedes and overrides any previously entered Interim Protective Order issued by a
Commissioner.
Date: 06/02/2008
JUN 02 2008
ENTERED
JUN 02 2008
Clerk of the Circuit Court
Montgomery County, ~ r f
NOTICE TO RESPONDENT
A Petition for Protection alleges that you have committed abuse. On the basis of the Petition this Temporary
Protective Order has been issued. Violation of this Order may be a state and/or federal crime or contempt of
court, or both, and result in imprisonment or fine or both. This Order may be enforced by another state or
jurisdiction, which may Impose additional or different penalties for the violation.
In order to respond to the allegation that abuse occurred, you must appear in court at the Final Protective
Order hearing provided for In thie Order. If at the heerlng the court finda by clear and convincing evidence that
abuse occurred, the court will issue a Final Protective Order against you, whether you appear or fail to appear,
and may order all or part of the relief requested by the Petitioner or granted in this Order. This relief may include
temporary use and possession of your home, use and possessionof jointly owned vehicles, Emergency Family
Maintenance, child visitation, surrender of firearm($) to a law enforcement agency, and counseling or
participation in a domestic violence program. A Final Protective Order may be effective for as long as twelve
(12) months, and the court for good cause may extend the term of the Final Protective Order for an additional six
(6) months after a further hearing.
If you fail to appear in court and a Final Protective Order is issued against you, you will be served by first-
class mall at your last known address with the Final Protective Order and all other notices concerning the
Protective Order. The Final Protective Order will be valid and enforceable upon mailing. It is your responsibility
to notify the court in writing of any change of address.
Although each party is not required to have a lawyer at the hearing, all of the Rules of Evidence will apply
to the case. If you choose not to have a lawyer with you on the hearing date the Petitioner will still have to
prove me case by "clear and convincing evidence" and eacn party will have to comply with me Rules of
Evidence. Due to the emergency nature of the hearing, the hearing may be held even If a party requests more
time to obtain an attorney.
At the Final Protective Order hearing the court may order the Respondent to pay Emergency family
Maintenanceand may pass an immediate and continuing withholding order for that purpose. If this Emergency
Family Maintenance is requested, both parties should complete a Financial Statement (CC-DClDV4) before the
Protective Order hearing and bring it to court. You should also bring documents (such as pay stubs, copy of
your lease, bills, etc.) to support the figures you supply.
ENTERED
JUN 02 2009
Clerk of the Circuit Court
Montg'orneryCounty, Md,
Wiggins - COJ - 000333 Page 4 of 5
Case No. 70620FL Date: 05/02/2008534 p.m.
TRUE COPY CERTIFICATION OF TEMPORARY PROTECTIVE ORDER
Attestation of Clerk
I, Loretta E. Knight, Clerk of this Court in MONTGOMERY COUNTY, State of Maryland, do hereby certify that I
have compared this Order with the original Order which is on file in my office, and that this Order is a true and
correct copy of the original, and the whole thereof.
- .#
Loretta E. Knight, Clerk of Court
Attestation of Judge
I, David A. Boynton, Judge of this Court in MONTGOMFRY COUNTY, State of Maryland, do hereby certify that
Loretta E. Knight whose name is subscribed to the foregoing certificate of attestation, now is, andlor was at the
time of signing and sealing the same, a Clerk of this Court in MONTGOMERY COUNTY and that histher
attestation is in due form of law.
Date: 06/02/2008
Court: Circuit Court for MOntgOm0ry County, Maryland
Address: 50 Maryland Ave, Rockville, MD 20850
Phone: 240-777-9402
To request a foreign language interpreter or a reasonable accommodation under the Americans with
Disabilities Act, please contact the Court Immediately.
ENTERED
JUN 0 2 2008
Clerk of the Circuit Court
Montgomery County, Md.
Page 5 of 5
Wiggins - COJ - 000334
CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND
50 Maryland Ave, Rockville, MD 20850 Case No. 70620FL
ARIEL KING olio Date: 06/02/20005-34 p.m.
ARIANA LEILANI KING-PFHFFER us MICHAEL H. PFEIFFER DR
4838 RESERVOIR RD 3
WASHINGTON, DC, 20007
RETURN OF SERVICE
BY LAW ENFORCEMENT OFFICER
I CERTIFY that:
I served a copy of the 0 Petition and Interim Protective Order Petition and Temporary Protective Order
Final Protective Order Petition for Contempt and Show Cause Order, filed in the above entitled case, on:
at
Name Address
on- at
Date Time
0 I could not serve a copy of the 0 Petition and Interim Protective Orderfl Petition and Temporary Protective Order
Final Protective Order 0 Petition for Contempt and Show Cause Order, filed in the above entitled case. on:
-. -
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Wiggins - COJ1212004)
- 000335
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further abuse or reveals the confidential address of ashelter. If this is the case, check h e r e n Ifwu need additional
pa ,ask the clerk.)
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1 ;.'i'^LsBe Respondent committed (he following acts of abuse against
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At this time the victim can be found at
l am Stntcb Attorney I""] DSS &relative an adult living in the home.
3. The pa'flon(s) I want protected are (include yourselfifyou are a victim):
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dused
sf-ofped nc. 4ovtv.6
\\5£ li^Ccfced h& AA ^he b?loa< fifsdot^ctO
the victim, and give date, ifJinown
8. I want the court to order the Respondent: (NOTE: Petitioner need not give an addressif doing so risks further abuse.)
to t e n to b e /tgAd h 'la 6 +LU d 4u i* ~ M - V~~ VU.
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9. I also want the Court to order:
d custody of ~ ~ R ~ Ã ˆ A^tm6
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be granted to w.m.
10. (Fill in only ifyou are seekingEmergency Family Maintenance.) The Respondent has the following financial
resources:
Income from employment in the amount of $ every week 2 w e c k s 0 month
Otto -
Source of employment income
e tddrtss of sow" mdafflounwiilmc&Rc3"
~ a m said
Income from other source and amounl(s) received
~~oinS'atlBrcaB'ofaourcc
The Respondent also owns (he following property of value: Automobilc(s) $
aitiinatoil value
Home $ Bank Accountfs) SP
" " E s f l n i a t c d value
Other:
Estimated Value
I solemnly afflrm under the penalties of perjury that the contents of the foregoing Petition are true to the best of my
knowledge, iirfbnnation and belief.
Fentirn"
/
q I have filled in the Addendum (Description of Respondent), CC-DCmV 1A
NOTE
If you believe that you have been a victim of abuse and that there is a danger of serious and immediate injury to
you, you may request the assistance of a police officer or local law enforcement agency.
The law enforcement offiicar must protect you from hami when responding to your request for assistance and
may, if you ask, accompany you to the family borne so that you may remove clothing and medicine, medical devices, and
other personal effects required for you and your children, regardless of who paid for them.
You are entitled to request that address and telephone number of a victim, a complainant, or a witness be considered for
shielding at the filing of this application.
NOTICE:Remote access td the name, address, telephone number, date of birth, e-mail address, and place of employment
of a victim or non-party witness is blocked, (Md Rule 16-1008(3)(3)(B))
cars Tattoos wh
..
Petitioner's Signature Date
MICHAEL H. PFEIFFER
Petitioner,
ARIEL R. KING
Respondent.
Respondent Ariel King, PhD, filing pro se, hereby respectfully requests this
Court grant, sua sponte, this second request for stay of the above captioned proceedings
and related proceedings, and continue the upcoming hearing scheduled for June 6, 2008,
for the following additional reasons to those presented in its Emergency Motion for Stay,
County Maryland has found that there are reasonable grounds to believe that Dr. Pfeiffer
committed the following abuses: Statutory Abuse of a child (Physical and Sexual); See,
2) per the Temporary Protective Order, Dr. Pfeiffer is prohibited from being in
contact with: 1) Dr. King, 2) Ariana-Leilani, and specifically named places they frequent.
3) as protection for the child, the Circuit Court’s Temporary Protective Order,
awarded temporary custody to Dr. King until the hearing to make the TPO permanent,
condition. Over the last several weeks that blood count has dropped significantly –
while Dr. Pfeiffer has refused to acknowledge any problems with the child’s health.
Hemotologist has instructed Dr. King to keep Ariana-Leilani out of school until the
underlying problem is fully diagnosed, and treated. Exposure to other children is now
considered a severe risk to Ariana-Leilani. Given the urgent nature of the medical
lives with her mother in Montgomery County Maryland for part of the week, and lives
with her father in Washington DC for the remainder of the week. Ariana-Leilani King
Pfeiffer has been experiencing symptoms of abuse for some time, which symptoms have
become acute since this Court has changed the custody schedule to requre Ariana-Leilnai
1
As previously argued before this Court and not waived by this or any other filing or appearance, this
Court does not have subject matter or continuing exclusive jurisdiction to conduct this proceeding. See,
Petition, Dr. Ariel R. King, Case No. 080963, Supreme Court of Commonwealth of Virginia. It is also
noted that no party to this proceeding has lived in Virginia since October 2007, and before that for only a
temporary period of approximately three months. This Virginia case was brought by Dr. Pfeiffer (a
Washington DC resident who has never lived in Virginia) after Dr. King had tempoarily lived in Virginia
less than 29 days. It is a waste of judicial resources of Virginia – by a non-resident of Virginia against a
Maryland child -- that are better spent on other matters.
2 It is my understanding that on Monday June 2, 2008, Dr. Pfeifer brought Ariana-Leilani back to school
with a “physician’s letter” – presented it to the teacher --- claiming that Ariana-Leilani is well, when he
knew that she, in fact, was very ill.
deteriorating situation. As a result they now have severely elevated concerns, which
The Montgomery County Circuit Court is aware of the status of the Virginia and
Maryland child custody proceedings. Maryland remains the “home state” of the child
and has the most significant connections to Ariana-Leilani, as well as convenient access
to her medical, school, and other records. It remains undisputed that no party lives in
Virginia.
In light of the TPO and the proceedings in Maryland, as well as the need to
attend to Ariana-Leilani’s medical needs first, Respondent will be unable to attend the
No party would be harmed by the grant of the temporary continuance and stay.
The June 6, 2008 hearing has been scheduled for some time (since February 21, 2008),
and any additional temporary postponement will not harm any party. Conversely, a
failure to grant a stay and continuance would be detrimental to the course of these
proceedings and harmful to Ariana-Leilani King Pfeiffer, subjecting her to even more
abuse by the Father, and further setback in her health. Holding a hearing on June 6,
2008 will also be unfair to Respondent and Ariana-Leilani, as Respondent will be unable
to attend that hearing. It would be ill advised, irresponsible and improper for this Court
* * *
with the Montgomery County Circuit Court and stay the above captioned proceeding, and
- at a minimum -- continue any upcoming hearings until the child abuse is thoroughly
investigated and the Montgomery County Circuit Court determines how to proceed in
3
In the best interests of the child, the Court may wish to confer with the Montgomery
County circuit Court, per the UCCJEA.
MICHAEL H. PFEIFFER
Petitioner,
June 6, 2008 Hearing Pending Emergency TPO Hearing And Investigation By MD DSS,
the Court finds that a temporary stay of these proceedings, and continuance of the
________________________________
Honorable Judge Esther Wiggins Lyles
_____________
Date
I HEREBY CERTIFY that on the 3rd day of June, 2008, a copy of the forgoing Motion
was sent by priority mail to the counsel, listed below:
Sean O'Connell
4113 Lee Highway
Arlington, VA 22207
_________________________
1 VIRGINIA:
3 OF ARLINGTON COUNTY
5 MICHAEL H. PFEIFFER, )
6 Petitioner, )
8 ARIEL R. KING, )
9 Respondent. )
10
11 * * * * *
12
17 Public.
18
19 BEFORE:
21
22 * * * * *
1 A P P E A R A N C E S
7 (703) 558-0000
9 GUARDIAN AD LITEM:
13 Suite 100
15 (703) 293-2901
16
17
18
19
20
21
22
3 and Ms. --
16 the mother.
20 here.
22 a witness.
3 Whereupon --
4 NANCY HEY,
7 follows:
8 DIRECT EXAMINATION
9 BY MS. OLIN:
12 King-Pfeiffer.
14 Court.
17 A. H-e-y.
20 Virginia.
22 address?
9 A. No.
2 Maryland.
4 roughly.
7 A. I don't know.
11 behavior.
14 behavior?
22 hers, to be present.
7 BY MS. OLIN:
13 that time.
18 e-mail.
4 daughter's health.
15 danger.
21 hearing.
1 now?
2 A. No.
4 telephone ever?
5 A. Yes, I have.
7 her?
15 phone?
16 A. I don't know.
1 CROSS-EXAMINATION
2 BY MR. O'CONNELL:
3 Q. Hi.
4 A. Hello.
6 Ms. King?
9 Q. A month ago.
10 A. Yes.
1 A. Yes.
3 A. Yes.
6 dinner.
9 convenient.
11 A. Yes.
17 Q. On the telephone.
18 A. No.
19 Q. You're sure.
20 A. Yes.
5 A. -- in my address book.
6 My e-mail address is
7 cattynancy@hotmail.com.
11 communications.
21 BY MR. O'CONNELL:
4 the phone?
9 A. Yes.
12 A. That's correct.
16 Georgia or someplace?
20 moving, no.
22 move to Georgia?
1 A. No.
10 it?
16 BY MR. O'CONNELL:
17 Q. Were you --
21 BY MR. O'CONNELL:
8 BY MR. O'CONNELL:
11 jurisdiction?
12 A. No.
17 A. L-a-k-r-i-t-z.
20 was there.
4 A. Yes.
6 A. Yes, I was.
9 sometimes.
21 there.
2 BY MR. O'CONNELL:
14 YouTube.
19 BY MR. O'CONNELL:
20 Q. Go ahead.
7 that.
14 reporter, so --
19 potluck.
20 BY MR. O'CONNELL:
1 A. Yes.
7 BY MR. O'CONNELL:
17 date for this case had been set, and she sent an
21 A. I e-mailed her.
4 you?
15 e-mails?
17 Q. Um-hum.
1 BY MR. O'CONNELL:
5 than have --
6 A. No.
22 have that.
2 that.
7 the child.
12 Two days ago she was still talking about that she
12 father.
21 living?
2 University in Arlington.
14 hospital for --
11 BY MR. O'CONNELL:
15 A. Yes.
19 A. I . . .
21 number?
3 A. Yes, I do.
5 A. Verizon.
11 A. Christopher Slitor.
13 of that, please.
14 A. C-h-r-i-s-t-o-p-h-e-r S-l-i-t-o-r.
16 A. No.
18 two of you?
19 A. Yes.
22 name.
2 possession.
12 provider?
16 Q. Okay.
18 that enough?
19 BY MR. O'CONNELL:
21 A. No.
2 A. No.
16 REDIRECT EXAMINATION
17 BY MS. OLIN:
2 A. Yes, I have.
9 A. No.
12 A. No, I don't.
16 I don't know.
8 to regain my composure.
9 in those words.
14 what.
9 relevance.
5 to do today?
12 father. A capias.
20 recommendation?
15 of us today.
19 Your Honor does have a rule upon that that she was
6 of a punishment.
8 Whereupon --
9 MICHELLE WOOD,
12 follows:
13 DIRECT EXAMINATION
14 BY MS. OLIN:
18 child?
22 A. Yes.
6 up.
10 you.
21 father.
22 BY MS. OLIN:
3 A. No.
11 woman?
12 A. Lisa Hoffman.
16 Q. In Maryland?
17 A. Yes.
3 evaluation.
9 motions.
13 that motion.
15 that motion.
1 that's appropriate --
5 Dr. Lane?
9 mother.
13 jurisdiction.
10 20-124.3.
14 Honor. 124.3.
20 were concluded.)
21
22
1 CERTIFICATE OF REPORTER
13
14
Sean P. Goza
15
16
17
18
19
20
21
22
Guardian ad litem
The above-named child has been brought before this Court upon the filing of a written petition or motion concerning custody or
visitation or for which transfer of custody is a dispositional alternative. Legal notice has been given to all proper and necessary
parties. All provisions of the Juvenile and Domestic Relations District Court Law have been duly complied with in assuming
jurisdiction over the child, and all determinations have been made in accordance with the standards set forth in Virginia Code 8 16.1-
278.4, 8 16.1-278.5, 5 16.1-278.6 or 5 16.1-278.8 or 5 16.1-278.15 and $8 20-124.1 through20-124.6.
HAVING CONSIDERED ALL RELEVANT AND MATERIAL EVIDENCE PRESENTED AND THE BEST INTEREST O F
THE CHILD, T H E COURT FINDS THAT T H E CHILD IS WITHIN THE JURISDICTION O F THIS COURT AND
FURTHER FINDS AND ORDERS THAT:
1. 0 The parties are in agreement on the arrangement for the child's custody and visitation:
0 as set forth in the attached document, which is incorporated
0 as set forth below.
2. CustodyNisitation
SOLE LEGAL AND PHYSICAL CUSTODY O F ARIANA LEILANI KING-PFEIFFER IS GRANTED T O HER FATHER,
MICHAEL H. PFEIFFER. THE MOTHER, ARIEL R. KING, SHALL NOT HAVE ANY CONTACT WITH THE CHILD
UNTIL SHE AVAILS HERSELF TO THE COURT AND COMPLETES A PSYCHOLOGICAL EVALUATION.
The basis for the decision determining custody or visitation has been communicated to the parties orally or in writing.
3. 0 A supplemental sheet with additional findings andlor orders is attached and incorporated.
4. Relocation. Each party intending a change of address shall give 30 days advance written notice of such change of address to the
court and other party, pursuant to Virginia Code $ 20-124.5. Unless otherwise provided in this order, this notice shall contain the
child's full name, the case number of this case, the party's new telephone number and new sheet address and, if different, the
party's new mailing address. Unless otherwise provided in this order, the notice shall be mailed by first-class or delivered to this
court and to the otherparty.
5. Access to Records. In accordance with Virginia Code 5 20-124.6, neither parent, regardless of whether such parent has custody,
shall be denied access to the academic or health records of that parent's minor child, unless otherwise provided in this order or, in
the case of health records, if the minor's treating physician or clinical psychologist has made a part of the child's health record a
written statement that furnishing to or review by the parent of such health records would be reasonably likely to cause substantial
harm to the minor or another. person;
. , ,
6 This Order is 6B FINAL TEMPORARY and a final hearing on this matter will be held on
IT IS ORDERED THAT:
MOTHER HAS ABDUCTED CHILD AND MOTHER EXHIBITED BEHAVIOR TO MONTGOMERY CPS WHICH MADE
THE AGENCY CONCERN FOR THE CHILD'S SAFETY_
SOLE LEGAL AND PHYSICAL CUSTODY OF THE CHILD IS GRANTED TO THE FATHER MICHAEL PFEIFFER
AND NO CONTACT OF CHILD BY THE MOTHER UNTIL THE MOTHER AVAILS HERSELF OF THIS COURT AND
UNDERGOES A COMPLETE PSYCHOLOGICAL EVALUATION_
Arlington Juv.nll. , Domutlc
Relatlolll District Court
i, the undenllgned clerk or deputycierI(
0'pursuant
the above named court, authenticate
to Code
Va. on
§8.01.J9tfC)
!hIs date that the document \0 which this,
!1it;-H:mlca~I01! Is affix.ed is a true copy of
~- .() ,--ecool1O !he abow named eourt, mad,
Petitioner, other counsel, and Dr. Lane. No timely response was forthcoming.
discovery request and that it was long overdue. Again, no response was forthcoming.
Finally, on the evening of June 2, 2008, a package was left at Respondents’ home
In this short period of time, only a preliminary review has been completed. However, the
following facts emerge that clearly indicate fraud on the Court and other improper conduct, and
bias on the part of the GAL causing her to act in the best interests of the Petitioner and not the
child.
1) Ms. Olin directed Dr. Pfeiffer, through counsel, to make unauthorized copies of
the child custody evaluation of Michelle Wood in late October to November
2007,
2) Ms. Olin directed Dr. Pfeiffer to have that unauthorized copy forwarded to Dr.
Lane, in an apparent attempt to influence Dr. Lane’s report to the Court.
3) As a direct result of Ms. Olin’s actions, Dr. Lane delayed the production of his
November 8, 2007 report to the Court – falsely blaming Respondent -- and then
Ms. Olin used that that claim to argue for a continuance, apparently in an attempt
to get Ms. Wood to change her recommendations to conform with the
recommendations that Ms. Olin sought out of Dr. Lane,
4) To reassure Petitioner that her “independent” recommendations were in
conformance with the expectations of Petitioner, Ms. Olin provided to Petitioner -
-- and only Petitioner – copies of her draft recommendations days before making
those recommendations known to the Court, Respondent or her counsel.
See, Exhibit I.
Michael: Did you tell your lawyer about the report from Wood?
See, Exhibit II at 2.
Dear Ms. Olin: Yes, he was able to get the report, but we have not discussed the
report yet.
See, Exhibit II at 2.
What about Dr. Lane? I can't get it to him from here - no fax machine. It is
important that he see it before writing his report.
Mother and Father accuse one another of many of the same things - mental health
issues, parenting issues, financial issues. Both parents focus on the weaknesses of
the other, without being able to find a common ground where they can raise their
child. Each sees the weaknesses of the other without being able to see their own
weaknesses. Both are traumatized by the difficulties of separation and divorce,
and this colors their abilities to parent effectively. The child appears to be torn
between the parents, and she is not being protected from the negativity of the
failure of the marriage.
We also have two parents with advanced degrees and training, and neither is
making a living commensurate with their skills. Each conveys blame for the other
I will wait to see Dr. Lane's report, and especially the results of his mental health
evaluations before finalizing my own and making a recommendation as to
custody.
Finally, we have a very young child, and her needs will likely change over the
next couple of years which may well impact custody and visitation later on.
Dear Ms Olin:
Dr Lane also has the report.
Michael
See, Exhibit II at 1.
6) Immediately after receiving Ms. Wood’s Report, on November 7, 2008, Dr. Lane
wrote correspondence to both counsel (presenting that he had no previous correspondence with
either of them) seeking a delay in the deadline for his report. He alleged that because the child
was asleep at the commencement of his home visit (which he had rescheduled a number of times
to result in that late date), he claimed he could not complete his report (when, in fact, the child
had gotten up during his visit and he could have easily completed his home visit – a fact he failed
Ms Olin did not make an independent investigation of the circumstances. Ms. Olin did
not tell the Court that she knew – and encouraged – the copying of Ms. Wood’s report and that it
be forwarded to Dr. Lane in order to influence what Dr. Lane’s actions. The child custody
evaluation standards require no counsel may attempt to substantively influence the custody
evaluator. See, Excerpts of Model Standards of Practice for Child Custody Evaluation,
Association of Family and Conciliation Courts, Exhibit X. However, Ms. Olin did this openly,
counsel -- violate the rules, procedures, and standards for the treatment of Ms. Wood’s report,
and use that report to influence Dr. Lane’s child custody study. Dr. Lane then created this
“issue” of Dr. King now being cooperative, to delay the November 8, 2008 hearing, and, in turn,
to buy time and hopefully get Ms. Wood to change her position to conform to what Ms. Olin
This clearly shows misconduct by the GAL Ms. Olin, and bias on her part. Thus, for this
reason alone the GAL should be sanctioned, and removed from this case.
report to Dr. Lane – hopefully with help by “sweet talking” the clerks – is a violation of the
treatment of the report and misconduct on this Court. For this reason, Mr. O’Connell should be
Finally, all filings, testimony, and evidence by Petitioner and the GAL referring to Dr.
Lane, his report, or any alleged misconduct by Respondent with regard to Dr. Lane should be
stricken from the record for fraud on the court. The contrivance created by Petitioner, in
collusion with Ms. Olin, Mr. O’Connell, and Dr. Lane, was simply a setup to falsely pin on
Respondent the blame for a delay that was intentionally created by these bad actors to give time
to pressure Ms. Wood to change her recommendations (which were originally favorable to
It will now be shown how Petitioner, using his medical credentials in violation of the
HIPAA privacy regulations, colluded with the GAL and Mr. O’Connell to commit fraud on the
court.
correspondence.
On January 20, 2008. Dr. XXX King, the xxxx of Respondent was stricken with a
stroke, that left her in a coma and an intensive care unit in an Atlanta hospital. See, January 31,
In an attempt to intimidate and mislead Respondent’s counsel and the court, on January
30, 3007, Ms. Olin, copying the court and other counsel represented that:
Ray:
I know you would never knowingly mislead the court about facts, so I want to
share with you the latest information (todays’) from Dekalb Hospital. Dr. XXXXX
King is doing well, is out of intensive care, and in the general wards. According
to the hospital, there is minimal damage, and she may be prescribed some
minimal rehab, but on the whole is on the mend. The stroke was a small one with
minimal blood loss. I know that we are all relieved that she is doing better. You
may want to consult with the physicians yourself to be sure.
Mother should be able to fly back with the child for the hearing. If not, then she
should return the child ASAP, as I have suggested before, so that I may complete
more of my investigation.
Deborah Olin
On January 31, 2007, Ms. Olin wrote to Dr. King, reassuring her that what she wrote was
accurate in what she was told by her source, Petitioner Dr. Pfeiffer:
On January 31, 2007, a letter from DeKalb Medical indicated otherwise. See, January
31, 2008 Letter of Dekalb Medical. See, Exhibit VIII. That letter was forwarded to Ms. Olin.
As for the doctor issue, let's be straight. XXXXXXX's doctor gave one story (I
was on the phone with father's counsel while father spoke with doctor on a
different phone in the same room as counsel. I heard the questions, heard the
repeated answers, and asked a few questions myself). Now, I suppose this could be
staged, but what would clear it up would be my conversation with the same doctor.
You can make it a conference call and be on the other line, I don't care. Why
wouldn't one of ya'll think of that yourselves?
See, Exhibit X.
This arrangement was a clear scheme to disclose private medical information in violation
hearing]” Counsel for Dr. Pfeifer trivalized for the court that Dr. XXXXX’s condition:
While it is regrettable that the Respondents xxxx recently fell, the Respondent
has done the following acts which should alone cause the Court to deny the
request and change custody of the child.
b. There never was a large bleed in the brain but the fluid drain avoided the
possible complication of increased intracranial pressure. We know this because
Dr. Pfeiffer, upon the written request of Dr. King, called the neurosurgeon in
the case and was briefed. We also know that the Respondents (sic) has no loss
of speech and no major weakness.
See, Exhibit XI
When GAL Olin and Petitioner’s counsel Mr. O’Connell wrote these statements, they
knew they were false. This is evidenced by Dr. Pfeiffer’s email to Ms. Olin and Dr. Lane
(another third party disclosure in violation of HIPAA Privacy requirements), dated January 31,
He stated that she was somewhat more lethargic than before and he felt that
XXXXXXXXX could have a meningitis, a not uncommon complication after
ventriculostomy. Infectious disease consultation was called and the antibiotics
she receives were adjusted.
See, Exhibit XII.
Note first that there was no support for Mr. O’Connell’s claims that XXXXXXXX
simply “fell.” Second, note that no mention is made in any of the communications by GAL Olin
or Mr. O’Connell that “XXXXXXXX could have a meningitis” and that an “infection disease
consultation was called and the antibiotics she receives were adjusted.” Third, note that, in
contrast to Pfeiffer telling them that XXXXXXXX was “somewhat more lethargic,” Mr.
O’Connell and Ms Olin told the opposite claiming that “We also know that the Respondents
of intensive care, and in the general wards. According to the hospital, there is minimal damage,
and she may be prescribed some minimal rehab, but on the whole is on the mend.”
The truth was that when these representations were made by Ms. Olin and Mr.
O’Connell, XXXXXXXXX was back in the ICU, could hardly sit up, her speech (in the rare
times she was awake) as slurred, and her survival was still in doubt due to the infectious disease,
gave a reasonably accurate general impression of XXXXXXX's condition, GAL Olin and
Mr. O’Connell made fraudulent statements to the Court – providing no candor whatsoever. As a
result, Respondent was forced to leave her xxxx in Atlanta, get on a plane early on the morning
of February 8, 2008, in order to attend a hearing that should have been continued if either Ms.
Olin and Mr. O’Connell were truthful to the Court. Worse yet, and probably by plan, the
February 8, 2008 hearing set in motion a sequence of “setups” that resulted in Respondent losing
temporary primary physical custody of her five year old daughter – based on superficial
“violations” of ambiguous court rulings. See, February 21, 2008 Order at Exhibit XII.
The real tragedy is that GAL Olin has not been acting in the best interests of the child,
but instead, has acted in a singular purpose of getting custody transferred to the Petitioner. The
GAL has discounted all concerns by Respondent, including those raised about problems with
Petitioner’s care and custody of the child, as set forth in an Emergency Motion filed in October
2007, choosing instead to assume that everything was “OK’ with Petitioner, as she would be
required to do in order to achieve her goal of shifting custody from the mother to the Father.
Using fraudulent and misleading representations to the Court, the GAL, Petitioner,and his
counsel, Mr. O’Connell, have sought to steer this court towards their common goal of shifting
custody from the Mother to the Father, even if it is not in the best interests of the child.
1) The Court should sanction the GAL Olin and remove her from the case.
2) The Court should further sanction Mr. O’Connell for his fraudulent representations to
the Court.
the GAL relating to the emergency visit of Respondent to care for her xxxxxx in Georgia, and the
4) With the striking of all pleadings, testimony, and evidence of Petitioner and the GAL
relating to Dr. Lane and the emergency visit of Respondent to care for her xxxxx in Georgia, the
Court needs to reopen all the “Rules to Show Cause” that relied on said evidence (i.e., the Rules
to Show Cause regarding Dr. Lane, the GAL, and the alleged Violation of the February 8, 2008
Order involving the return of custody after returning from Atlanta), and the vacating of any
The misconduct in this case -- clearly shown by the correspondence recently belatedly
produced by Dr. Pfeiffer -- has been destructive and counterproductive, and undermined the
credibility of the process and this Court. It is particularly disconcerting that the very persons --
the GAL, Petitioner and his counsel -- using fraud and misconduct in this case are the very
parties who sought jail for Respondent based on alleged violations of rulings of this court via that
v.
PRAECIPE
Pursuant to the February 8, 2008 Order where the Court ordered both the Father and the
Mother to have a psychological examination, Dr. IGng, the Mother, completed said psychological
examination with Susan Van Ost, Ph.D., Director,Assessments and Solutions a part of 1ewish
FILED
August 14,2008
Dr.Ariel King contacted me as she was concerned that her daughter, A r i a Leilani
King-PfeiiTer, age 5, was being abused. I initially met with Dr.King and her attorney, Mr. Ray
Moms,on July 22,2008, Subsequently I reviewed documents that Dr.King provided to me,
including a record of symptoms that Dr. King compiled during the period June 2-9,2008, notes
from pediatric visits from June 12,2007 until January 8,2008 ,a transcript of Ariana Leilaoi's
discussion with her mother on June 4,2008, and brief videos of Anana Leilani. I had Dr. King
complete a detailed developmental history of her daughter. Dr. King also completed the Child
Dissociative Checklist, Version 3.1 then had a telephone interview with Dr,King on August 13,
2008 focusing on specific changes in Ariana's behavior. Based upon my review of these
materials and my interview with Dr. King, it is my professional opinion that there is strong
clinical evidence to suspect that Ariana Leilani King-Pfeiffer is being sexually molested.
The developmental history suggests that Ariana's development was proceeding normally
until age four. She was a healthy newborn (APGAR scores 9/10) who was successfully breast-fed
for three years. There were no early feeding difficulties and she enjoyed being held and cuddled
by her mother. Developmental milestones for walking and talking were met within normal
i-
limits. Toilet training was accomplished by age three years and she was sleepingthrough the
night by age two years (although this i s somewhat on the late side, chil n who are breast-fed
often do not sleep through the night until this age as they need to feed o a regular basis due to
the tower calorie content of breast milk). Socially she was extroverted and gregarious, making
friends easily. The "terrible two's"were relatively easy for Ariana as she only manifested a few
temper tantrums a week during this period; these were appropriately managed by allowing
Ariana to vent her frustration and then discussing the issue with her after she calmed down.
At age four, Arianaysbehavior began to change dramatically. She went from being an
outgoing child to a shy and withdrawn child. The occasional "accident"became full blown
eneuresis, culminating in her urinating in her clothing several times per day and even having
multiple encopretic episodes. The well mannered child began to exhibit outbursts of rage, during
which she would scream, strike her mother, bite herself, and destroy her own toys and treasured
belongings. When her mother would ask her what was wrong, Ariana would reply that she could
not tell her mother why she is angry as it is a secret. hi February, 2008 Ariana spoke of seeing
"Mr,Piggy's shangl e." Dr. King's German au pair informed her that "shangle" is a German
slang word for penis. Later &at month Ariana was assessed at the Tree House Center, where she
was taught the difference between "good touch" and "bad touch". In June, 2008, k a n a told her
mother that her father was doing bad touching with her, whereas she and her mother enjoy good
touching between them.
As mentioned earlier, Dr. King completed the Child Dissociative Checklist, Version 3.
This is a twenty (20) item checklist designed by Frank Putnam, MAD,, an expert in the field of
dissociative identity disorder (DID), to assess for the possibility of dissociation The median
score for normal population is 2.0, for anxiety disorder it is 4..0, and for DID it is 25; Anma's
scored 27, strongly suggesting the possibility that she is experiencing symptoms of dissociation.
Discussion of tile items with Dr.King indicated that Ariana has experienced periods where she
"zones ouf'and does not respond to hear mother or react for a period up to one minute- She has
also exhibited striking changes in personality. On one occasion Ariana was crying as she did not
want to go on a visit with her father. She then suddenly stopped crying and said in a different
voice "ok, I'm going to get my pocketbook", picked up her belongings and left, exhibitingtotally
different mannerisms from her normal behaviors. She has also had rapidly changing physical
complaints, one moment complaining of a stomach ache or headache and then the next moment
it was completely gone. Dr.King has also noted cuts and bruises on Ariana that her daughter
could not recall sustaining. Finally, in recent months Ariana began to kiss her mother with an
open rnoutb, a behavior that was totally foreign to their prior interactions-
The deterioration in Arim's behavior, combined with her dissociative symptoms and
her verbalization ofexperiencing bad touch, strongly suggest that Ariana has been subject to
sexual abuse for a sustained period and clearly warrant that she immediately receive a thorough
sexual abuse evaluation by a trained expert in this field, such as Katie Killen, PhD., of Towson,
MD. To not require such an assessment to rule out this possibility would be to potentially subject
this young child to a sustained period of abuse which could well result in her becoming a
dissociative identity disorder (DID),which would have profoundly negative implications for her
future.
Sincerely yours,
MICHAEL H. PFEIFFER
Petitioner,
ARIEL R. KING
Respondent.
IN RE: XXXXXXXXXXXXXXX
DOB: 05/07/2003
MOTION TO RECUSE
Respondent, Dr. Ariel King, on behalf of herself and her daughter, XXXXXXXXXXXX
King-Pfeiffer, respectfully asks that the Honorable Esther Wiggins Lyles (hereinafter referred to
as “the trial judge” or “this Court”) recuse herself from any further proceedings in the above
captioned matters, including those brought by Petitioner, who is an illegal German immigrant
1. Under 28 USCS Sec. 455, and Marshall v Jerrico Inc., 446 US 238, 242, 100
S.Ct. 1610, 64 L. Ed. 2d 182 (1980), "[t]he neutrality requirement helps to guarantee that life,
liberty, or property will not be taken on the basis of an erroneous or distorted conception of the
facts or the law." The above is applicable to this court by application of Article VI and the
Fourteenth Amendment of the United States Constitution and Stone v Powell, 428 US 465, 483
1
See, Motion to Set Aside Orders, filed by Respondent on August 21, 2008.
2. Furthermore, procedural fairness is of critical import in a child custody case and the
Fourteenth Amendment protections must be applied with the ultimate vigilance. As Justice
"Choices about marriage, family life, and the upbringing of children are among
associational rights this Court has ranked as 'of basic importance in our society,' rights
sheltered by the Fourteenth Amendment against the State's unwarranted usurpation,
disregard, or disrespect. M.L.B's case, involving the State's authority to sever
permanently a parent-child bond demands the close consideration the Court has long
required when a family association so undeniably important is at stake.
...
"Although both Lassiter and Santosky yielded divided opinions, the Court was
unanimously of the view that 'the interest of parents in their relationship with their
children is sufficiently fundamental to come within the finite class of liberty interests
protected by the Fourteenth Amendment.' It was also the Court's unanimous view that
'few consequences of judicial action are so grave as the severance of natural family ties.'"
[Alteration original.] [Citations omitted.] [Footnote omitted.]
3. Canon 3(E)(1)(b) of the Canons of Judicial Conduct of Virginia require the trial judge
to recuse herself in proceedings in which the judges impartiality might reasonably be questioned:
Disqualification.
While “[a] purported violation of the Canons alone is not enough to mandate recusal,” 3 in the
3. The requirements of this Canon are clear; a judge must not only diligently avoid
actual impropriety, but a reasonable appearance of impropriety as well. Thus, Canon 3(C)(a) of
the Canons of Judicial Conduct also provides that "[a] judge shall disqualify himself in any
proceeding in which [her] impartiality might reasonably be questioned. "!S! ee, Commonwealth v.
Jackson, 267 Va. 226, 229, 590 S.E. 2d 518, 520 (2004) (holding that "in the absence of proof of
actual bias, recusal is properly within the discretion of the trial judge"); Davis v. Commonwealth, 21
Va. App. 587, 590-91, 466 S.E. 2d 741, 742-43 (1996) (trial judge's discretion to determine
whether "impartiality might reasonably be questioned") (citing Canon 3(C) of the Canons of
Judicial Conduct).
4. No matter how well intended, the record in this case demonstrates that this honorable
court acted in a biased or prejudicial manner toward Respondent, Dr. Ariel King. Such bias was
evident from the beginning of the proceeding, through the most recent hearing on June 6, 2008;
2
Commentary: Under this rule, a judge is disqualified whenever the judge's impartiality might reasonably be
questioned, regardless whether any of the specific rules in Section 3E(1) apply. A judge should disclose information
that the judge believes the parties or their lawyers might consider relevant to the question of disqualification, even if
the judge believes there is no real basis for disqualification. By decisional law, the rule of necessity may override the
rule of disqualification. For example, a judge might be required to participate in judicial review of a judicial salary
statute, or might be the only judge available in a matter requiring immediate judicial action, such as a hearing on
probable cause or a temporary restraining order. In the latter case, the judge must disclose the basis for possible
disqualification and use reasonable efforts to transfer the matter to another judge as soon as practicable.
3
Commonwealth v. Jackson, 267 Va. 226, 229, 590 S.E. 2d 518, 520 (2004) (citing Davis v. Commonwealth, 21
Va. App. 587, 591, 466 S.E.2d 741, 743 (1996)); see Welsh v. Commonwealth, 14 Va. App. 300, 317, 416 S.E.2d
451, 461 (1992), aff’d, 246 Va. 337, 437 S.E.2d 914 (1993).
4
Jackson, 267 Va. at 229, 590 S.E.2d at 520 (citing Justus v. Commonwealth, 222 Va. 667, 673, 674, 283 S.E.2d
905, 908 (1981), cert. denied, 455 U.S. 983 (1982))
hearing for such order was scheduled to occur, i.e., the next day, September 6, 2007, denying
due process to Respondent, (See, Original Summons, attached hereto as Exhibit I). Due to
defective service of the Custody Petition by Petitioner, Respondent did not learn of the
originally set September 6, 2008 hearing date for Petitioner’s custody petition until August
31, 2007. On September 4, 2007 (the next business day after receiving service), Respondent
filed a “Motion to Continue” the hearing date the originally set September 6, 2007 hearing
date for a week or two. A hearing was then set on September 5, 2007 solely for the Court to
hear and rule on the Motion for Continuance of the September 6, 2007 hearing date.
However, instead of limiting her ruling to the Motion for Continuance, the Court entered an
“Initial Order,” a day ahead of the earliest scheduled hearing date possible for such an order
advance of the hearing on the merits of Petitioner’s custody petition. In addition, the
opportunity to testify or give evidence before the initial order was entered on September 5,
2007. This was a clear violation of Respondent’s due process rights by this Honorable
Court. See, e.g., Burdick v. Brooks, III, 160 Md. App. 519; 864 A.2d 300 (2004).
of the child. This Honorable Court never scheduled a hearing on that Motion, even though it
set forth that there were concerns about XXXXXXXXX showing great psychological stress
from the overnight visits with nightmares, wetting her pants, biting herself and seeing
“bumble bees. ” That Emergency Petition also raised the issue of the father sleeping in the
child’s bed, among other issues. Again, that Emergency Motion was never scheduled for
hearing by this Court, nor was that Emergency Motion ever denied. (See Emergency
Respondent’s witnesses were all in attendance. Before allowing the hearing to go forward,
the trial judge allowed the Guardian Ad Litem to “testify” for Dr. Christopher Lane (a
private custody evaluator engaged by Petitioner, but a choice never approved by this Court),
claiming that he was unable to complete his custody evaluation in time. No opportunity was
given to place Dr. Lane on the stand to be examined him regarding the truthfulness of what
the GAL said of Dr. Lane – even though Dr. Lane was in the courtroom, and the sole reason
for delaying the hearing was Dr. Lane’s alleged inability to complete his study – allegedly
because of Respondent’s “failure to cooperate” with Dr. Lane. In fact, had Dr. Lane been
required to testify, the GAL statement of the claims would have been shown to be unfounded.
The truth was that Dr. Lane was unable to complete his work because of procrastination and
cancellations by Dr. Lane, himself – which is evidenced by Dr. Lane’s time entries on his
billing showing much work being done after November 5, 2007 which had nothing to do with
Respondent’s action (Dr. Lane had not disclosed to Respondent that billing prior to the
hearing but was disclosed to Petitioner by Dr. Lane in the hallway on the day of the hearing).
(See, Time Records of Dr. Lane, Exhibit III, herein) No opportunity was given for the
Respondent to testify that she was not the cause of Dr. Lane’s alleged failure to complete his
work. What sworn statements were allowed to be made by the Respondent clearly conflicted
with the unsworn hearsay of Dr. Lane contained in statements of Ms. Olin. As it turns out
and evidenced by discovery produced by Petitioner on June 2, 2008 (months after it was
requested), Dr. Lane’s “excuse ” was simply part of an orchestration by Ms. Olin to assure
that Ms. Wood’s favorable recommendations were not considered by this Court on
Respondent’s Motion for Sanctions, etc., filed June 9, 2008, which remains pending. Ms.
Olin’s attempts – along with Petitioner’s counsel -- to manipulate this Court were successful,
and the November 8, 2007 hearing was postponed over Respondent’s objections.
and on November 30, 2007, a “Motion to Dismiss” based on lack of subject matter
jurisdiction was also filed. Despite numerous attempts to get these threshold matters heard,
this Honorable Court failed to schedule a hearing on these matters until a month and a half
later (January 17, 2008). The Court ignored the case law, and accepted Petitioner’s
counsel’s novel interpretation of the UCCJEA – which was not based on any precedent and
was inapposite with the universal views other courts on the statutory language interpretation.
See, Petition for Mandamus, etc, In Re Ariel King, Case 080963, Supreme Court of Virginia,
filed by Respondent due to the need to attend to her mother who was stricken with a severe
stroke, this Honorable Court transferred primary custody from the Respondent to the
Petitioner without any taking any evidence or making any evidence-based findings of why
such a change in custody was in the best interests of the child. Also, without taking evidence,
the trial judge found Respondent in contempt for “not cooperating with the Guardian Ad
Litem,” and relied solely upon the unsworn (and unspecific) statements of the GAL. The
GAL has never documented which alleged nonspecific requirements this Court imposed and
what specific actions Respondent took (or failed to take) that would support any such finding.
This Honorable Court refused to allow the Respondent to testify on her own behalf to defend
herself against the misstatements of the GAL. See, Transcript, February 8, 2008 Hearing,
Exhibit IV)
e) On February 21, 2008, the trial judge again – without allowing witnesses or taking
any evidence -- transferred “Temporary Full Custody” to the Petitioner. The trial judge
refused to allow Respondent to take the witness stand and testify on her own behalf, and did
the child that he have custody of the child. As of that date, this Honorable Court had not
heard the Petitioner testify on the stand, nor had it received any psychological examination
report on Petitioner, that would suggest that Petitioner was in any way fit to have custody of
the child. Moreover, the Emergency Motion, which raised questions about the Petitioner,
which were reinforced by Ms. Wood’s November 8, 2007 report about Petitioner sleeping
in the child’s bed, had not been taken up by the Court (and remains to this day unheard by
f) On April 8, 2008, the Court aided and guided Petitioner’s counsel on how to
question the Respondent on the witness stand. The trial judge refused to allow Respondent
to present a 911 tape of the incident at issue – prejudging its contents without hearing it –
and refusing to allow Respondent’s mother to testify about her illness and recovery – which
were the focus of the rules to show cause that were at issue. See, Transcript, April 8, 2008
g) After the April 8, 2008 hearing, this Honorable Court thwarted Respondents
attempts to notice appeals of the April 8 rulings by directing the clerk of the Juvenile and
Domestic Relations Court to refuse to allow notices of appeal by Respondent of her April 8,
2008 “rules to show cause” orders.
h) On June 6, 2008 (See, Transcript, June 6, 2008 Hearing, Exhibit VII), this
Respondent, and no orders being entered denying said motions for continuance,
The trial judge’s interjection of this fact was not supported by any evidence
presented in this case, nor did she suggest she came to that conclusion based on
any evidence in the record in the case. (See, Transcript, June 6, 2008 Hearing at
28-33.)
iii) this Honorable Court transferred custody to the Petitioner and barred all
communications with the mother be prohibited. The trial judge admitted coming
to this draconian outcome based solely on hearsay evidence from the only witness
(Michele Wood) whose testimony was limited to her hearsay statements about
what another witness said at another hearing the prior day which was held in
iv) this Honorable Court entered custody order, (which was noted as being
“final ”) despite the fact that no notice was given that a “final ” custody order
was to be entered on June 6, 2008. In fact, the only notices received by
Respondent (who is pro se) were that two motions filed by Respondent (a
motion for mediation, and a motion for reconsideration of the February 18, 2008
temporary custody order) were to be heard on June 6, 2008. The notices did not
indicate that any “final ” custody order was to be entered on that date.
proceedings and the Petitioner having never completed a full psychological exam,
the Court awarded in that “final order,” the custody of a five year old child to
said Petitioner.
5) Even though Respondent has filed a Motion for Sanctions and to Vacate (all orders in the
case) with the clerk on June 9, 2008, the trial court has not scheduled a hearing for that Motion as
of this date. (See, Motion For Sanctions And To Strike Pleadings By Petitioner, Motion For
Sanctions Against The Guardian Ad Litem, Motion To Dismiss The Guardian Ad Litem, And
Motion To Reopen Motion To Show Causes Regarding Dr. Christopher Lane, The Guardian Ad
Litem And February 8 2008 Order, filed with the clerk of the JDR Court on June 9, 2008.)
6) In addition, a conflict has arisen out of the necessity of Respondent to reluctantly file a
Petition for Mandamus and Prohibition against this Honorable Court in the Supreme Court of
Virginia – for this Court’s failure to dismiss this proceeding for lack of subject matter jurisdiction
in a hearing on January 17, 2008 (In Re Ariel King, Case 080963, Supreme Court of Virginia, filed
May 16, 2008). Most of the evidence of bias has occurred since that date. It would appear
unlikely, if not impossible, at this point for this Court to view any further proceedings before it in a
There is ample evidence in the record supporting a conclusion that this Honorable Court,
consciously or subconsciously, has harbored bias and prejudice against Respondent. To avoid
any further appearance of bias or impropriety, Respondent respectfully requests that the trial judge
Re: Please Save 7-year old “Little Ambassador” Ariana-Leilani King-Pfeiffer From
The Ravages of The “Silent War” of Child (Mis)Use, Abuse, and Neglect
Right here and right now in the United States there is a silent war. In this "silent war," the vic-
tims of abuse and neglect include children who suffer, because no one will listen or believe their cries for
help. The perpetrators of this domestic silent war on children are child abusers, who are most often
trusted adults, including parents. They victimize their own children through sexual and physical abuse,
child pornography and even trafficking of their own children. Disturbingly, the enablers of this silent
war on children, including little Ariana-Leilani, are often the very institutions who are mandated to pro-
tect and help them, that includes the local family courts which often act in secrecy, and the "Child Protec-
tion Services" who treat everything they do as "confidential" void of any transparency thus making them
unaccountable and prone to corruption. In addition, in Ariana-Leilani’s case, even the US State Depart-
ment's Office of Children’s Services claims to be powerless to take effective action, even though Ariana-
Leilani is a citizen of Germany who is living in the United States. October is Domestic Violence Aware-
ness Month. This is not the time for excuses, but a time for action.
Ariana-Leilani King-Pfeiffer is a very ill child who is being denied life-saving medicine, G-CSF
to boost her immunity to normal levels. It is well documented by medical records that Ariana-Leilani has
suffered from Severe Chronic Neutropenia of undiagnosed cause since Fall 2008. Severe Chronic Neu-
tropenia is severely low immunity, similar to that suffered by those with HIV/AIDS, which renders them
very vulnerable to fatal infection. This very rare condition began when Ariana-Leilani was placed in the
custody of her father, Dr. Michael H. Pfeiffer, a German national living in Washington DC, who, as a
neurologist, would have easy access to psychotropic drugs (e..g, benzodiazepine "date rape" type drugs)
that can cause neutropenia. She is now only one of 1300 people worldwide on the Severe Chronic Neu-
tropenia International Registry (SCNIR). The Co-Directors of the SCNIR, Prof. Dr. Dale (US) and Prof.
Dr. Karl Welte (Germany) have written letters supporting the need for immediate intervention to save
Ariana-Leilani’s life with G-CSF. Without it, she is at high risk to suffer “toxic shock, loss of limbs or
loss of life” (Dr. Dale, July 2010). They have also stated that taking all the test results into account, the
Severe Chronic Neutropenia is likely “induced by toxins”/drugs (Dr. Welte, August 2009).
Since Fall 2007 various child protection institutions have documented that Ariana-Leilani has
been complaining about her father sleeping in her queen sized bed in a one bedroom student apartment,
and doing "bad touch," and “naughty touch.” Ariana-Leilani complained to a court officer, but, although
the officer noted it, she did nothing about it. Ariana-Leilani complained to a Montgomery County (Mary-
land) forensic investigator, but, although she noted it, she also did nothing. Ariana-Leilani has also com-
plained that her father gives her "green medicine" that "makes me sick." Ariana-Leilani has been diag-
nosed with Post Traumatic Stress Disorder (PTSD) and Dissociative Identity Disorder (DID) since 2008
with no treatment to date. No one in all of these "protection" systems has effectively protected her since
2007. It seems that the more people who don't act on her cries for help, the longer the list gets of those
"group thinkers" who completely ignore her obvious health problems and the abuse that has caused it.
Wiggins - COJ - 000427
Letter to President Barack O'Bama
September 29, 2010, Page 2
When her mother tried to get Ariana-Leilani protection with a domestic violence temporary protection
order and sought to get her a full medical and sexual abuse evaluation at New York's Montefiore Chil-
dren’s Hospital, the abusive father had her arrested and had the evaluation stopped. Since then the US
family courts have allowed him to fully isolate Ariana-Leilani from all of her family in the USA and
Germany, her friends, her religion and her school in order to gain full control. Ariana-Leilani has been
cut off from all contact with mother -- who was the only person who she could trust to help her.
The international community is horrified and outraged. The United Nations Human Rights
Commission, Convention on the Rights of the Child Special Rapporteur for Sale of Children, Child Pros-
titution and Child Pornography has sent an urgent formal letter to the United States Government in Janu-
ary 2010 requesting the US Government take action. Also, Innocence in Danger International (France),
the German Government through the German Embassy, and the Co Directors of the Severe Chronic Neu-
tropenia International Registry, have all expressed serious concern that this child is not getting the medi-
cine and/or full independent medical and psychological evaluation and protection she desperately needs.
The US's apathy to the child's medical and abuse condition is unexplainable. Why are these institutions
more interested in protecting the abusive father rather than addressing the child's obvious life-threatening
medical and debilitating psychological needs. Could it be that because Ariana-Leilani’s father does hu-
man medical research in Neurology for the United States Government at the Veterans Administration
Hospital in the District of Columbia, he is being protected at the expense of his severely ill daughter? As
you have said many times, “No one is above the law.” Such US misbehavior would not be anywhere in
the vicinity of the "moral high ground."
As a human being, Ariana-Leilani was born with “human rights.” As a German child, Ariana-
Leilani is entitled to protection under the UN Convention on the Rights of the Child, including her rights
to life, health and health services, and freedom from torture or cruel, inhuman or degrading treatment. As
an American child she is entitled to protection under the CRC Optional Protocol on Sale of Children,
Child Prostitution and Child Pornography as requested by the Special Rapporteur to the US Government.
To date these basic human rights have been denied by the US institutions.
We appeal to you, as the President, our moral leader, and as a father, to lead your administration
to get this child the necessary medicine and the full medical (as well as criminal) investigation into the
root cause of her very rare illness and the associated psychological issues. Alternatively, we request that
your administration allow the German Government to take the lead in protecting this German child. Her
possible death, as a result of this “domestic silent war” in Washington DC, the backyard of our White
House, would be an international tragedy that would bring into question the United States’ commitment
to the human rights of all children within its borders. We are confident that immediate action, including
a thorough investigation of Ariana-Leilani's situation, will pull back the curtain to expose and help cure a
growing silent cancer of our society, child (mis)use, abuse and neglect in America. Please listen to the
drumbeat of international voices that continue to plead to get her the help to save her life.
Attached are the letters from the Germany Embassy to the State Department and from The Severe
Chronic Neutropenia Registry Professor Dale and Professor Welte, and my letter to the Department of
State, Office of Children’s Services explaining the failures of the US local institutions to protect this
child. I would be happy to provide additional information at your request and meet with members of
your administration to get this problem investigated and addressed before it is too late.
Sincerely,
Klaus Botzel
Consul Genera! and Legal Adviser
TH,OIRECT 2022984361
Tk,;@wash,dipiode
Please allow me to bring to your attention and seek your assistance in the case of
seven year old KING-PFEIFFER, a child with dual German and American
citizenship. She is living with her father, the German national Dr. Michael Pfeiffer, ill \Vash-
ington , D,C. Her mother, Dr. Ariel King, a U.S. citizen, lives in Germany.
Earlier this year, the NOO Innocence in Danger International has brought serious concerns
about possible medical mistreatment and possible sexual abuse of the child by the father to
the attention of the Embassy. The concern s related to based. on the
child's extensive medical and school records, and were supported by physicians of the Severe
Chronic Neutropenia International Registry and the German NGO Avalon.
The German Embassy so far has had no direct access to the child nor to information fi'o m an
independent source. As of today, the F,mbassy has received documentation on the child's
case consisting of medi ca l test records from George Washington University Hospital
(GWU H), opinions and school health records. UnfOitunately, without the consent of the fa-
ther who has sole custody, the Em bassy has no way of veri tying the status of the chi Id, orthe
information it has been given,
In any event the allegat ions are of such a serious nature. that we feel that a fully independent
medical examination of rhe child should be ordered by the competent U.S. authorities. A
divorce and custody case is currently pending in Bayreuth, Germany. The mother claims that
the father refuses to agree to allow her, or anyone actin g on her behalf; to have direct contact
with her child, the child's sole treati ng physician at G\VlJH, and GWUH itself. The mother is
represen ted by Mr. Roy L. Morris, Esq., Arlington, VA. The father is represented by Mr.
Sean W. O' Connell, Arlington, VA.
3
Wiggins - COJ - 000430
' ..?.:;.,
GWUH health recOrds, which were forwarded to the Embassy, state that the child suffers
from Severe Chronic Neutropenia, a medical condition which consists of severely low immu-
nity levels over an extended period of time that leave the child vulnerable to potentially fatal
infections. The Embassy was also provided with opinions from international experts in the
field of pediatric hematology who expressed serious concerns for the child's safety. In the
opinion of these experts there is a lack of a thorough evaluation of the cause of the medical
condition of the child and a lack of an appropriate treatment with a rnedical drug called
GCSF which boosts immunity to more normal levels. However, these medica! experts have
not yet had the possibility to examine the child in person.
The mother believes that the medical condition of the child could have been induced by the
administration of a particular psychotropic drug. According to her, the sole treating physi-
cian's reports are biased because he is an associate of Dr. Pfeiffer at GWUH , and his reports
show inconsistencies with regard to the medical tests and school reports.
The Embassy was informed that Dr. Pfeiffer has been working at GWUH as a physician until
2008. Reportedly he is currently working for the Veteran's Admini stration Hospital in
Washington, D.C.
The report from a guardian ad litem in 11 past child clIstody case notes that the child purport-
edly lives ina one-bedroom apartment with her nlther. The representative of the mother, rvlr.
J\1orris, forwarded documents which include a statement of a clinical psychologist from
Maryland who, based on medical records, interviews of the mother, and other documentation,
utters her professional opinion in writing that the child Ariana-Leilani " ... continues to be at
risk in her current environment of both physical and medical neglect, and likely sexual
abuse. "
The German Embassy has a legal obligation under Art. 5 of the German Consular Act to sup-
port German citizens in need of assistance. A written proposal fI'om the Embassy dated
March 30, 2010, to let the child undergo a full independent medical examination on a volun-
tary basis -- and which costs the mother's health insurance in Germany would cover - has
been declined by the father's lawyer, Mr. O'Connell. So far, the father has refused to com-
municate I.",ilh the Embassy directly.
The possibilities of the Embassy are limited to voluntary cooperation and have been ex-
hausted. The German Embassy would therefore be grateful if the Department of State could
lake up this matter in order to obtain an independent medical examination of Ariana-Leilani
King-Pfe iffer. Once her true health status is clarified, optimal medical care for her seemingly
serious medical condition can be ensured .
If you have questions in this matter please do not hesitate to contact me. [am including a list
of points of contact and a copy of a letter from the University of Washington , Department of
Medicine, in this matter for your information.
./CL
Botzet
4
Wiggins - COJ - 000431
TRANSLATION
Medical School
Hanover, Germany
Lower Saxony Professorship – 65 plus Research
31 August 2009
Medical Opinion
Dear Dr Niethammer-Jürgens,
This report deals with the abovementioned patient whose mother accompanied by Ms Hebart-
Herrmann with medical records consulted us on 31 August 2009. Unfortunately the child is at
present in the USA so that we were unable to examine her in person.
On the basis of the medical documents produced we have arrived at the following evaluation:
Diagnoses:
• Severe chronic neutropenia of unknown origin,
no exclusion of a mutation in the genes ELA2/HAX1/SBDS
• To date no indication of an antibody-induced immune neutropenia
• To date no therapy with hematapoietic growth factors
Further diagnostic investigations to clarify the cause of the severe neutropenia with continuous
absolute neutrophil counts under 500/µl were only undertaken in July 2009 at the Georgetown
Pediatric Hematological-Oncological Outpatient Dept. Day Unit Roof Terrace Ward 64a Ward 62
Tel. +49-511-532-3214 88 Tel. +49-511-532-3288 Tel. +49-511-9411
5 iggins - COJ - 000432
W
University Hospital, Washington, by Dr Myers. There was no sign of maturation arrest of
granulopoesis as an indication of a congenital neutropenia. At the same time there was no
evidence of a malignant systemic disease. Taking the bone marrow findings and the persisting
severe neutropenia together, the most likely assumption is a bone marrow disease caused by an
infection or induced by toxic agents.
Recommendations:
ALM is suffering from a severe chronic neutropenia of hitherto unknown origin.
In view of the fact that a chronic neutropenia with absolute neutrophil counts of under 500/µl
involves the risk of a life-threatening infection, treatment with the hematapoietic growth factor G-
CSF, e.g. Filgrastim, should be initiated urgently.
In view of the unknown origin of the neutropenia we recommend that the diagnostic investigation
be continued in order to exclude an autoimmune disease, an infectious disease and a malignant
systemic disease.
Independent of this we recommend that a bone marrow screening with histology and cytogenetics
be repeated in approx. one year.
A conclusive assessment is only possible after personal consultation with the child.
Yours etc.
[signature]
Pediatric Hematological-Oncological Outpatient Dept. Day Unit Roof Terrace Ward 64a Ward 62
Tel. +49-511-532-3214 88 Tel. +49-511-532-3288 Tel. +49-511-9411
6 iggins - COJ - 000433
W
David C. Daile, MD
Professor of Medicine
Anna Bolyard, RN, BS
Research Nurse
July 9, 2010
Neutropenia is the condition of having lower than normal neutrophils. A nqrmal absolute neutrophil
count (ANC) is maintained at approximately 2000-5000 lemm, allowing a person to fight off
infections. Mildly neutropenic patients have an ANC between 1000 to 150q Icmm, moderately
neutropenic patients have an ANC between 500-1000 Icmm, and severe chrrnic neutropenia is the
rare condition where the bone marrow doesn't produce sufficient neutrophils to keep the levels in the
blood above the 500/cmm level, resulting in not enough neutrophils to fightlinfection. Ariana-
Leilani has severe chronic neutropenia; her neutrophils were consistently be~ow 500 without G .. CSF
treatment. .
Neutrophils are very important because they fight infection. When bacteria!invade the body a
chemical signal is sent out and the neutrophils, like fire fighters responding 0 a blaze, rush to the site
of infection. The bone marrow also responds by speeding up its production bf neutrophils to replace
those involved in fighting the infection. If, however, production of new neWrophils is suppressed or
slowed down, a shortage may develop, and any infection can overwhelm th~ few neutrophils
available. Therefore, a person with only a few neutrophils is at particular risk for developing a
serious bacterial infection. j
Department of Medicine • University of Washington .. Box 356422
1959 NE Pacific St .. Seattle, WA 98195-6422 .
Dr. Dale: Phone 206-543-7215 • Fax 206-685-4458 • Email: ds:dalc(ZiJu. tvashington.edu
7 iggins - COJ
W - Audrey
000434 Anna Bolyard: Phone 206-543-9749 .. Fax: 206-543-3668. E-mail: bol\1ardra;tl.washington.edu
Many SCN patients are treated with G-CSF, a hormone that increases the neutrophil level. This
medication will help fight infection by raising the neutrophil count. Even With the administration of
G-CSF, the neutrophils may still drop to critical levels. G-CSF allows the patient to fight infection
better than the untreated patient, but infection is still a constant concern. T~e treated patient "rill
continue to experience infections, hopefully not life-threatening infections' i The neutropenic
person's life may be greatly affected by her/his inability to fight infectionS,\
The SCNIR follows over 1300 SCN patients. We have tracked each ofthe$e patients, gathering
medical information over the last 16 years for the Registry and 7 years beDl'rc that in clinical blaiS.
Our mission is to follow closely the health of neutropenic patients and to e .ntinue to research::he
mechanisms causing this condition. The SCNIR is actively distributing infprmation regarding SCN
to doctors and patients. The goal is to help the local physician become mo~e knowledgeable about
this rare and difficult condition, and to prevent the severe consequences odmtreated SCN: Toxic
shock, loss oflimbs, and loss oflife.
If you have any questions, the SCNIR web site is very helpful: 1=1t"",t~="'-'t=s.,+.,!ashington.edulrcgistm
Thank you.
Sincerely,
David C. Dale, MD
Professor of Medicine
AUdrc~d' RN, BS
Clinical Manager SCNIR
DCD/las
i
Department of Medicine. University of Washington. Box 356422 ..
1959 NE Pacific St. Seattle, WA 98195-6422
Dr. Dale: Phone 206-543-7215. Fax 206-685-4458 • Email: lli:da!e:(vu.\ ·ashington.edu
8 iggins - COJ
W - Audrey
000435 Anna Bolyard: Phone 206-543-9749 • Fax: 206-543-3668 • E-mail: =L'.4"~~~"';~'-"'=~~~
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Low and High Values
!
BLOOD NORMAL 8/13/2008 10/10/2008 10/22/2008 1/9/2009 3/27/2009 6/26/2009 7/21/2009 10/16/2009 11/10/2009 11/11/2009 12/18/2009 12/21/2009 3/12/2010
Differential Manual
NEUT 53-79 25 L 20 L 20 L 10 L 12 L 15 L 33L
NEUT ABSOL # 1.3 - 8.1 .88 L 0.82 L 0.33LL 0.38 LL 0.47 LL 0.96L 0.4 L 0.5 L 3.5 N 0.5 L
LYMP 13-46 55 H 48 H 48 H 72H 68 H 69 H 49H
LYMP MAN % 16.7-57.8 63 H 59.7 H 30.6 N 62 H
MONO 3 TO 9 14 H 12.3 H 12 H 14 H 12.2 H 5L
SEG MAN 30-71
MONO MAN 4 to10 14 H 12 H 12 H 18 H
EOS % 0-4 13.5 H 15.2 H 6H 7H 18 H 8.5 H
Eosinophil Abs 0.0 - 0.5 0.7 H 0.6 H
EOS MAN 0 TO 4 8H 10 H 17 H 14 H 8H 6H
BASO 0-2
BASOPHIL % 0.0-0.6 1.1 H 0.9 H 1.9 H
BASOPHIL MAN 0-1 3H 2H 14 H
ATYP LYHP 0 -0 2H 2H 2H 3H
Ldh 91-180 213 H 209 H
Alko Phosphatatse 39-117 169 H 135 H 216 H
Phosphorous 2.4-4.5 4L 4.6 H
Sodium Lvl 137-145 136 L
Sodium 137-145 136 L
Chloride 101-111 100 l
Sed Rate 0-20 36 H
Sodium 135-145 134 L
10
Wiggins - COJ - 000437
father's large face and her details about his appearance. h e n Adriana was certain about her
information, her voice would become stronger and stem.
-
On an emotional level, Adriana did not show fear or feeling scared with the significant adults in
her life. She displayedjust the opposite, feelings of love and happiness when talking about
either of her parents.
Many statements made by Adriana were spontaneous. She had little trouble understanding the
focused open-ended questions. If there was a problem, it was the interviewer not asking clear
and concise questions. It appeared to the interviewer that Adriana had more thoughts in her head
than she had language to use in explanations.
Adriana appeared to have difficulty staying focused on any subject matter for more than a few
minutes. She was physically active during the entire interview, not sitting for longer than a few
minutes. Staying active parallels focusing time frames for Adriana, It appeared to the
interviewer that Adriana thinks and speaks more clearly when physically active.