A-1

Court Order dated October 31, 2022

Content

Modified visitation schedule; one visit per month in San Diego (Sunday 10:00 a.m. through Wednesday approximately 6:00 p.m.); alternating visits in Scottsdale, Arizona.

Source

Superior Court of California, San Diego County.

Relevance

Establishes baseline against which visitation compliance is measured; confirms court-ordered parenting time that Respondent repeatedly failed to exercise.

A-2

Income and Expense Declaration, signed August 24, 2022

Content

Respondent’s sworn financial disclosure; total claimed monthly expenses of $6,024; omits furniture ($10,000), firearms ($2,400), Nike payment ($10,000), Grand Cayman income, and mother’s financial contributions.

Source

Court filing, Case No. 21FL004542N.

Relevance

Foundation for financial misrepresentation claims; multiple omissions and inaccuracies documented under oath.

A-3

Motion filed August 24, 2022

Content

Respondent’s request for modification of custody/visitation, modification of spousal support, bifurcation of marital status, Gavron warning, and work/job contacts order.

Source

Court filing, Case No. 21FL004542N.

Relevance

Establishes Respondent’s affirmative litigation posture while simultaneously failing to comply with existing orders.

A-4

Exhibit 6 — Schedule of Assets and Debts, signed October 5, 2021

Content

Lists Bank of America Savings Account No. 3847 (closed; approximately $14,500 transferred out April 29, 2021); Bank of America Savings Account No. 5006 ($18,033 balance, listed as separate property); Southwest Airlines credit card (approximately $4,500 balance); furniture at $10,000; firearms at $2,400; vinyl record collection listed as “unknown” value.

Source

Court filing, Case No. 21FL004542N.

Relevance

Establishes baseline asset disclosure; inconsistencies with Income and Expense Declaration demonstrate pattern of selective financial reporting.

A-5

Exhibit 8 — Reply Declaration of Respondent, signed October 24, 2022

Content

Respondent’s written response to Petitioner’s Declaration; notably does not dispute visitation percentage figures set forth in Exhibit 9.

Source

Court filing, Case No. 21FL004542N.

Relevance

Constitutes a binding admission that Respondent exercised only 11% of court-ordered time with River and 18% with Sofia during the documented period.

A-6

Supplemental Declaration of Respondent, signed October 20, 2022

Content

Contains statement: “Petitioner’s true intention is to assassinate my reputation publicly so that I will capitulate to her desire to remove me from our children’s lives.”

Source

Court filing, Case No. 21FL004542N.

Relevance

Demonstrates Respondent’s adversarial framing of custody proceedings; relevant to credibility and parenting attitude.

A-7

Exhibit 9 — Declaration of Courtney Clifford in Response and Opposition to Request for Order, filed October 20, 2022

Content

Paragraphs 5A–5J and 6A–6C document specific date ranges of reduced and missed visitation; Paragraphs 7 and 8 establish visitation compliance percentages (11% with River, 18% with Sofia during one period; 31% with River, 76% with Sofia during a second period).

Source

Court filing, Case No. 21FL004542N.

Relevance

Primary evidentiary document establishing Respondent’s chronic failure to exercise court-ordered parenting time; not disputed in Respondent’s written reply.

A-8

Exhibit 16 — Responses to Petitioner’s Requests for Production and Inspection of Documents for Deposition, November 7, 2022

Content

Confirms 2021 personal tax returns not yet filed; confirms Cathedral Catholic employment ended early 2020; confirms Boys and Girls Club employment ended approximately March 2020; confirms Palm Heights payment of $3,711 on August 22, 2022; confirms gifts from mother; confirms Philip Bilikoff coaching income; objects to production of One With the Ocean financial records.

Source

Respondent’s discovery responses.

Relevance

Establishes multiple undisclosed income sources and confirms refusal to produce nonprofit financial records.

A-9

Civil Harassment Restraining Order Application against Michael Clifford, approximately June 2021

Content

Filed by Respondent; dropped at hearing in exchange for informal agreement; no restraining order granted.

Source

Court filing, San Diego County.

Relevance

Demonstrates Respondent’s pattern of using legal filings as tactical instruments; relevant to credibility.

B-1

Exhibit 7 — Payment Records from Respondent’s Attorney’s Office

Content

Shows all legal fee payments made via American Express card in the name of Gregory R. Mineo (Respondent’s father); Respondent confirmed he has never personally paid attorney’s fees and does not own an American Express card.

Relevance

Directly contradicts Respondent’s sworn Income and Expense Declaration, which listed attorney’s fees as paid from “credit cards and personal funds”; constitutes a material misrepresentation under oath.

B-2

Exhibit 13 — Promissory Note, $50,000 loan from Gregory Mineo (father)

Content

Dated May 1, 2021 (three days after separation); no payments made as of deposition date; repayment does not begin until 2026.

Relevance

Loan structured to minimize apparent assets and income; timing raises concern regarding asset concealment; $37,500 additional payment by father to Cantor Law Group has no corresponding loan document.

B-3

Exhibit 14 — Earnings Statement, August 1–31, 2022

Content

Shows 16.333 hours worked and paid at $72.12 per hour; Respondent testified he actually worked significantly more hours but was only paid for 16.333 hours.

Relevance

Demonstrates discrepancy between actual labor and reported compensation; supports argument that Respondent’s true economic benefit from the nonprofit is understated.

B-4

Exhibit 15 — Earnings Statement, September 1–30, 2022

Content

Shows 30 hours paid; same explanation as Exhibit 14.

Relevance

Consistent with pattern of underreporting compensation from nonprofit employment.

B-5

Bank Records (produced morning of deposition, November 7, 2022)

Content

Covers transactions through end of October 2022; confirms Nike payment of $10,000; Respondent could not recall the specific month of receipt.

Relevance

Confirms undisclosed income; timing relative to August 23, 2022 Income and Expense Declaration requires forensic analysis; late production limits opposing counsel’s ability to prepare.

B-6

Bank of America Account Records — Accounts No. 3847, No. 5006, and No. 1513

Content

Account No. 3847 closed with approximately $14,500 transferred out on April 29, 2021 (one day after separation); Accounts No. 5006 and No. 1513 opened post-separation and received transferred funds.

Relevance

Potential dissipation of community property assets; transfer timing is highly suspicious.

B-7

Zillow Rental Application, December 2021, for 316 A Street, Encinitas, California 92024

Content

Not produced despite document request; Respondent could not recall income represented to landlord.

Relevance

Income representations to landlord likely contradict court filings; failure to produce despite request is itself significant.

B-8

Year-to-Date Earnings Summary through October 31, 2022

Content

Total earnings of $66,370.16; October 2022 gross pay of $2,289.36; prior two months both under $2,000.

Relevance

Establishes actual income trajectory; inconsistent with claimed financial inability to exercise visitation or pay child support.

B-9

Discogs.com Sales Records — Account “Mechanic Alba”

Content

Approximately 100 records sold in the two months preceding the deposition; estimated proceeds of approximately $1,000; sales range from $6 to $20 per record; last sale within one week of deposition.

Relevance

Undisclosed income source; Respondent continues purchasing records while claiming financial hardship.

B-10

Grand Cayman Work Trip Payment Records

Content

First trip payment of $3,600; most recent trip payment of $4,000; total of at least $7,600; Emily Hammond accompanied Respondent on at least one trip.

Relevance

Undisclosed or underreported income; trips coincide with missed court-ordered visitation dates; Respondent’s denial of being in Grand Cayman in August 2022 contradicts earlier testimony.

B-11

Vehicle Lease Credit Application, February 2022

Content

Respondent signed credit application at time of lease for hybrid electric vehicle; lease payment approximately $500 per month; income represented on application not recalled by Respondent.

Relevance

Income representations on credit application may contradict court financial disclosures.

B-12

Nike Payment Documentation

Content

$10,000 payment to Respondent; received after August 23, 2022 Income and Expense Declaration signing per Respondent’s testimony; visible in bank records produced at deposition.

Relevance

If received before or contemporaneous with Income and Expense Declaration, constitutes material omission from sworn court filing.

C-1

Sophia’s Urgent Care Records, approximately January 11, 2022

Content

Visit to urgent care at Scottsdale Links Resort area; initial diagnosis of sprain; prescription for pain medication issued.

Relevance

Documents circumstances of injury; history provided to treating physician is relevant; mandatory reporting compliance should be verified; Respondent did not fill pain prescription.

C-2

Sophia’s Follow-Up Medical Records, approximately January 14–18, 2022

Content

X-ray confirmed fracture/break of leg; Respondent was in San Diego when fracture was confirmed.

Relevance

Nature and severity of fracture; parental involvement in follow-up care; Respondent did not independently contact treating physicians after learning of fracture.

C-3

River’s Last Documented Medical Records, approximately April 2021

Content

Last documented medical visit when the family was still together in San Diego; River was approximately 7 months old at that time (DOB September 28, 2020); Respondent has not taken River to a doctor since.

Relevance

Demonstrates Respondent’s failure to engage in routine medical care for River over an approximately 18-month period.

D-1

Arizona Department of Child Services Investigation Records, approximately late January 2022

Content

DCS conducted house/hotel visit at Scottsdale Links Resort; investigation related to allegations of digital penetration of Sophia.

Relevance

Respondent voluntarily testified about this investigation, waiving any privilege; directly relevant to child safety assessment.

D-2

Scottsdale Police Department Investigation Records

Content

Investigation referenced by Respondent as closed; related to same allegations as DCS investigation.

Relevance

Same as D-1; Respondent’s voluntary testimony waived Fifth Amendment protection.

D-3

Cantor Law Group Billing Records, Phoenix, Arizona

Content

$37,500 paid by Gregory Mineo on Respondent’s behalf for Arizona criminal defense; no loan document exists for this payment; specific attorney was on maternity leave.

Relevance

Establishes Respondent retained criminal defense counsel for serious allegations; $37,500 payment is an undisclosed financial obligation; no loan documentation means this may be a gift that affects financial picture.

D-4

Polygraph Test Results

Content

Respondent testified he took and passed a polygraph related to molestation allegations.

Relevance

Admissibility to be evaluated; circumstances of administration and chain of custody are relevant.

E-1

Exhibit 1 — Photographs of 316 A Street, Encinitas, California

Content

Exterior gate (locking mechanism present but no actual lock; photographed ajar); stairwell gate (locking mechanism present but no actual lock); backyard (pebbles, no children’s play equipment; boxed toys behind shed, unopened); stairwell leading to unit.

Relevance

Documents safety deficiencies at proposed custodial residence; Respondent concedes toddlers could likely reach interior gate locking mechanism.

E-2

Video on Respondent’s Phone — Sophia’s Leg Injury

Content

Recorded at bottom of playground slide on January 11, 2022 at 5:16 p.m.; shows Respondent looking at camera throughout; Respondent claims he saw Sophia’s foot catch on slide wall “out of the corner of his eye”; video appears to contradict this claim; Respondent denies ever stating the injury occurred on a pool slide.

Relevance

Contradicts Respondent’s account of how he observed the injury; relevant to credibility and to the circumstances of a serious injury to a toddler in his care.

F-1

Exhibit 10 — Article titled “Moneo Reeling” by Michael Volpe, dated April 27, 2022

Content

Published content drawn from Respondent’s November 2021 deposition; Respondent confirmed he read it; no defamation lawsuit filed.

Relevance

Independent third-party documentation of Respondent’s public statements; Respondent’s failure to sue for defamation is relevant to the accuracy of the content.

F-2

Exhibit 11 — Article titled “Image is Everything: How Brian Moneo Transformed Himself into a Swimming Icon” by Michael Volpe, dated May 16, 2022

Content

Contains plagiarism accusations from swim coaches Gerry Rodriguez and Eny Jones; Respondent denied being a “swimming icon”; no defamation lawsuit filed.

Relevance

Independent professional credibility concerns; pattern of misrepresentation in professional sphere.

F-3

Exhibit 12 — Marketing/Bio Document, approximately 2009–2010, Dallas, Texas

Content

States Respondent “swam competitively through college” (Respondent clarified this was intramural); states Respondent had “four years working as a physical therapist at some of Texas’ best hospitals” (Respondent denied ever being licensed as a physical therapist and denied writing the document but admitted seeing it 12–13 years ago without correcting it).

Relevance

Establishes long-standing pattern of misrepresentation regarding professional credentials; directly relevant to overall credibility assessment.

F-4

LinkedIn Profile of Emily Hammond

Content

Lists Hammond as “Director of Business Development, One With the Ocean”; Respondent acknowledges this is inaccurate; she was a volunteer from approximately February/March 2020 through July/August 2020.

Relevance

Demonstrates misrepresentation of organizational structure to the public; relevant to Respondent’s credibility and the legitimacy of the nonprofit’s operations.

F-5

Podcast — “From Fear to Career,” January 22, 2020

Content

Respondent has vague recollection; likely discussed fear of open water and his business.

Relevance

Public statements regarding professional background and business may contradict deposition testimony.

G-1

Talking Parents Application Records

Content

Referenced during deposition but not produced; likely contains communications regarding visitation, Sophia’s injury, and shoe size requests.

Relevance

May document Respondent’s communications (or lack thereof) regarding children’s needs and visitation scheduling.

G-2

Board Approval Text Message Vote

Content

Text message exchange between Angela Lee and Kari Stoever purportedly authorizing release of pay stubs; date unknown; no written record produced.

Relevance

Demonstrates artificial barrier to financial transparency; may reveal actual compensation structure.

G-3

Email Regarding Children’s Removal from San Diego

Content

Respondent states he received an email notifying him that Petitioner had taken the children and left; he came home to an empty house.

Relevance

Establishes date, time, and manner of children’s removal from San Diego; relevant to relocation timeline.

Oliver Baker

Role

Landlord, 316 A Street, Encinitas, California 92024.

Relationship

None; arms-length landlord.

Topics

(1) Income representations on December 2021 rental application; (2) income representations at October 2022 lease renewal; (3) condition of property, including gate mechanisms and safety features; (4) whether any childproofing modifications were requested or made; (5) whether Respondent disclosed presence of toddlers in the unit.

Priority

High — rental application income representations likely contradict court filings.

Michael Volpe

Role

Journalist and author of Exhibits 10 and 11.

Relationship

None; independent journalist.

Topics

(1) Sources for factual assertions in published articles; (2) Respondent’s contact with Volpe regarding salary figure correction (voicemail); (3) whether Respondent or any party paid Volpe to write articles (Respondent’s allegation); (4) plagiarism accusations from Rodriguez and Jones and the basis for those accusations.

Priority

Medium — relevant to credibility impeachment and professional misrepresentation pattern.

Gerry Rodriguez

Role

Swim coach, Los Angeles.

Topics

Nature and specifics of plagiarism accusation against Respondent; what materials were allegedly plagiarized and from whom; whether any formal complaint or legal action was taken.

Priority

Medium — supports pattern of misrepresentation in professional sphere; relevant to credibility.

Eny Jones

Role

Swim coach.

Topics

Same as Gerry Rodriguez above; independent corroboration of plagiarism pattern.

Priority

Medium — corroborating witness for professional misrepresentation pattern.

Urgent Care Physician, Scottsdale, Arizona (approximately January 11, 2022)

Role

Treating physician for Sophia’s leg injury.

Topics

(1) History of injury as provided by Respondent at time of visit; (2) initial diagnosis and basis for sprain determination; (3) whether mandatory reporting obligations were triggered or considered; (4) Respondent’s demeanor and level of concern during the visit; (5) whether pain prescription was discussed and issued.

Priority

High — directly relevant to Respondent’s parental judgment and credibility regarding injury account.

Follow-Up Physician, Scottsdale, Arizona (approximately January 14–18, 2022)

Role

Treating physician who confirmed fracture via x-ray.

Topics

(1) Nature and severity of fracture as revealed by x-ray; (2) whether fracture presentation was consistent with the described mechanism of injury; (3) parental involvement in follow-up care; (4) whether mandatory reporting was triggered.

Priority

High — nature of fracture and consistency with described mechanism is critical.

Philip Bilikoff

Role

Private swim coaching client.

Topics

Dates and number of coaching sessions with Respondent; total amount paid ($1,400 for 15 sessions at $100 per hour); whether any formal contract or receipt was provided; dates of sessions relative to court-ordered visitation periods.

Priority

Medium — establishes undisclosed income source; may reveal scheduling conflicts with visitation.

Palm Heights Resort Representative (Grand Cayman)

Role

Contract employer for Respondent’s work trips.

Topics

Dates of Respondent’s work trips (April, August, and November 2022; possible June 2022); compensation paid ($3,600 first trip; $4,000 most recent trip); whether accommodations and travel were provided; whether Emily Hammond was present and whether her expenses were covered; nature of services performed.

Priority

High — establishes undisclosed income and confirms trips coinciding with missed visitation.

Village Runner Representative (Swim the Avenues Race)

Role

Race organizer; paid Respondent for swim coaching services.

Topics

Compensation paid to Respondent for three of four years (estimated $3,000–$4,000 per year); whether 1099 or W-2 was issued; dates of engagement.

Priority

Medium — establishes additional undisclosed income.

Angela Lee

Role

Board member, One With the Ocean. Category II.

Topics

Respondent’s actual compensation structure and total economic benefit from the nonprofit; business meals and gas expenses paid by the nonprofit on Respondent’s behalf; the text message board vote authorizing pay stub disclosure; Respondent’s actual hours worked versus hours for which he is paid; financial condition of One With the Ocean; connection to Kupanda Kids organization.

Priority

High — key witness on financial opacity; text message vote is a critical document.

Kari Stoever

Role

Board member, One With the Ocean. Category II.

Topics

Same as Angela Lee.

Priority

High — corroborating witness on nonprofit finances.

Anson E. Nguyen

Role

Board member, One With the Ocean. Category II.

Topics

Same as Angela Lee.

Priority

Medium — additional corroboration.

Unnamed Female Friend Present During Michael Clifford Incident

Role

Eyewitness to confrontation; filmed the incident; phone was seized.

Topics

(1) What she observed during the confrontation with Michael Clifford; (2) what her phone footage captured before seizure; (3) whether her phone was returned and whether footage is recoverable.

Priority

Medium — relevant to credibility of Respondent’s account of the Clifford confrontation.

Greg Lucic

Role

Court reporter / notary present at November 7, 2022 deposition.

Topics

Certification of deposition transcript; circumstances of deposition suspension.

Priority

Administrative — necessary for transcript authentication.

Emily Hammond

Role

Respondent’s girlfriend; present at residence approximately two nights per week; accompanied Respondent to Grand Cayman.

Topics

Living arrangements at 316 A Street and frequency of overnight stays; children’s environment and safety conditions during visits; Respondent’s parenting conduct during visits; Grand Cayman trip details, dates, and who paid for her expenses; her role at One With the Ocean (volunteer versus Director of Business Development).

Priority

Medium.

Gregory Mineo (Respondent’s Father)

Role

Financial supporter; paid $50,000 loan and $37,500 in Arizona legal fees.

Topics

Terms and circumstances of $50,000 promissory note dated May 1, 2021; whether the $37,500 Cantor Law Group payment was a loan or a gift; whether any other financial support has been provided; American Express card payments for Respondent’s attorney’s fees.

Priority

High — financial support structure is central to income and asset analysis.

1-A-1

Failure to Disclose Palm Heights Contract Income on I&E Declaration

Respondent’s Income and Expense Declaration, signed under penalty of perjury on August 24, 2022 (Exhibit A-2), omits any reference to income received from Palm Heights resort in Grand Cayman. In his deposition, Respondent admitted to two paid contract engagements with Palm Heights: one in early August 2022 and one from approximately November 1 through 6, 2022. He further admitted to an April 2022 trip during which the resort paid for flights, hotel, and food. Discovery responses (Exhibit A-8) confirm a Palm Heights payment of $3,711 on August 22, 2022 — two days before the declaration was signed.

1-A-2

Failure to Disclose Grand Cayman Income as a Recurring Source

When asked about employment, Respondent initially identified only One With the Ocean, the YMCA, and private coaching under the name “Swim Mechanic.” He did not volunteer the Palm Heights relationship, and characterized it as a one-time appearance. Respondent’s own testimony reveals three separate 2022 engagements with Palm Heights: April (development trip, accommodations paid), August (paid contract), and late October through early November (paid contract).

1-A-3

Failure to Disclose Philip Bilikoff Coaching Income

Respondent’s discovery responses (Exhibit A-8) confirm that he received coaching income from Philip Bilikoff. This income was not disclosed on the sworn Income and Expense Declaration filed August 24, 2022.

1-A-4

Failure to Disclose Mother’s Financial Contributions

Respondent’s discovery responses confirm that he receives gifts from his mother. Under California law, regular financial contributions from a family member that enable a party to meet living expenses are relevant to the court’s assessment of that party’s actual financial circumstances.

1-A-5

Omission of Furniture Value from I&E Declaration

The Schedule of Assets and Debts (Exhibit A-4) lists furniture at a value of $10,000. The furniture did not disappear between October 2021 and August 2022. Its omission from the later sworn declaration is inconsistent with the earlier sworn disclosure.

1-A-6

Omission of Firearms from I&E Declaration

The Schedule of Assets and Debts lists firearms at a value of $2,400. As with the furniture, no explanation has been offered for the disappearance of this asset from the later sworn disclosure. The presence of undisclosed firearms in a household where minor children visit is independently relevant to child safety.

1-A-7

Omission of Nike Payment from I&E Declaration

Respondent’s Income and Expense Declaration does not disclose a $10,000 payment from Nike. A substantial sum that, if received in proximity to the filing date, would be directly material to the court’s assessment of Respondent’s financial circumstances.

1-A-8

Refusal to Produce One With the Ocean Financial Records

Respondent claims to be employed solely as president of One With the Ocean. His discovery responses (Exhibit A-8) reflect that he objected to production of the organization’s financial records. A party who claims an organization as his primary source of income but refuses to produce its financial records invites the inference that those records would be unfavorable.

1-B-1

Bank of America Account No. 3847 — Transfer of Approximately $14,500

The transfer occurred on April 29, 2021, in close temporal proximity to the initiation of dissolution proceedings. The destination of these funds has not been adequately accounted for.

1-B-2

Vinyl Record Collection Listed as “Unknown” Value

A vinyl record collection is a tangible asset with an ascertainable market value. Listing it as “unknown” rather than obtaining even a rough estimate is inconsistent with the obligation to make a good-faith disclosure — particularly given that Respondent was able to assign specific dollar values to furniture ($10,000) and firearms ($2,400).

1-C-1

2021 Personal Tax Returns Not Filed as of November 2022

Respondent’s discovery responses confirm that his 2021 personal tax returns had not been filed. The filing deadline for 2021 returns was April 15, 2022, with an extension deadline of October 17, 2022. As of the deposition date, both deadlines had passed.

2-A-1

Cathedral Catholic Employment — Termination

Employment at Cathedral Catholic ended in early 2020. The fact that this employment ended, combined with the subsequent end of Boys and Girls Club employment approximately March 2020, raises questions about the circumstances surrounding both terminations.

2-A-2

Boys and Girls Club Employment — Termination

Two institutional employment positions ending within months of each other in early 2020, followed by a transition to self-employment and nonprofit leadership, is a pattern that warrants examination.

2-A-3

Inconsistency Regarding One With the Ocean Staffing

Respondent testified that there are no other employees at One With the Ocean and specifically denied having a director of business development — despite Emily Hammond’s LinkedIn profile identifying her in that role.

2-A-4

Evasiveness Regarding Swim Coaching Income Disclosure

Respondent disclosed income sources only when specifically prompted, requiring multiple rounds of questioning to obtain a complete picture.

3-A-1

Failure to Exercise Court-Ordered Parenting Time — River

Respondent filed a motion on August 24, 2022 seeking modification of custody, presenting himself as an engaged parent. Petitioner’s Declaration documents that Respondent exercised only 11% of court-ordered parenting time with River during one documented period, and only 31% during a second. Respondent’s Reply Declaration does not dispute these percentages — constituting a binding admission.

3-A-2

Failure to Exercise Court-Ordered Parenting Time — Sofia

Respondent exercised only 18% of court-ordered parenting time with Sofia during the first documented period, and 76% during the second. The disparity is itself significant — it suggests Respondent’s engagement is variable and responsive to litigation pressure rather than reflecting consistent parental commitment.

3-A-3

Filing for More Time While Failing to Use Existing Time

A party who fails to exercise existing court-ordered parenting time, and who simultaneously seeks more time through litigation, presents a credibility problem that goes to the heart of his stated motivations.

3-B-1

Characterization of Petitioner’s Conduct as “Assassination” of Reputation

In his Supplemental Declaration of October 20, 2022, Respondent stated: “Petitioner’s true intention is to assassinate my reputation publicly so that I will capitulate to her desire to remove me from our children’s lives.” This demonstrates that Respondent frames this litigation in terms of his own reputation rather than the welfare of his children.

3-C-1

Civil Harassment Restraining Order Against Michael Clifford — Filed and Dropped

The filing and subsequent abandonment of a civil harassment restraining order is consistent with a pattern of using legal filings as tactical instruments rather than as genuine remedies.

4-A-1

Firearms Disclosed in 2021 but Omitted from 2022 Financial Declaration

The presence of firearms in a household where minor children exercise parenting time is a child safety issue that the court must address regardless of the financial disclosure implications. Respondent’s failure to disclose these assets in his most recent sworn filing suggests either that he disposed of them without accounting for the proceeds, or that he deliberately omitted them.

4-B-1

Travel to Grand Cayman During Periods When Parenting Time Was Already Underutilized

Travel dates should be cross-referenced against the parenting time calendar. If any international trips occurred during periods when Respondent was scheduled to exercise parenting time, they would constitute additional evidence of Respondent prioritizing personal and professional activities over his obligations to his children.

5-A-1

Pattern of Claiming Inability to Recall

Throughout his November 7, 2022 deposition, Respondent repeatedly claimed inability to recall specific dates, events, and details — while readily recalling information favorable to him (e.g., his exact Palm Heights November dates, his monthly YMCA hours, his current rent). The pattern of recalling information favorable to him while claiming inability to recall information that might be unfavorable is a recognized indicator of evasive testimony.

5-A-2

Equivocal Response to Question About Prior Lies

When asked whether he had told any lies since his prior deposition of November 2, 2021, Respondent answered: “Not that I can recall.” When pressed, he said: “I don’t remember… I can’t remember everything.”

5-A-3

Incremental Disclosure of Income Sources

A witness who is forthcoming about his income would provide a complete answer when asked about his employment. Respondent’s pattern of disclosing each income source only when specifically asked is consistent with a deliberate strategy of minimizing disclosed income.

5-B-1

Simultaneous Pursuit of Litigation Advantages While Failing to Meet Existing Obligations

At the time the August 24, 2022 motion was filed, Respondent was exercising a fraction of his existing court-ordered parenting time, had not filed his 2021 tax returns, had omitted multiple income sources from his sworn financial disclosure, and had received a $3,711 payment from Palm Heights two days before signing the Income and Expense Declaration that did not disclose it.