IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT IN AND FOR UTAH COUNTY, STATE OF UTAH

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Kailin Wang, Pro Per 2481 Fairway Dr.

Spanish Fork, Utah 84660 kaywg2372@gmail.com

IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT IN AND FOR UTAH COUNTY, STATE OF UTAH

KAILIN WANG,

Petitioner, vs.

CHRISTOFFER STANFORD THYGESEN, Respondent.

PETITIONER’S PROPOSED FINDINGS OF FACTS WITH SUPPORTING EXHIBITS

Case No. 194400718 Judge: Thomas Low Commissioner: Marian Ito

Petitioner, Kailin Wang, consistent with Judge Low’s ruling from March 17, 2020, and in preparation for the hearing set for April 27, 2020, hereby submits the following Proposed Findings of Facts, with references to the record for said facts:

PROPOSED FINDINGS OF FACTS I. BACKGROUND OF THE PARTIES

1. Ms. Kailin Wang (hereafter “Kailin”, “she”, or “mother”) matched1 with Mr. Christoffer Thygesen (hereafter “Christoffer”, “Thygesen”, or “father”) on Tinder (a dating web-site) on February 14, 2018; shortly after connecting, Mr. Thygesen immediately added Ms. Wang on a popular Chinese messaging app WeChat2, Snapchat 3, and Instagram.

2. At that time Kailin Wang was living in Utah and Christoffer Thygesen was living in San Francisco.

1 “Matching” refers to the process of people using dating websites to identify other people with similar interests. 2 WeChat is a Chinese multi-purpose messaging, social media, and mobile payment app developed by Tencent. Wikipedia 3A social media platform. Its use would be predominantly for privacy-sensitive content, including the much talked about potential use for sexual content and sexting. One of the principal features of Snapchat is that pictures and messages are usually only available for a short time before they become inaccessible to their recipients.

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3. On February 14, 2018, Ms. Wang traveled to San Francisco on a vacation. She canceled going to a concert with Christoffer. Later that evening, he texted her at her home address of 294 Ewing Terrace, San Francisco, California. She took no action.

4. The parties met in person for the first time on February 28, 2018; he suggested a bar in Pacific Heights called Snug4. When she finally met him, he told her he was high on drugs and often texted strangers online to go to have casual sex at his house that he shares with three other male roommates. His roommates include John Corbett, Adam Skarlin, and another male. Christoffer told Kailin they were friends from Christoffer's fraternity in college.

5. Christoffer described his house as frat house-like with volumes of alcohol, marijuana bongs, and illicit drugs. Christoffer told Kailin about his love of music and how he frequents music festivals around the country, living a hedonistic lifestyle. He tours with his band, meeting groupies on the way, philandering around the world, living off of the ultra wealth of his father, Allan C. Thygesen, a major tech tycoon.

6. He told Kailin he comes from a long line of nobility; his grandfather Niels Thygesen literally invented the monetary currency, Euro. His father is the President of Google; he leads the company’s $161.95 Billion-dollar advertising business.

7. He told Kailin to call him Christoffer "Tiggy" Thygesen, even though his family named him after their alma mater, "Stanford University." He told her he graduated from Carnegie Mellon University and majored in Statistics/Computer Science, --that he is an expert in the technology field.

8. He told Kailin about his frequent meet-ups with women online. He boasted about frequently participating in "Netflix and chill" sessions, an Internet slang term used as a euphemism for sexual activity, casual sex, or as a groupie invitation. He likewise told Kailin about his recent trips to Shanghai, China, ---- where he went for the international Hearthstone video game competitions.

9. He told Kailin that while he was in China, he subscribed to "Tinder Plus,” an app that allows you to match with an unlimited number of people, and that within 24-hours of touching down in China, he had matched with over 300 Chinese Girls.

4 The Snug, The Coziest New Bar on Fillmore. https://sf.eater.com/2017/11/28/16711372/eater-inside-the-snug-fillmore-pacific-heights-sf-opening

5 In the most recently reported fiscal year, Alphabet's [the parent of Google] revenue amounted to 161.9 billion U.S. dollars, up from close to 137 billion U.S. dollars in the previous year.

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10. He told Kailin about touring with his band called “East-End Mile." He said they tour around the country, meeting women for casual sex at various music festivals such as Ground UP Music Festival in Miami, Florida, and various other epicurean events.

11. He told Kailin he also travels for his professional gaming competitions and goes to competitions in places like Los Angeles and China. This is on top of the worldwide travels he frequents with his family. He said he had a substantial family in Denmark. (EXHIBITS_1, BATES #27 to #50)

12. At the end of the evening the parties went to Christoffer’s apartment and had sex. Christoffer represented he would use a condom but, in the dark he did not use one, which Kailin discovered afterward (EXHIBITS_1_FEBRUARY 14, 2018_TEXT MESSAGES-BATES# 27-34)

13. The parties met a second time on March 4, 2018, in San Francisco and also had sex at his apartment. Kailin wanted Christoffer to wear a condom and Christoffer did, but during sex Christoffer took it off, which Kailin again didn’t discover until afterward (EXHIBITS_1_FEBRUARY 14, 2018_TEXT MESSAGES-BATES# 27-34) 6

II. THE TEXT MESSAGES BETWEEN THE PARTIES, BETWEEN MARCH 4, 2018 AND OCTOBER 11, 2018, INCLUDING THE PREGNANCY AND CHRISTOFFER’S THREAT OF CONSEQUENCES IF KAILIN WANG DID NOT ABORT THE CHILD

(EXHIBITS_1_FEBRUARY 14, 2018_TEXT MESSAGES, BATES #3)

14. From March 4, 2018, to June 20, 2018, Christoffer sent several unsolicited photos of his genitals, pictures of him posing in front a mirror with an erect penis, and Snapchat videos of him masturbating alone from his account #Tegroplease to Kailin.

15. On June 20, 2018, Kailin felt nauseous, she “googled” my symptoms online and went in for a medical check-up at Utah County Health Department located in Provo, Utah. To her disbelief, she was pregnant; here I was, -- 35 years old and pregnant for the first time in her life.

6 Later, Kailin learned that Christoffer apparently has a pattern of deceiving his sexual partners about wearing condoms: A Chinese women saw Kailin’s case online and sent Kailin a description of her encounter with Christoffer: “We met on tinder at January 2018. I said I’m not going to have sex without condom. He show to me the condom. But took out and cum inside me. He said so sorry, it was broken. And his grandma died. That’s why he did. He bought Plan-B near drug store. I have those chat history in WeChat. I thought it was his mistake But now I think like this is his pattern. Hook up an Asian girl on tinder. And the cum inside. If I called to police at that time I time I might be she wouldn't that happening. I hope no more victims from him.”

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16. On June 20, 2018 Kailin texted Christoffer, --at first, an abortion was agreed upon; Kailin then went to Salt Lake City to view the Temple of The Church of Jesus Christ of Latter-day Saints , the Church she was baptized in, texted a picture of the Temple to Christoffer, and contemplated about this life-changing decision. Christoffer knew Kailin was living in Utah. (EXHIBITS_1, BATES #5,)

17. On June 22, 2018, Kailin drove alone to Las Vegas for an abortion. She asked Christoffer to help with the costs; he sent me money for the abortion by Venmo7.

18. At the Abortion Clinic in Las Vegas, Kailin was surprised to learn the baby was quite far along --around the 18-weeks stage. The nurse told her that she would need to go through anesthesia for the procedure, and she would not be able to drive home afterward.

19. Kailin was having second thoughts--- then, --- she caught a glimpse of the baby on the Ultrasound Screen; ---the baby was moving and looked completely human. At that moment, her heart literally melted, her maternal instincts kicked in. She stepped outside, got in her car, and drove away. She then immediately returned the abortion money via Venmo. Afterward, she informed Christoffer about her decision. (EXHIBITS_1, BATES #7)

20. Christoffer did not take the news well. He was angry, ---enraged, infuriated, he repeatedly called Kailin, desperately urging, coercing8 her to proceed with the termination. He warned her that her decision to keep the child would not be without consequence. In a 36-minute phone conversation, he affirmed that his parents would disown him if they found out he fathered a Chinese baby9.

21. On June 25, 2018, Christoffer Thygesen, sent the following message to Kailin: "The longer you wait, the harder it is going to be to pull the trigger. I do not know what you have been researching or who has been giving you advice, but this will not play out favorably for anyone. Guaranteed. I can't sugar-coat this since it's so late already…”. (EXHIBITS_1, BATES #8)10

7 Venmo account holders can transfer funds to others via a mobile phone app.

8 Coercion is “the intimidation of a victim to compel the individual to do some act against his or her will by the use of psychological pressure, physical force, or threats.”

9. Racist Overtones; the shame of Baby-K being a bi-racial baby is manifest throughout evidence obtained from

Thygesen's unreasonable discovery. On March 6, 2019, on a Central Utah 911 Dispatch Call, Thygesen referred to Baby-K as a " White Baby." In Baby-Baby-K's Stanford Medical Reports, Thygesen declined to disclose Baby-K.W.'s ethnicity; the father further illegally changed the baby’s first and surname from Kayson Wang to Liam Thygesen.

10 Some states have fetal homicide laws where any third party who causes a baby in the womb to be killed may be

prosecuted. (See Lawrence v. State, 211 S.W. 3d 883, 884-85 [Tex. App. –Dallas 2006). The Federal Unborn Victims of Violence Act is another law that can be used to prosecute those who force or coerce a woman to have an abortion.

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22. On Mon, Jun 25, 2018 Christoffer Thygesen Texted Kailin from (650) 862-8473: "I was certain you were getting an abortion when this first came to light, and that was hard enough to swallow. I feel debilitated by this uncertainty I don't take abortion lightly; I can barely live with myself knowing I'd do that. "But I can't be a real father to a kid at this point in my life." ... "Financially, emotionally, in any way."

23. On June 25, 2018 Christoffer Thygesen texted Kailin from (650) 862-8473:

"Neither you nor I are fit to be parents given our respective situations, probably not this 1% "LA guy" either." "The longer you wait, the harder it's going to be to pull the trigger. I don't know what you've been researching or who's been giving you advice, but this will not play out favorably for anyone, guaranteed can't sugarcoat this since it's so late already." ...

24. Christoffer never considered nor asked Kailin, 'Is this really what you want?'… Up until the very end, he constantly stated his anger and resentment, repeatedly stating that this was not his decision, and if Kailin kept the baby to "f*ck with him more," that he would make sure that "this will end unfavorably for me [her]". 25. That same day Kailin went to St. Marks Hospital in Salt Lake City and began prenatal care with Dr. Kevin Jensen. He took ultrasound pictures. Her prenatal care visits continued with 15 visits in Utah before the birth of the child.

26. On September 25, 2918 Kailin texted Christoffer the ultrasound pictures of the baby and told him her due date of November 25, 2018.

27. The last time the parties communicated was on October 11, 2018, ---Christoffer displayed his anger towards the baby and Kailin. He said this wasn’t his decision to keep the child. He urged me to do an invasive, disturbing prenatal genetic test. This test, if performed at the 37-week stage of gestation, can be deadly and potentially cause miscarriage. (EXHIBITS_1, BATES #10,11)

28. Kailin tried to communicate with Christoffer further, but he blocked all methods of communication. III. KAYSON WAS BORN IN OREM, UTAH ON NOVEMBER 26, 2018

29. Kailin’s neighbors held a baby shower for her at her parents’ home in Spanish Fork. Approximately 25 friends and family attended.

30. Baby Kayson Wang was born on November 26, 2018 at Timpanogos Hospital in Orem Utah at 11:45 p.m.. Kailin’s parents, John and Jen Wang were present; My father took various pictures of Kailin and the baby, including pictures of the Timpanogos Hospital sign showing Kailin’s name and birth.

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Christoffer was not present for the birth of Kayson. He did not call or text Kailin. Later, he denied paternity and refused to be on the birth certificate.

31. Kailin’s pediatrician visits for the child Kayson began the same day and continued for 15 visits in Utah up to March 7, 2019, when the child was removed from Kailin by Utah DCFS.

IV. LOS ANGELES CHILD SUPPORT APPLICATION IS IRRELEVANT TO HOME STATE ANALYSIS

32. After Baby Kayson’s birth, Kailin contacted Utah ORS (Child Support Services) and inquired about the child support application process. (EXHIBITS_1, BATES #12)

33. Utah ORS informed Kailin that if the father lived in California, the case would be referred to the father’ local child support services agency anyway. Therefore, Kailin could either apply through Utah ORS, or could apply directly with the state where the father lived online. Kailin then applied online from Utah to Los Angeles Child Support Services (hereafter; LACSS) through the online portal from Utah on November 27, 2018. The LACSS only provided for free Child Support Services; their application did not provide services for Custody/Visitation requests. Kailin did not apply for custody or visitation.11 (EXHIBITS_4, BATES #194). 34. Under the UCCJEA, an application for child support is not the initiation of a “child custody proceeding” (78B-13-102 (3)).

35. In order to apply for Child Support, Kailin then “Googled" Christoffer's public online information,. His father, Allan C. Thygesen, was at the top of the search results. Kailin saw that Allan C. Thygesen12 is the President of Google Americas—one of the largest tech companies in the world; he also has investments in various startup companies and is a lecturer at the Stanford School of Business. (EXHIBITS_1, BATES #24)

Allan Thygesen <allant@google.com> Google

• Allan C. Thygesen, • President, Americas

Google, LLC. • allant@google.com, • 650-253-5389

11 Thygesen was well aware that the Child Support Services case does not include a Custody/Visitation element, yet he blatantly lied to Judge Smith and Judge Darwin and falsely asserted that the LA and NY child support applications were actually custody actions. Moreover, Thygesen had numerous highly knowledgeable--30-years plus experienced counsel—who were well aware that Administrative actions through Child Support Services (Utah ORS or LACSS) does not provide for Custody/Visitation matters. “The LA-CSS CANNOT help you with: Divorce; Custody; Visitation; Restraining orders; Source: LA-CSS WEBSITE: https://cssd.lacounty.gov/

12 Allan C. Thygesen, as the President of the Americas at Google, leads the company's advertising business in North and South America. Allan is a sought-after voice in the technology industry and presently serves as a Lecturer at the Stanford Graduate School of Business, Director for RingCentral (NYSE: RNG), and managing director and partner in the U.S. venture and growth funds of The Carlyle Group. https://www.gsb.stanford.edu/faculty-research/faculty/allan-c-thygesen

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Kailin also found that his mother Terry Thygesen13 is also a public figure; she is the President of the Board of Trustees for Atherton/Menlo Park. She serves as the Business Board of Trustees for Stanford University. Christoffer’s grandfather, Niels Thygesen, has a Wikipedia entry,-- he invented the Monetary Euro14.

36. Kailin also found that Christoffer had worked for “Square, Inc.”—a smart-phone, point of sale payment software company--in San Francisco. When she contacted them to try to find out how much Christoffer’s salary was for the Child Support Application she was told that he had quit his job on October 10, 2018. It seemed apparent to me her he had done this to avoid paying child support. (EXB. 19, BATES #648)

37. On December 11, 2018, Los Angeles Child Support Services (LACSS) sent Kailin postal mail to 2481 Fairway Dr., Spanish Fork, Utah, which demonstrated that they knew she was living in Utah and that as a Utah resident she could still pursue child support services against a California father. LACSS estimated Christoffer Thygesen’s earnings and calculated his child support payments to be approx. $1534/Month. (EXHIBITS_41, BATES #1405 to #1442)

38. On December 20, 2019, Christoffer Thygesen was served with the LACSS Summons and Complaint. (EXHIBITS_41, BATES #1408),

39. On January 3, 2019, Kailin received Thygesen’s Answer to Los Angeles v. Thygesen Child Support Complaint (18CWCS16140). Christoffer Thygesen denied he is the father of the child Kayson Wang.

(EXB. 4_NOVEMBER 27, 2018_LA CSS, BATES #195)

V. COMMUNICATIONS WITH CHRISTOFFER’S PARENTS.

40. In the telephone conversation about Kailin’s pregnancy Christoffer had expressed a deep fear to tell his parents of my pregnancy and after he blocked further communication from me Kailin did not know if he had told his parents.

41. Therefore, on December 05, 2018, Kailin emailed his parents Allan C. Thygesen and Terry Thygesen pictures of Baby Kayson (EXHIBITS_1, BATES #19, 20)

13 Terry Thygesen previously a management consultant for Booz-Allen & Hamilton, the first director of operations for one of the firm's worldwide industry groups. She retired from Booz-Allen shortly after beginning a second career in public education governance, where she was elected four times to the Menlo Park City School District, serving four terms as board president. https://www.gsb.stanford.edu/alumni/contact/alumni-association/about-alumni/teresa-stromberg-thygesen 14 Niels Thygesen is sometimes referred to as the internationally best-known Danish economist [1] and as "the father of the euro." https://da.wikipedia.org/wiki/Niels_Thygesen

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42. Terry Thygesen replied to Kailin’s e-mail on December 6 by asking what her plans for the baby were. When Kailin replied that adoption and termination of parental rights were not options for her, both Allan and Terry blocked her from any further communication. This was the last time Kailin communicated with the family. (EXHIBITS_1, BATES #21,22)

43. Kaililn later learned that Terry Thygesen sent an e-mail to her husband Allan on December 06, 2018 saying: “Wang sent Email asking the family to talk to Christoffer to figure out if he wants to co‐parent; says adoption is not an option for her. Suggests both families help out.” Kailin also learned that Terry Thygesen declared my email as “Language implying extortion plan.” which was a totally false and an unwarranted over-reaction.

44. On December 06, 2019, Allan Thygesen hired the high profile San Francisco Family Law Firm, Kaye Moser Hierbaum15, LLP, whose clients included Imran Chaudhri16. Imran Chaudhri is a world-renowned designer, who invented the user interface for the Apple iPhone. (EXHIBITS_1_FEBRUARY 14, 2018_TEXT MESSAGES, BATES #23)

45. On February 13, 2019 Allan Thygesen made a police report to the San Francisco Police Department (Incident Report No. 190112228). In the report Allan Thygesen stated: “Wang has not made any threats to harm anyone, and has not requested any money or anything else from A. Thygesen.” (Exb. _8, BATES #338, FEBRUARY 13, 2019_ALLAN THYGESEN POLICE NO.190112228 ).

VI. COMMUNICATIONS WITH THYGESEN ATTORNEY AND GENETIC TESTING.

46. On December 27, 28, and 29 Kailin received and responded to e-mails from Darrick Chase of the Kaye Moser law firm. He was aware of the LA-Child Support Application Kailin had filed and wanted to have genetic testing to confirm that Christoffer was the father of the child. Kailin was willing to do that and she was also willing to have the child support case handled in San Francisco (but not the child custody case). She was in fear of the threats Christoffer had made against her for deciding not to have an abortion and she intentionally

15 Kaye•Moser•Hierbaum•Ford LLP is pleased to announce our firm’s ranking in the 2018 Edition of the “Best Law Firms” by U.S. News & World Report and Best Lawyers. The 2017 list of "Best Law Firms" includes firms that are not just consistently highly rated from clients and peers, but also have a unique combination of quality law practice and breadth of legal expertise.

https://bestlawfirms.usnews.com/profile/kaye-moser-hierbaum-ford-llp/overview/6614

16 Imran Chaudhri (born 1973) is a British-American designer and inventor, who created the user interface and interaction designs for the iPhone.[3] While at Apple from 1995 to 2017,[4] he was a designer on products including the Mac, iPod, iPhone, iPad, Apple TV, Apple Watch, AirPods, and HomePod. https://en.wikipedia.org/wiki/Imran_Chaudhri

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gave his attorney misleading information about where she was living and where the child was living. She was not under oath when she did this.

47. By letter dated January 16, LACSS scheduled genetic testing. Initially, LACSS set it up for February 5, 2019 in Provo, Utah, near where I was living in Spanish Fork, but they told Kailin it would be faster to get test

results by going to California. So, Kailin traveled to

California on January 31, 2019 with Kayson and her two parents and returned to Utah after two days. These two days of temporary absence were the only time that the child Kayson left the State of Utah from his birth until March 7, 2019 when he was removed from the mother’s home by Utah DCFS.

48. On February 1, in response to an e-mail from Christoffer’s attorney, Kailin informed him she had completed the test.

49. By e-mail dated February 3, 2019 Kailin asked Christoffer’s attorney if Christoffer would be interested in being in Kayson’s life. He did not respond.

50. On February 11, Kailin received the genetic test results that Christoffer and she were the parents of Kayson and she e-mailed the results to Christoffer’s attorney.

VII. THYGESEN COMMENCES A CHILD CUSTODY PROCEEDING ON FEBRUARY 15, 2019 IN SAN FRANCISCO.

51. Without any warning to Kailin, on February 15, 2019, Christoffer filed a Request for Domestic Violence Restraining Order (DV-110) in the San Francisco, California court. (Christoffer never met nor inquired about his son until the removal date of March 7, 2019). Attached to the Request were additional court forms asking for sole legal and physical custody with no visitation for Kailin. (EXHIBITS_9_FEBRUARY 15, 2019, BATES #354).

52. In support of his Request, Christoffer alleged that Kailin had made posts on public internet blogs complaining about him abandoning his child and being a deadbeat Dad for offering no child support.

53. Christoffer abused the low threshold of an ex-parte request for a Temporary Restraining Order, ---he desecrated the VAWA17 Domestic Violence statue and abused the laws made to protect women--- and disregarded its purpose for a cheap tactical advantage to get around the normal processes of custody and visitation determinations.

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54. Christoffer asked that the “Protected Parties” for the restraining order would be himself, his parents, his brother, his sister, and his grandparents. As of the date of application he did not fear any danger to the child because He did not seek for the restraining order to cover his child Kayson.

55. Kailin was not served with the Request for the DVRO prior to the February 15 hearing.

56. The case was assigned to Judge Rebecca Wightman who issued an ex-parte temporary restraining order based on the allegations, but denied the requests for custody and “no visitation.” She set the next hearing date for March 6, 2019 to give the Thygesen’s time to serve the Request on Kailin.

VIII. THE CHILD KAYSON HAS ONLY LIVED IN UTAH WITH HIS MOTHER FROM BIRTH TO THE COMMENCEMENT OF THE FIRST CHILD CUSTODY PROCEEDING FILED ON FEBRUARY 15, 2019

57. The child Kayson had only lived in Utah from its birth until it was removed from the home by Utah DCFS on March 7, 2019, based on fraud later reversed on November 06, 2019.

A. Testimony of Kailin Wang and Her Parents.

58. Both Kailin Wang and her parents testified that the child Kayson was born in Orem, Utah on November 26, 2018 and, except for two days when the child was taken to California for genetic testing, the child Kayson has never left their home in the state of Utah until March 7, 2019 when the child was removed by Utah DCFS. 59. Both Kailin Wang and her parents testified that the child Kayson never lived with his father at any time, either in Utah or California, between the time of birth and the time of removal of the child by Utah DCFS on March 7, 2019.

B. Photographic Proof.

60. Between November 26, 2018, the date of the child Kayson’s birth, and March 7, 2019, when Kayson was removed from his home to the custody of Utah DCFS, Kailin’s father and Kailin took 1,215 digital photos of Kayson as a baby. Each of the photos has an embedded time stamp and an embedded GPS location that establish that Kayson was always in Utah for the entire 3.5 months except for 2 days where he was taken to California for DNA testing. Kailin submitted 78 representative photos to this court (EXHIBITS_2, Bates #51 to #130).

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61. Prior to Kayson’s birth the mother, Kailin Wang had 15 pre-natal examinations and doctor care between June 25, 2018 and birth on November 26, 2018. (EXHIBITS_27_KAILIN'S PRE-NATAL CARE_6/28/18 TO 2/03/19)

62. Shortly after Kayson was born, he was diagnosed with severe newborn Jaundice18. At one point, his bilirubin levels were at toxic levels of 22.5, high enough to cause long-term brain damage. During this challenging time, the father, Christoffer Thygesen, completely went missing in action; in fact, he never saw Kayson, he never communicated, never offered any financial support, nor showed any interest in being a part of Kayson’s life. (EXHIBITS_3_KAYSON UTAH PEDIATRICIANS)

During Baby Kayson's Jaundice period, he had to get blood work done almost every day. These tests were performed at local Utah Hospitals and Utah Pediatrician Offices, which included: Mountain Star Hospital in Payson, Utah, Timpanogos Regional in Orem, Utah, Intermountain Health Care in Provo, Utah, Utah Valley Pediatrics and Hobble Creek Pediatrics in Springville, Utah. Kayson had 35 Pre and Post-Natal doctor visits in the State of Utah between June, 2018 and March, 2019. The Doctors have all mandated reporters; the medical reports state that I, Kailin Wang, brought him to all the medical appointments, that the child was healthy, clean, and living in a safe home. (EXHIBITS_3_KAYSON UTAH PEDIATRICIANS) Kayson Wang saw the following Doctors in the State of Utah:

Kayson Wang’s Pediatrician Visits in Utah

Visit Doctor Hospital Location

1 11/26/18 Brian Wolsey Timpanogos Regional Orem, Utah

2 11/28/18 Douglas J. Later Timpanogos Regional Orem, Utah 3 11/30/18 Scott Leifsen Utah Valley Pediatrics Spanish Fork, Utah 4 12/2/18 Benjamin G. Lauritzen Utah Valley Pediatrics Spanish Fork, Utah 5 12/4/18 Scott Leifsen Utah Valley Pediatrics Spanish Fork, Utah 6 12/7/18 Scott Leifsen Utah Valley Pediatrics Spanish Fork, Utah 7 12/9/18 Kevin Nelson, MD Utah Valley Pediatrics Spanish Fork, Utah 8 12/14/18 Mountain View Hospital Mountain View Hospital Payson, Utah 9 12/17/18 DAVID S. DEVENPORT Hobble Creek Pediatrics Springville, Utah 10 12/27/18 DAVID S. DEVENPORT Hobble Creek Pediatrics Springville, Utah 11 1/20/19 Michael P. Fullmer Utah Valley Pediatrics Spanish Fork, Utah 12 1/28/19 DAVID S. DEVENPORT Hobble Creek Pediatrics Springville, Utah

13 Jan. WIC Utah Health Department Provo, Utah

14 Feb. WIC Utah Health Department Provo, Utah

18. What are the possible complications of hyperbilirubinemia in a newborn?

High levels of bilirubin can travel to your baby's brain. This can cause seizures and brain damage. https://www.stanfordchildrens.org/en/topic/default?id=hyperbilirubinemia-and-jaundice-90-P02375

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15 Mar. WIC Utah Health Department Provo, Utah 16 3/9/19 Katharine Lavendar Summit Pediatrics in Park City Park City, Utah

Kailin Wang’s Pre-Natal Doctor Visits in Utah

Visit Doctor Hospital Location

1 6/25/18 Dr. Kevin Jensen St. Marks Hospital Salt Lake City, Utah

2 7/13/18 Dr. Kevin Jensen St. Marks Hospital Salt Lake City, Utah

3 7/23/18 Dr. Kevin Jensen St. Marks Hospital Salt Lake City, Utah

4 8/10/18 Dr. Kevin Jensen St. Marks Hospital Salt Lake City, Utah

5 8/13/18 Dr. Kevin Jensen St. Marks Hospital Salt Lake City, Utah

6 9/10/18 Dr. Kevin Jensen St. Marks Hospital Salt Lake City, Utah

7 10/1/18 Dr. Kevin Jensen St. Marks Hospital Salt Lake City, Utah

8 10/5/18 Dr. Brian L. Wolsey Valley OB-GYN Provo, Utah

9 10/9/18 Dr. Brian L. Wolsey Valley OB-GYN Provo, Utah

10 10/12/18 Dr. Brian L. Wolsey Valley OB-GYN Provo, Utah

11 10/30/18 Dr. Brian L. Wolsey Valley OB-GYN Provo, Utah

12 11/2/18 Dr. Brian L. Wolsey Valley OB-GYN Provo, Utah

13 11/13/18 Dr. Brian L. Wolsey Valley OB-GYN Provo, Utah

14 11/15/18 Brian Platt Cotton Tree Family Doctor Provo, Utah

15 11/20/18 Dr. Brian L. Wolsey Valley OB-GYN Provo, Utah

16 11/26/18 Dr. Brian L. Wolsey Timpanogos Hospital Orem, Utah

17 11/27/18 Hep-B shot Timpanogos Hospital Orem, Utah

18 12/7/18 Dr. Brian L. Wolsey Valley OB-GYN Provo, Utah

19 2/12/19 Dr. Brian L. Wolsey Valley OB-GYN Provo, Utah

C. Google Inc Subpoena Results Verify the Mother was Living in Utah Between August 5, 2018 and April 19, 2019. Google Inc.

63. Mr. Thygesen executed Subpoenas to Google Inc. and Comcast Inc. for the records of Kailin’s e-mail activity for my Gmail account, lancewr12@gmail.com., for the period covering August 5, 2018 to April 19, 2019. (Copies filed with this court on 10/07/19, 03/30/20) See Declaration of authenticity by Legal Department Custodian of Records Laura Devine from Google Inc.

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64. The records provided by Google Inc. showed the IP addresses associated with the login and log-out activity of that account from the time period of August 5, 2018, through April 19, 2019. It showed a total of 273-IP addresses were logged.

65. Of the 273-IP addresses recorded, 226 of the IP addresses identified the locations to be from Utah. From there, a traceable IP address was associated with the Internet Service Provider, Comcast. (EXHIBITS_11_SUBPOENA RESULTS, BATES #437-459)

66. Two Comcast Subpoenas were then subsequently executed to identify the subscriber of the account assigned to the IP address, which then pinpoints to the physical location of the subscriber. The Comcast subpoena results showed the physical address of the subscriber to be located at 2481 Fairway Dr., Spanish Fork, UTAH 84660. This is where Kailin Wang was living with her parents both before the child was born and thereafter. (EXB. 11, BATES #461-465)

IX. THYGESEN’S ABUSIVE ASSAULT, VIOLENCE, AND UNJUSTIFIABLE CONDUCT IN ATTEMPTING TO SERVE THE APPLICATION FOR A DVRO ON MS. WANG.

67. On February 11, 2019, five days before Christoffer Thygesen applied for a temporary restraining order, he hired Hillard and Heintz, state of the art Private Investigation Company, consisting of former United States Secret Service, DOJ, and CIA agents, and had investigators stalk Kailin, her child Kayson, and her parents (EXHIBITS_6_PRIVATE INVESTIGATORS, BATES #211 TO 222)

68. February 16, 2019- March 18, 2019. Around 15-20 attempts (many attempts unlogged) were made to serve the Request for DVRO on Kailin Wang in Utah by special process servers, constables, and private investigators hired by Christoffer Thygesen. Although these agents were informed that Kailin was in New York on a job-hunting trip, they engaged in a campaign of intimidation against her and her parents. They hired agents that waited outside Ms. Wang’s parents' house 24 hours a day, 7 days a week, on top of agents coming over four times a day, every day, looking through their windows, tampering with our cable box, banging on our garage door, threatening to get a Search Warrant, etc. They talked to numerous neighbors and acquaintances.

69. On February 20, 2019 (11:52 a.m.-12:21 p.m.), "The Investigators hired by Allan Thygesen sat in black SUV's outside Ms. Wang's home, questioned neighbors, friends and loved ones, even chasing her parent's car off the road.” (EXB. 17, BATES #572 to #603)

70. On February 20, 2019, AFTER receiving notice Ms. Wang was in New York, Christoffer Thygesen and Allan Thygesen had Hillard and Heintz (private investigators), Salem Police, and Spanish Fork Police, go to Ms. Wang’s father's work, accused him of having a deadly weapon, accused Ms. Wang’s father and Ms. Wang of having a gun. They notified Ms. Wang’s father's HR, requested to interrogate him in a closed room, and said

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they would not leave until they could talk with him. Thygesen had Hillard Heintz make false police calls, using law enforcement action words: " Prepare for Anything," plus these false allegations of the family having a gun, could very well result in a S.W.A.T team gunning down Ms. Wang’s family and Baby Kayson, who was in the home in Spanish Fork. (EXHIBITS_18_FEBRUARY 19, 2019_RANDALL_MELLISA WITNESS AFFIDAVITS, BATES #644 to #647)

71. February 20, 2019 (3:00 p.m.-5:00 p.m.) The harassment did not stop there. On the same day as the frightening interrogation of Kailin’s father by Thygesen's agents, they proceeded to follow her father after work. Thygesen's agents followed Kailin’s father, mother, and Baby Kayson, from Spanish Fork to Sandy on a 60-minute car chase that endangered the baby and almost caused a car accident. EXHIBITS_6_PRIVATE INVESTIGATORS, BATES# 223-240, 241, 242) NOTARIZED STATEMENT OF WITNESSES (EXHIBITS_18_FEBRUARY 19, 2019_RANDALL_MELLISA STATEMENTS)

72. Ms. Wang’s father and mother drove to Sandy to meet and consult with Jeff Rifleman, a family law attorney to get advice on how to handle this situation. Melissa Todd, an employee of Jeff Rifleman, observed the harassment and signed a Notarized Statement: (EXB. 17, BATES #572 to #603):

“On February 20, 2019, After a bit more conversation between the two men and Jeff [Rifleman], the two men went to their own vehicles, and Jeff was able to get his client, his client's wife, and their grandbaby out of the Lexus and into the “Bank of the West” building. I then assisted Jeff in calming down the client and his wife. It was at this time; I fully understood how scared these two people were, as they had been being harassed for more than just at this time. I truly believe these two people were so afraid that they didn’t know if their lives were in jeopardy or not. They had mentioned that maybe they should leave and go on a vacation, so they could calm down and be left alone.” "The Wang's were in fear for their lives, and the Babies." Were forced to leave town to get away from the Non Stop Harassment by Thygesen. (EXB. 18, BATES #646 to #647). “Ms. Wang’s parents were so frightened they went with Kayson to Bryce Canyon, Utah; they were terrified to go back to their own home. Thygesen's agents would not stop, they banged on our door four times a day, had multiple cars wait outside our home 24 hours a day, 7 days a week.” (EXB. 17, BATES #590 to #592) 73. On March 8, 2019, in response to a complaint filed by the Wang’s to the Utah County Attorney’s Office against the harassing and intimidating conduct of Utah Constable, Justin Lampropoulous, who had been hired by Christoffer Thygesen, wrote a letter to David Shawcroft, Civil Division, Utah County Attorney’s Office and confirmed his role in this abuse and harassment as follows:

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1. February 16, 2019, The neighbors indicated that Kailin Wang did indeed reside at Spanish Fork, Utah, and provided information about her having a child recently. The neighbors even recently hosted a baby shower for her. They confirmed that Kailin Wang was living at 2481 Fairway Drive in Spanish Fork.

2. February 20, 2019, Stowell and Officer Gurney of the Salem Police Department attempted to contact Mr. John Wang at his place of employment. Stowell requested an officer to be present for officer safety purposes. The Constable’s Office was informed that Kailin might have a firearm, and with Wang's determined non-cooperation and hostility, having another officer was prudent in case Mr. John Wang had a firearm as well.

3. On the afternoon of February 20, 2019, Mr. Stowell followed Wang's in hopes of serving. Kailin Wang, while she was not in the vehicle, but it was instead Mrs. Wang. Kailin’s baby was also in the vehicle. This corroborates the reasonable belief that Kailin resides at the Spanish Fork, Utah residence. Moreover, Kailin’s baby was with the Wang’s when the incident occurred in Sandy – indicating that they had good contact with Kailin, which is contrary to every statement they made of not knowing her whereabouts.

4. February 21, 2019, The Wang’s noticed a red Toyota Hybrid parked near their home. This vehicle does not belong to the Unified Constable Service. However, the office was aware of several private investigators in the area.

74. Christoffer did not serve the Request for a DVRO on Ms. Wang until March 18, 2019, 13 days after the March 6 hearing in which Judge Darwin in San Francisco granted Christoffers’ request for an order for sole legal and physical custody of Kayson an 3 days after Ms. Wang filed her Petition for Paternity in Utah.

X. CALIFORNIA JUDGE DARWIN COMMITS NUMEROUS LEGAL ERRORS ON MARCH 6, 2019. 75. On February 15, 2019 Judge Rebecca Wightman had issued an ex parte temporary restraining order which was continued to, and set to expire on, March 6, 2019. On March 6, 2019 Judge Richard Darwin held another hearing.

76. The hearing was ex-parte again. Christoffer Thygesen, unhappy that Judge Wightman had not granted his request for sole legal and physical custody and “no visitation” to the mother on February 15, filed another memorandum on March 4, 2019 in an effort to persuade Judge Darwin to grant his request.

77. In the Memorandum Christoffer argued that Judge Darwin had the authority to issue the requested custody and no visitation order because (a) The child Kayson was likely living in California or, (b) if the child was not living in California, California was the “home state” of the child Kayson (EXHIBITS_37_THYGESEN'S PREVIOUS FILINGS CASE NO. 194400718, 194400711, 194400689, FDV-19-814465, BATES #1,2)

In Thygesen’s March 04, 2019 “POINTS AND AUTHORITIES DEMONSTRATING

THIS COURT'S AUTHORITY TO ISSUE AN EX PARTE CUSTODY ORDER TO PROTECT KAYSON THYGESEN WANG”. Christoffer false alleged that California Is Kayson's home state knowing that Kayson had not been born in California and had not lived in California for six months if at all

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Make an Ex Parte Order Determining Temporary Child Custody

(1) “California is Kayson's home state. As with all cases where the child's home state is California, this Court has jurisdiction to make an order.” “This Court, even if Ms. Wang has removed Kayson from California temporarily has the authority under Family Code Section 6323(a)(1) to make an ex parte order for custody and visitation of Kayson. There are no other custody orders In place. No orders have been made in the New York proceeding that was filed subsequent to the Los Angeles proceeding and this proceeding.” (Memorandum Pg.2,3) & MARCH 6, 2019 TRANSCRIPT OF THE PROCEEDINGS

78. Judge Darwin said there was not sufficient evidence the child was living in California, but decided he had authority to issue an order to take physical custody of the child because California was the “home state” of the child under the UCCJEA because (a) the mother had listed a California address for the mother on the child’s birth certificate and (b) because the mother had filed for child support through the Los Angeles Child Support Service (Transcript, p. 22).

79. Judge Darwin issued an amended temporary DVRO awarding sole legal and physical custody of the child to Christoffer and “no visitation” for the mother. EXHIBITS_00021_MARCH 6, 2019 TRANSCRIPT. The Order also contained a “no contact” order for the Protected Parties (which did not include the child Kayson),

80. Judge Darwin’s Order was erroneous and illegal because (a) although the child was under six months old Judge Darwin heard no evidence relating to what state the child was born in (Utah), which is required by UCCJEA Section 102 (7); (b) where the mother had lived or intended to live was irrelevant to the home state of the child unless the child was with the mother, (c) there was no evidence the child had ever lived in California (he had not), which was required by Section 102(7); (d) where the mother filed for child support is irrelevant in determining the home state of the child under the UCCJEA; and (e) under UCCJEA Section 204 (1) Judge Darwin could not make any “emergency jurisdiction” order because the child was not “present” in California. 81. Despite issuing the requested Order, Judge Darwin went to great lengths to state that he was not making any “findings” because the briefing and hearing was ex-parte. He said:

Now I am going to take off the extra section on these findings [the proposed findings that Christoffer’s attorney had drafted] because this is being done on an ex parte basis. So I am not making any findings at this point other than he’s established, and the Court already did that, found that there was domestic abuse sufficient to issue a temporary restraining order. I don’t want to make it that we’ve done anything beyond that. I haven’t made any findings. There’s been no evidence, there has not been an evidentiary proceeding, so I don’t want to imply that there has. (March 6 Transcript p. 22).

XI. THE PARTIES’ MUTUAL ALLEGATIONS OF DOMESTIC VIOLENCE AND STAY OF PROCEEDINGS

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82. Christoffer Thygesen alleges that, beginning December 24, 2018, Kailin Wang began making posts on public blogs that humiliated, embarrassed, and threatened him, which he alleges constituted domestic violence.

83. Between February 15, 2019 (when Christoffer’s request for custody was initially denied) and March 6, 2019 (when the next hearing on the DVRO and custody issue was scheduled), a series of threats appeared on Holysmoke.org19

2/15/19: Kailin Wang is an unfit parent, easy, full custody win

2/17/19: Posted. Kailin Wang is in violation of her probation; she's been arrested for assault, Chris will get Full Custody.

2/18/19: "Kailin Wang is getting locked up soon."

2/28/19: "Kailin Wang is an unfit mother, get this child away from her, it is a dangerous situation". Kailin Wang has alleged in her Utah application for a Protective Order filed on March 18, 2019 that these posts were made by Christoffer Thygesen or someone at this request.

84. Kailin Wang alleges that on February 16, 2019, Thygesen made several fake Social Media Accounts under the alias "Jaime Nelson," and contacted at least 8 of her friends, cyber stalking, and wrote several old co-workers of hers. She alleges her old co-worker Kristina Mikalnova sent her screenshots of harassing messages from the alias "Jaime Nelson," inquiring about Ms. Wang’s whereabouts, deceptively stating that he wanted to bring over a baby shower present. Ms. Wang claims she does not know anyone by the name of Jaime Nelson, and that this was done by Christoffer Thygesen or someone at his request and this was intentionally done to harass, stalk, and victimize Ms. Wang for refusing to abort Kayson. (EXHIBITS_42_ALIAS JAMIE NELSON)

85. On March 16 a post appeared on Holy Smoke under the name of Kailin Wang stating:" I'm going to kill myself and our baby if he does not start paying me a child support and then he will be guilty of first-degree murder". "I hope his parents are happy to hear this !!!”. (“Kill Baby” post).

86. Kailin Wang denies making this post and she has alleged in her application for a Protective Order filed in Utah on March 18, 2019 that it was made by Christoffer Thygesen in her name to bolster his claim of domestic violence so he could obtain custody of the child and ultimately place the child for adoption. In fact on the same web-site on March 24 there is the following post: “I’m going to kill this baby so I don’t have to pay child support” under the name of Christoffer Thygesen.

87. Christoffer Thygesen also alleges that Kailin Wang engaged in similar harassing conduct with Rory Will and Walker Stone. Kailin Wang asserts that Christoffer Thygesen has engaged in victimizing similar conduct as

19 Holysmoke.org is a platform which lets you report about the bad businesses or cheaters who have scammed you for money or have played with your trust. The platform makes it easy for its users to voice their opinion and warn others to save them from falling into the same trap. Anyone who has been cheated at any point can access Holy

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she experienced with other women who claim they were sexually assaulted by Christoffer. Since this court declines to enter into any determination of whether the parties committed domestic violence or engaged in criminal conduct it also declines to receive any evidence or testimony regarding these allegations.

88. Christoffer Thygesen has also alleged that Kailin Wang violated Judge Darwin’s temporary restraining order on several occasions, including during supervised visits to the child at Rally. Kailin Wang alleges that Christoffer made false allegations to Rally that Kailin Wang would poison the child, murder the child, kidnap the child, commit mass-casualty of Rally workers.

89. This dispute over whether Kailin Wang committed domestic violence or violated the temporary restraining order against Christoffer Thygesen is currently pending before Judge Monica Wiley in San Francisco.

90. On October 17, five days before the domestic violence case was scheduled for trial, based on allegations by Christoffer Thygesen, the San Francisco Police Department charged Kailin Wang with electronic stalking and electronic harassment.

91. Judge Wiley reviewed the charges and agreed that the allegations in the criminal case were the same as the allegations in the domestic violence case. She further agreed that Kailin Wang had a Fifth Amendment privilege not to testify in the civil domestic violence case in regard to matters that were charged in the criminal case. 92. Christoffer Thygesen’s attorneys complained that they should be given an opportunity to brief this issue so Judge Wiley continued the case, set a briefing schedule, and set a new hearing date on December 19, 2019. 93. At the December 19, 2019 hearing Christoffer Thygesen’s attorneys, apparently having researched the matter, agreed that a stay would be proper. Judge Wiley stayed the case on that day.

94. This court is bound to give full faith and credit to Judge Wiley’s stay order, and because the allegations of domestic violence must be decided under California law, and because there is no case involving allegations of domestic violence pending in any Utah court, this court declines to enter into or hear evidence on the allegations of domestic violence and makes no findings in regard thereto.

XII. TYGESEN’S ORCHESTRATED BLITZKRIEG TO REMOVE KAYSON FROM HIS HOME IN UTAH.

Enlistment of Utah Law Enforcement

95. Christoffer’s plan for obtaining physical custody of the child was pre-planned and swiftly executed as follows:

a. On March 3, three days before Judge Darwin even issued his Order Thygesen retained four Utah attorneys: Mitchell Olsen, Martin Olsen, Beau Olsen, Bryan J. McConkie. (EXHIBITS_00037_THYGESEN'S PREVIOUS FILINGS CASE NO. 194400718, 194400711, 194400689, FDV-19-814465, BATES # 8 ) Thygesen also secured and consented to a Guardian ad. Litem, and was served with the Juvenile Court Notice of hearing while he stayed at: Christoffer S. Thygesen (Home) 55 Fox Glen Circle PARK CITY UT 84060

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b. On March 04, 2019, Thygesen filed “Declaration of Christoffer Thygesen in Support of DVRO w/ Custody” in the California court stating: "My Investigators witnessed Ms. Wang was in Spanish Fork, Utah, with her mother, they had the baby with them." (Pg. 5 Lines 27:28, Pg. 6 Line 1:3) (EXB. 5_MARCH 04, 2019 CHRIS DECLARATION, BATES #196 to #198) (EXB. 5, BATES #197to #198)

Mr. Thygesen was fully aware the baby was in Utah; he also hired agents to came outside Ms. Wang’s house 24 hours a day, seven days a week. Her parents were able to get license numbers for two of the vehicles. At all times, least three cars were parked outside, one by the entrance of the hill, one at the exit street, and a third opposite to the mountain. (EXB. 17, BATES #557 to #641)

c. March 6, 2019 (2:00 p.m.) Forensic Psychologist, Mark Bernizger, from Hillard Heintz (Private Investigations, based in Chicago, IL) called Central Utah 911 Dispatch #: C6050525 @ 14:12. (EXB. 23, BATES #726 to #748)

Utah Valley Dispatch 14:13:17 03/06/19 CALL DETAIL REPORT, Call Number: C605052 COMPLAINANT/CONTACT

Complainant: HILLARD HEINTZE, Race: Sex: DOB: **/**/**

Address: 30 S Wacker Dr, Chicago

Home Phone: (312) 229-9806, Contact: Mark Brenzinger, Address: 30 S Wacker Dr, Chicago Phone: (847)306-2220, Work Phone: (312) 869-8500, March 6th, 2019, 14:23.

Dispatch: Police and fire dispatch.

Mark B.: Hi, my name is Mark Brenzinger. I'm calling from Chicago. I work with a private security risk management firm, and we have an emergent situation in your jurisdiction. I was hoping to speak with ... We've been working with your constable in the area, and he's been working with a sergeant, and we have some information we want to share with you in a fresh court order. Is there any way you can get connected to a watch commander or a sergeant?

Mark B.: Hillard Heintze. We're based in Chicago.

Dispatch: And that's a private investigation firm, you said? Mark B.: A private investigation firm. Yes, ma'am.

Mark B.: Okay, can we make this, with all due respect, a priority? We believe our the subject is mentally unstable, has just got bad news and she just posted a the threat about two hours ago about a homicidal threat and a suicidal threat regarding herself and this baby.

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Mark B.: Kailin, Wang.

Dispatch: Do we need to have an officer respond to her address?

Mark B.: Well, I think we do. I'd like to give you the address. So the address is 2481 Fairway Drive in Spanish Fork and an officer should be prepared for anything.

Mark B.: And to the baby. As of two hours ago, there was a posting. She was aware there was a hearing in San Francisco. She was not present, and we're not certain how much information she has, but the court found

that the baby needs to be removed from [crosstalk 00:04:21]-

Terry Thygesen: The first one, its the parents' home address. I'm going to give you three phone numbers. The first one is at the residence-

Dispatch: Okay, go ahead with the phone numbers, ma'am.

Terry Thygesen: Yes. And I have one more cell phone number for her, and that one is 917- 432-4181. I don't know which of the two cell phones are still active or if

they both are.

Darrick Chase: Yes. The baby's name is Kayson. His middle name is Thygesen. Last name, Wang. He's a boy. His birth date is 11-26-2018. He's a white baby.

Dispatch: Okay, and then the vehicle information for Kailin?

Terry Thygesen: Give me one second. I'm opening it up. There are two cars. One is a gold BMW SUV. The license plate is Boy Five Three Eight Edward Apple. I'll

read that back to you. Boy Five Three Eight Edward Apple. The second car

is a red Lexus SUV. The license plate is David Size Six Nine X-ray Tango. We believe the baby seat is usually in the red Lexis, FYI.

d. On March 6, 2019 Constable Justin Lampropoulos in Utah was sent a copy of the “Kill Baby” post. e. On March 6, 2019, the same day the Order was issued, Christoffer Thygesen and his mother Terry Thygesen flew into Utah with Darrick Chase, his California attorney, and his Google America security team. They recruited the cooperation of Assistant Utah Attorney General, Gary Bell and Guardian Ad Litem, Daniel Gubler; Utah DCFS, Spanish Fork Assistant District Attorney, Jason Sant, and Spanish Fork Police Sgt. Zack Adams. (EXB. 24, BATES #749 to #753)

f. The paranoid Thygesen’s had their Google America security team perform a bomb sweep of the Provo DCFS offices.

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g. Christoffer and his California attorney presented Judge Darwin’s Order for custody issued the same day and a copy of the Holy Smoke post, also dated March 6.

h. On March 6, 2019, Sgt. Martinez of the San Francisco Police Department called Spanish Fork Police and informs them of the " Kill Baby post. (EXB. 24, BATES #749 to #753)

i. On March 6, 2019: Terry Thygesen stated to Utah DCFS: "I don't fear the longer-term custody process either given the facts in the case and also given that San Francisco PD expects the DA will be pressing felony charges against Ms. Wang very soon. I expect that Christoffer will retain sole physical and legal custody of his son forever". (EXB. 25, BATES #776)

See: Certified GRAMA Police Reports, Warrant for Removal of Baby K, GRAMA DCFS Reports, Transcript of March 12, March 18 Shelter Hearing in 4th District Juvenile County w/ Judge Richard Smith. (EXB. 25, BATES #765 to #786)

Utah DCFS

j. On March 7, 2019 (9:30 a.m.) Utah DCFS agents Kimberly Webb, and Stephanie, went to Ms. Wang's Spanish Fork Home, and saw Baby K. In their detailed investigation they stated the baby “looked healthy, clean, well-fed and not abused". A video of this visit is included in the Jump Drive

k. On March 7, 2019, Terry Thygesen, Christoffer Thygesen and Darrick Chase met with Spanish Fork ADA, Jason Sant. See: DCFS Grama Report, informing them of the Kill Baby K Post (EXB. 22, BATES #721, EXHIBITS_25, BATES #771)

l. On March 7, 2019, Thygesen’s attorney Darrick T. Chase met with AAG Gary Bell and Guardian Ad Litem Daniel Gubler and convinced them that California is the " Home State," and showed them the Kill Baby post (EXHIBITS_25, BATES #765 to #786)

m. Due to Thygesen's attorney Darrick Chase misrepresenting Judge Darwin’s March 6 Order by falsely stating that Ms. Wang participated in the March 6 hearing, and that Judge Darwin made " Findings," that California is the home state of the child, the Utah authorities believed the California Order was granted based on its merits.

n. March 7, 2019, (4:00 p.m.) Due to the March 6 Kill Baby post and the threat of violence to the child, Utah DCFS obtained a warrant for the removal of 3.5 Months old Baby K. The infant was forcibly ripped away screaming from his terrified grandmother's arms, torn away from the only home he had known. (EXB. 25, BATES #771)

o. On March 8, 2019 Terry Thygesen discussed their coordination with the San Francisco Police Department to have Kailin charged with crimes:

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Francisco PD expects the DA will be pressing felony charges against Ms. Wang very soon. I expect that Christoffer will retain sole physical and legal custody of his son forever.”

(EXHIBITS_00025_MARCH 6, 2019 GRAMA DCFS_REVERSAL,. BATES# 776)

Juvenile Court Shelter Hearings

o. On March 12, 2019 a shelter hearing was held before Judge Richard Smith. DCFS believed the March 6 Kill Baby post represented a credible threat to the safety of the child, although they had done no investigation to confirm whether or not the post was made by Kailin Wang. DCFS “supported” the finding that there was a threat to the child. Judge Smith continued the shelter hearing to March 18.

p. On March 18, 2019, Judge Smith, without hearing any testimony or reviewing any evidence except the March 6 custody order and the March 6 “kill baby” post, directed DCFS to surrender custody of the child to the father Christoffer Thygesen. Judge Smith made no analysis of whether Judge Darwin’s Order was in “substantial conformity” with the UCCJEA as required by Utah 78B-13-303; if he had done so he would have quickly realized that California could not be the home state of a child under six months old if it was born in Utah. In Judge Smith's March 18, 2019, Juvenile Custody hearing he said: The Court states that the child is in the father’s custody for now and will remain there until further court order in a competent jurisdiction. On June 25, 2019, Judge Darwin concluded Utah is the court of competent jurisdiction. (EXB. 45, BATES #1479 to #1488)

q. Later, on November 6, 2019, Utah DCFS, through Utah Assistant Attorney General Gary Bell, filed a Motion to Reverse Supported Finding to Unsupported and on November 8, 2019 the State of Utah, Department of Human Services, Office of Administrative Hearings issued a “Final Decision and Order” changing the previous finding of child abuse to “unsupported.” Christoffer Thygesen did not appeal or challenge the new Order (EXHIBITS_25, BATES# 754-759).

XIII. KAILIN WANG’S TEMPORARY ABSENCE ACTIVITIES IN NEW YORK

96. On February 16, 2019 Kailin Wang traveled to New York to look for work. She was a tax accountant and h6ad worked in both California and New York in the past during tax season.

97. Kailin Wang left her son Kayson in the capable hands of her parents temporarily while she was gone.

98. Kailin Wang did not know if she would get a job, but she did know it would be a temporary job and would end as soon as tax season was over (end of April). She also knew that any time she was not working she would return to her permanent home and domicile in Spanish Fork, Utah with her parents.

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99. Since Kailin Wang had heard nothing from the LACSS and because she did not understand the concept of “home state” under the UCCJEA on February 19, 2019 Kailin Wang filed a petition for paternity and child support against Christoffer Thygesen in the Family Court in New York.

100. On February 19, 2019 Kailin Wang also filed a Family Offense Petition (request for a protective order) in New York to try to protect herself from further harassment and the threats of Christoffer Thygesen.

101. On March 8, the New York Family Court granted an order of protection in favor of Kailin Wang and against Christoffer Thygesen.

102. On March 13, 2019, Kailin Wang applied for and was issued a New York State ID which she could use to cash checks and use the computers and printing services at New York libraries.

103. On March 15, Kailin Wang abandoned her job search and returned to Utah to participate in Judge Smith’s shelter hearing and defend against her child being removed from her custody.

104. Through prior communications with a Utah attorney, she filed her Petition for Paternity in Utah on March 15, the same day she returned. By then Kailin Wang had learned that the proper state for filing her Petition for Paternity was Utah because that was where the child was born and was the home state of the child.

105. Prior to filing her Petition for Paternity in Utah, Kailin Wang consulted with a New York attorney who advised her that her Petition for Paternity and child support in New York would simply be dismissed if she did not attend the next scheduled hearing in New York on March 26.

106. Because these activities in New York occurred after February 15, 2019, when Christoffer Thygesen filed his child custody proceeding in California and because the child has never in New York (or California) they are outside of the relevant time period and irrelevant for determining the home state of the child Kayson.

XIV. CHRISTOFFER THYGESEN EVADES SERVICE OF UTAH PROTECTIVE ORDER:

*The following list of incidents is being currently charged as Felony Violation of RO in the Criminal Case, I have no prior convictions, no misdemeanors, never even been charged a Felony, not until Allan Thygesen used his influence. (EXHIBITS_33_MARCH 23-24, 2019_CHRIS EVADES SERVICE COMPLETE)

107. (a) On March 18, 2019: Serve by email to Respondents Utah Counsel: Beau J. Olsen, Mitch Olsen, Martin Olsen; Bryant J. McConkie (REFUSED TO ACCEPT SERVICE)

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(c) On March 23, 2019: Service in Menlo Park: The Process Server Tony Klein stated under penalty of perjury: On Saturday, “I attempted service at the requested address at 8:52 AM. There were two vehicles parked in the driveway, and a "ring" doorbell with a possible camera, but there was no

answer."(EXHIBITS_33, BATES #1001, 1009-1014) A Certified Copy of Transcript of SFPD Dispatch call is detailed below.

EVENT HISTORY DETAIL: Call 190821223 SAN FRANCISCO POLICE DEPARTMENT [03/23/2019] 10:21:37

Location:294 EWING TR, SF Type:910 Name: KAILIN WANG/UTAH Phone: (917) 432-4181 DAREA:3F Area:740B TypeDesc: WELL BEING CHECK LocDesc: btwn JEAN WY and MASONIC AV LocCross: btwn JEAN WY and MASONIC AV Priority: B Class:F:3PAT Agency: SP Map:A2 [

Sector/Stn:F3 Map:A2

Comment RELATED TO PRIOR CAD 190813073, RP .

AND BABY'S FATHER HAVE RO'S AGAINST EACH OTHER. RP'S RO INCLUDES SON AS PROTECTED PERSON AGAINST BABY'S FATHER. 910 ON KAYSON WANG ASIAN/CAUCASIAN MIX, 3 MONTHS OLD, BABY'S FATHER IS CHRISTOFFER THYGESEN DOB 19921113, WMA 6'5/150, BRN HAIR, BLU EYES, HX OF DRUG USE, pass HAS A GUN WHICH HE USES FOR HUNTING, RP HAS NEVER SEEN THE GUN, NO GUNS REGISTERED TO BABY'S FATHER. FATHER'S CADL COMES BACK TO THIS 10-20, NFl

(d) On March 25, 2019: On Sunday; Service in Menlo Park, "The Process Server Todd Brenneck stated under Penalty of Perjury Stated: “Todd Brenneck called last night a little before 10 PM and said that the lights were on and he heard movement inside, but nobody answered”. (NOTARIZED AFFIDAVIT) (EXHIBITS_33, BATES #1002)

(e) On March 25, 2019: An email was also sent to Mr. Thygesen’s Counsel, Darrick Chase at dchase@kayemoser.com regarding Kayson Wang, and Evasion of Service by Christoffer. (NO RESPONSE) Protective Order. (No Response) (EXHIBITS_33, BATES #1003)

(f) On March 26, 2019: 11:32 am San Francisco Sheriff Department: No One Answered Sheriff left Notice on Door.

(g) On March 28, 2019: 5:35 pm San Francisco Sheriff Department: No one Answered: Sheriff Left Notice On the Door.

(h) On April 4, 2019, San Francisco Sheriff Department: No one Answered: Sheriff Left Notice On the Door

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“It’s been over 1 month and we have received no pictures, health, nor updates on my 4 months old son, Kayson. Christoffer Thygesen has also evaded multiple service attempts to service him the Utah Protective Order which was also sent to yourself and his counsel in Utah. I will note this as the second maybe 3rd attempt made to inquire about the health, status, and well-being of my 4 months old Kayson Wang.”

Kailin Wang

(EXHIBITS_33, BATES #1004, 1009-1014) (I received no response, the conduct above was charged as a Felony Violation of PO)

(i) On April 9, 2019, Utah Wasatch Constables: I, Rob Kolkman, state: On 04/09/2019 at 15:38:00, I failed to serve the following: Temporary Protective Order for CHRISTOFFER STANFORD THYGESEN at 8142 STATE ST #200, MIDVALE, UT 84047 because after a reasonable investigation, I determined I services was impractical to Read the comments below for further details. “Attorney, Beau Olsen refused documents." 04/09/2019 03:38:40 PM 8142 State St #200, Midvale, UT 84047 Attorney Beau Olsen, Mitchell Olsen refused service said not authorized through the receptionist attorney would not come out.

(j) On April 9, 2019, San Mateo Sheriff: Attempted Service in Menlo Park; No One Answered The Door

(k) On April 10th, 2019, Process Server Tony Klein Served Christoffer at San Francisco Superior Court @ 8:28 am.

XV. CHRISTOFFER THYGESEN REFUSES TO PROVIDE INFORMATION ABOUT THE HEALTH AND WELFARE OF THE CHILD FOLLOWING REMOVAL OF THE CHILD, REFUSES TO SEND PICTURES, AND THREATENS THAT ATTEMPTS TO FIND OUT ANY INFORMATION, INCLUDING THROUGH THE POLICE, IS A VIOLATION OF THE TEMPORARY RESTRAINING ORDER

107. On March 23, 2010 Kailin Wang contacted the Menlo Park Police and asked them to visit the child to check on his health and welfare. She was informed that trying to make contact with the child, even to learn his welfare and even indirectly through the police, was a violation of the temporary restraining order, even though the child was NOT a protected party under the restraining order.

108. On March 25, 2019, Kailin sent an e-mail to Christoffer’s lead attorney Darrick Chase inquiring about Kayson Wang, asking about his health, his well-being, and safety. She was met with silence.

109. On April 07, 2019, Kailin inquired about the infant again through email with no response.

XVI. COMMISSIONER PATTON STAYS KAILIN WANG’S UTAH PATERNITY PETITION PENDING JUDGE DARWINGS’ EVIDENTIARY HEARING ON HOME STATE OF THE CHILD.

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111. After Kailin Wang filed her Paternity and Child Custody Petition in Utah on March 15, Christoffer Thygesen filed a Motion to dismiss alleging lack of personal jurisdiction, lack of subject matter jurisdiction (home state jurisdiction), inconvenient forum and unjustifiable conduct.

112. On June 3, 2019 Commissioner Patton stayed Kailin Wang’s Paternity Petition because Judge Darwin had decided to hold an evidentiary hearing on home state UCCJEA jurisdiction in California on June 25.

XVII. JUDGE DARWIN REVERSES HIS HOME STATE DETERMINATION AND FINDS UTAH IS THE HOME STATE OF KAYSON.

113. Because Judge Darwin’s March 6 was a temporary restraining order Judge Darwin scheduled additional hearings to set an evidentiary hearing for determining whether the temporary restraining order for domestic violence should be made permanent.

114. On May 8, 2019 Kailin Wang objected that further proceedings in California were without subject matter jurisdiction because Utah is the home state of the child Kayson.

115. On May 8, Judge Darwin bifurcated the case and sent the domestic violence trial to Judge Monica Wiley of the San Francisco Family Court and retained the issue of subject matter jurisdiction (UCCJEA home state) for himself, setting an evidentiary hearing on June 25, 2019.

116. On May 13, 2019, Judge Darwin and Judge Low had a telephone conference in which Judge Low agreed that Judge Darwin should proceed with the June 25 evidentiary hearing to determine the home state of the child.

Judge Darwin (May 13, 2019 Transcript: Pg. 5, 12:28)

“I will keep Jurisdiction until one of two things occur, either Ms. Wang successfully challenges that home state finding, which it sounds like she wants to try to do, so if I find that she can do so

procedurally and has demonstrated that California was not the home state at the time the case filed, or that even if it was that California is an inconvenient forum."

117. On June 25, 2019, after extensive briefing by both parties, after testimony by Kailin Wang and cross-examination, and legal oral arguments, Judge Darwin reversed his March 6 determination that California was the home state of the child and ruled that Utah was the home state of the child. Judge Darwin also declined to keep jurisdiction in California under an inconvenient forum argument.

Judge Darwin (Certified Transcript, Pg. 76, Lines-2:27): I do find that Utah is the home state. I think Kayson was born there. There was some indication that he -- from emails -- that he was back and forth between other states, but none of the other evidence suggests that. So my conclusion is that custody and visitation issues will have to be litigated and decided by a Utah court. So as I mentioned earlier, again, I make that determination based on everything that I heard, and notwithstanding some concerns, I have about the credibility of the respondent's testimony and some contradictory emails and communications, I think a great weight of the evidence supports that the child was in Utah almost continuously up until the day he was -- when this action was initiated.

118. Judge Darwin granted Kailin Wang supervised visitation of her child of 1 hour per week at the Rally facility.

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