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F I L E D. Filed at the Insistence of the Litigant 10/25/2021. Updates WITNESS LIST (TRANSACTION ID # )

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FL-321

Request for Order (FL-300)

Respondent Petitioner

Family Code, § 217(c);

Cal.Rules of Court, rule 5.113 www.courts.ca.gov

WITNESS LIST

Attachment to Responsive Declaration (FL-320)

hearing or trial scheduled on (date):

Other (specify):

Form Approved for Optional Use Judicial Council of California

FL-321 [New July 1, 2012]

FOR COURT USE ONLY

SUPERIOR COURT OF CALIFORNIA, COUNTY OF

STREET ADDRESS:

MAILING ADDRESS:

CITY AND ZIP CODE:

BRANCH NAME:

PETITIONER/PLAINTIFF:

OTHER PARENT/PARTY:

CASE NUMBER(S):

WITNESS LIST

ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):

TELEPHONE NO.: FAX NO. (Optional):

E-MAIL ADDRESS (Optional):

ATTORNEY FOR (Name):

RESPONDENT/DEFENDANT:

Name Subject and Brief Description of Testimony

intends to call the following witnesses to testify Other

at the time of

To keep other people from seeing what you entered on your form, please press the Clear This Form button at the end of the form when finished.

Kailin Wang 2481 Fairway Dr.

Spanish Fork, UT 84660 801-645-1060

kaywg2372@gmail.com

San Francisco 400 Mcallister st.

San Francisco, CA 94102 UFC

CHRISTOFFER STANFORD THYGESEN KAILIN WANG

FDV-19-814465

✔ ✔

WRIT A163278

TBD 12/21 TOO LATE

CHRISTOFFER S. THYGESEN

REBUTTALS TO ALL OF HIS EXHIBITS, RELATIONSHIP WITH CHILD, EVASION OF SERVICE, SURVEILLANCE, STALKING, TECHNICAL

BACKGROUND, SEXUAL ASSUALT, SOCIAL MEDIA, SOURCE OF INCOME, CREDIBILITY, FINANCIAL DEPENDECY, EMPLOYMENT, ANY OTHER RELEV

ALLAN C. THYGESEN

POLICE REPORTS, SURVEILLANCE, FINANCIAL RESPONSIBILITY TO CHRISTOFFER, RELATIONSHIP WITH CHILD, ANY OTHER RELEVANT FACTORS

TERRY THYGESEN

POLICE REPORTS, SURVEILLANCE, FINANCIAL RESPONSIBILITY TO

CHRISTOFFER, RELATIONSHIP WITH CHILD, NANNIES, ACAFS VIDEO, ANY OTHER RELEVANT FACTORS

EMMA THYGESEN

TEXT MESSAGES POLICE REPORTS, ALLEGED COMMUNICATIONS, RELATIONSHIP W/ CHILD, ACAFS VIDEO, ANY OTHER RELEVANT FACTORS

Rally Family Visitation

MAY CALL: May testify as to the supervised visits between Petitioner and the minor child.

Utah Family Academy 811 North Univ

MAY CALL: May testify as to the supervised visits between Petitioner and the minor child.

For your protection and privacy, please press the Clear This Form

button after you have printed the form. Save This Form Print This Form Clear This Form

Alt. Writ issued for re-examination of visitation

2021-07-19 WITNESS LIST (TRANSACTION ID # 66779810) Updates

ELECTRONICALLY

F I L E D

Superior Court of California, County of San Francisco

10/25/2021

Clerk of the Court

BY: TIM KYU

Deputy Clerk

Filed at the Insistence of the Litigant

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MITCHELL J. OLSEN Utah State Bar No. 13826 BEAU J. OLSEN

Utah State Bar No. 15213 OLSEN & OLSEN, L.L.C.

Attorneys for Respondent 8142 South State Street Midvale, Utah 84047 Telephone: (801) 255-7176 beau@olsenfamilylaw.net

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

KAILIN WANG,

Petitioner, vs.

CHRISTOFFER THYGESEN Respondent.

RESPONDENT’S WITNESS AND EXHIBIT LISTS

Civil No. 194400718 Judge Thomas Low Commissioner Marian Ito

COME NOW Respondent, by and through counsel, Mitchell J. Olsen, Jr., and hereby respectfully submits the following list of witnesses and exhibits that may be used at the evidentiary scheduled for March 11-12, 2021, before the Honorable Judge Low:

PROPOSED WITNESS LIST Respondent, Christoffer Thygesen.

Respondent may be reached through his counsel Mitchell J. Olsen Jr.

EXPECT TO CALL. It is expected that Mr.

Thygesen will testify as to his relationship with Petitioner prior to the birth of the minor child, his relationship with the Petitioner after the birth of the minor child, Petitioner’s actions towards Respondent and his family, Petitioner’s domestic violence towards

Respondent, his care for the minor child since

March of 2019, the activities of the minor

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child, the health of the minor child, the relationships of the minor child, and all other matters related to this case.

Petitioner, Kalin Wang

Ms. Wang may be contacted via email at Kaywg2372@gmail.com

EXPECT TO CALL. It is expected that Ms.

Wang will testify as to her whereabouts from October 2018 through March of 2019, her relationship with Respondent prior to the birth of the minor child, her relationship with Respondent after the birth of the minor child, her actions towards Respondent, the minor child, and Respondent’s family, her various filings in New York, California, and Utah, her visitation with the child, and all other matters related to this case.

Qizhong Wang

2841 Fairway Drive, Spanish Fork, Utah 84660

MAY CALL: Mr. Wang may testify as to his interactions with Petitioner, Petitioner’s whereabouts during the time period of October 2018 through March of 2019, his knowledge of Petitioner’s mental health, and all other matters related to this case.

Yunjing Cheng

2841 Fairway Drive, Spanish Fork, Utah 84660

MAY CALL: Ms. Cheng may testify as to her interactions with Petitioner, Petitioner’s whereabouts during the time period of October of 2018 through march of 2019, her knowledge of Petitioner’s mental health, and all other matters related to this case.

Terry Thygesen

May be contacted through Respondent’s counsel, Mitchell J. Olsen Jr.

MAY CALL: Ms. Thygesen may testify as to the wellbeing of the child form March 2019 through present date, inconvenient forum factors, the activities of the minor child, the harassment that she has had from Petitioner, and all other factors related to this case.

Allan Thygesen

May be contacted through Respondent’s counsel, Mitchell J. Olsen Jr.

MAY CALL: Mr. Thygesen may testify as to the wellbeing of the child from March 2019 through present date, inconvenient forum factors, the activities of the minor child, the harassment that he has had from Petitioner, and all other factors related to this case.

Unified Constable Service

3450 North Triumph Blvd. Ste. 102 Lehi, Utah 84043

MAY CALL: May testify as to the service attempts made on Petitioner at her parent’s home in February and March of 2019.

Representative from Rally Family Visitation Services

900 Hyde Street, SF, CA 94109

MAY CALL: May testify as to the supervised

visits between Petitioner and the minor child.

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415-353-6595 Sergeant Martinez

1245 3

rd

Street, SF, CA 94158 415-553-0123

MAY CALL: May testify as to the online postings and her investigation related to the criminal actions of Petitioner.

Justin Pain (Director of Trust & Safety Cloudflare)

101 Townsend Street, SF, CA 94107 1-888-993-5279

MAY CALL: May testify as to the IP addresses of various online postings.

Utah Family Academy

811 North University Ave, Provo, Utah 84604 801-377-5050

MAY CALL: May testify as to the supervised visits between Petitioner and the minor child.

EXHIBIT LIST 1 Notice of Concurrent Cases

2 Petitioner’s October 26, 2018 New York Application for ID Card.

3 November 26, 2018 Birth Certificate of Minor Child.

4 December 28, 2018 Email Stipulating to Litigate in San Francisco, California.

5 December 28, 2018 Email Providing New York Address

6 December 29, 2018 Email of Darrick Chase Agreeing to San Francisco, California 7 January 4, 2019 Email Stating She is out of Country

8 February 1, 2019 Email Confirming DNA Test Taken in California 9 February 3, 2019 Email Claiming Income All from New Jersey.

10 February 11, 2019 Paternity Results

11 February 15, 2019 Resp. Application for DVRO 12 February 15, 2019 DVRO California Order

13 February 19, 2019 Petitioner’s New York Declaration for Paternity 14 February 19, 2019 New York Petition for Protective Order

15 March 4, 2019 Supplemental DVRO Declaration 16 March 5, 2019 New York Family Offense Petition 17 March 6, 2019 California DVRO Order

18 March 6, 2019 California Hearing Transcript

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19 March 6, 2019 Suicide/Murder Post

20 March 8, 2019 Petitioner New York Declaration for Protective Order 21 March 8, 2019 Signed New York Protective Order

22 March 12, 2019 Minute Entry from Judge Smith Utah Juvenile Court 23 March 12, 2019 Southwest Confirmation

24 March 13, 2019 Petitioner New York ID Card 25 March 15, 2019 Utah Paternity Petition 26 March 15, 2019 Affidavit of John Wang

27 March 18, 2019 Minute Entry from Judge Smith Utah Juvenile Court 28 March 18, 2019 Utah Protective Order Request

29 March 26, 2019 Dismissal of New York Cases

30 March 26, 2018 Emails and Attachments to Jason Sant from Petitioner 31 March 30 through April 5

th

Police Reports

32 April 9, 2019 Cloudflare Declaration of March 6, 2019 Post Coming from East Coast 33 April 11, 2019 Signed Order by Judge Smith

34 April 25, 2019 Amended Birth Certificate 35 May 15, 2019 Declaration of Sergeant Martinez 36 May 17, 2019 California Order Extending TRO 37 May 30, 2019 California Child Support Order 38 June 3, 2019 Utah Paternity Order

39 June 3, 2019 Utah Order Denying Protective Order Request 40 June 25, 2019 California Order

41 June 25, 2019 California Order Transcript 42 September 2019 Deposition

43 September 12, 2019 California Order Modifying Supervision Order 44 September 19, 2019 DCFS/GRAMA Report

45 September 2019 Social Security Results

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46 October 2019 Criminal Complaint

47 October 11, 2019 California Order Allowing Maternal Grandparents to Attend Visitation

48 October 22, 2019 California Order Continuing Trial 49 October 23, 2019 California Criminal Protective Order 50 November 15, 2019 Order Granting Motion to Dismiss 51 December 19, 2019 California Order

52 December 19, 2019 Hearing Transcript 53 Text Messages of Parties

54 Social Media Posts Log

55 Direct Contacts of Petitioner to Respondent Family and Friends 56 Petitioner Criminal Docket

57 Declaration of Rory Will

58 Declaration of Maternal Grandparents 59 Social Media Posts

60 Summary of California Hearings

SUPPLEMENTAL CALIFORNIA EXHIBITS A Additional Summary of California Orders and Hearings

B March 6, 2019 Order Finding Ms. Wang to Deliberately Be Avoiding Service C April 5, 2019 Ms. Wang Response to DVRO

D June 25, 2019 Order

E July 18, 2019 Ms. Wangs Motion for Temporary Orders

F July 19, 2019 Minute Order Denying Ms. Wang Request for Additional Parent Time G September 12, 2019 Ms., Wang Visitation Request

H September 12, 2019 Ms., Wang Visitation Request (additional Documents)

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I September 12, 2019 Order Modifying Parent-time order to twice per month for a maximum of three hours.

J September 20,2019 Ms. Wang Request for Emergency Temporary Orders and Visitation

K September 20, 2019 Order Denying Ms. Wang’s Request for Emergency Orders L Stipulation to Cancel November 18, 2019 Hearing

M September 30, 2019 Ms. Wang’s Updated Declaration for Emergency Orders N October 11, 2019 Order granting Ms. Wang’s parents to attend visitation

O October 22, 2019 Order Continuing October 2019 Trial and reissuing March 6, 2019 Order

P November 7, 2019 Order continuing November 7 and December 2, 2019 Hearing and reissuing March 6, 2019 Order

Q January 30, 2020 Order Staying Proceedings

R April 8, 2020 Request to Register Utah Juvenile Order S August 27, 2020 Hearing Order

T May 12, 2020 Minute Order Denying Request to Register Order U July 6, 2020 Ms. Wang Aff for Contempt

V July 15, 2020 Denying majority of Ms. Wang’s Order to Show Cause Request W January 15, 2021 Ms. Wang Voluntary Dismissal of OSC

X August 24, 2020 Ms. Wang Request for Custody Orders Y August 24,2020 Order Denying Request for Custody Orders Z August 26, 2020 Ms. Wang Request for Custody Orders AA November 3, 2020 Criminal Order

BB October 14, 2020 Ms. Wang Request for Temporary Orders

CC December 23, 2020 Order Continuing Hearing Until April 22, 2021 DD December 16, 2020 Order Verifying Custody and TRO

EE January 5, 2021 Ms. Wang’s Notice of Appeal of Vexatious Litigant Ruling

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Respondent reserves the right to supplement this exhibit list at a later date when and if additional witnesses and/or exhibits are identified by the Respondent or are necessary to rebut exhibits used by the Petitioner. Respondent further reserves to supplement this exhibit and witness list as it is likely that the hearing will be continued, although no order has been signed by Judge Low yet. Furthermore, Respondent reserves the rights to call any witness listed by

Petitioner.

DATED this 10

th

day of February 2021.

OLSEN & OLSEN, Attorneys at Law, LLC Mitchell J. Olsen Jr.

MITCHELL J. OLSEN JR Attorney for Respondent

CERTIFICATE OF SERVICE

I hereby certify that on February 10, 2021, the foregoing PETITIONER’S WITNESS AND EXHIBIT LISTS and Exhibits were sent, via email, to the following:

Kailin Wang Petitioner

kaywg2372@gmail.com

/s/ Beau Olsen

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