Thygesen's 26 known Attorneys, Experts, Private Investigators vs.

Pro Se Wang
CA Attorneys
Hourly Rate Specialization Length of Representation Law Office CV
for Thygesen

Practice Areas: Criminal Defense; Licensed in California since: 1988; Education: Golden
Gate University School of Law; Selected to Super Lawyers: 2009 - 2023; For the past two
decades, Douglas Rappaport has been practicing criminal law in both state and federal courts
Douglas L Rappaport Law
throughout the Western United States. Known for his relentless, thorough, ethical, and
Douglas Lee Ofcs Address: 260
Criminal Law/DV August 2019 to Present (4+ compassionate representation, Mr. Rappaport takes pride in achieving the best possible
1 Rappaport $800/ Hr. California St, San
Family Years) outcome for each and every client, whether they face a simple fine or a life sentence. A
#136194 Francisco, CA 94111
Certified Criminal Law Expert, an AV-rated attorney and a member of the National
Phone: (415) 989-7900
Trial Lawyers Association's Top 100 Trial Lawyers, Mr. Rappaport specializes in all types
of criminal matters and represents attorneys and other professionals before State Licensing
Boards

Ms. Insalaco earned her Bachelor’s Degree from the University of Michigan and her J.D.
from the UC College of the Law, San Francisco. She has practiced exclusively in the area of
family law, at both the trial and appellate levels, for over 25 years. The California Board
of Legal Specialization certified Ms. Insalaco as a Family Law Specialist in 2003 and as
an Appellate Specialist in 2023. Ms. Insalaco is a Member or Fellow of many family law
and appellate organizations, including the Association of Certified Family Law Specialists
(ACFLS), the ACFLS Amicus Committee, the Association of Family and Conciliation Courts
(AFCC), the International Academy of Family Lawyers, the Family Law and Appellate
(June 2019 to Present) [4+
Sections of the Bar Association of San Francisco (BASF), the Contra Costa Bar Association,
Years] Insalaco has
and the Hague Convention Attorney Network. Her leadership roles include being the current
continously retained as Sucherman • Insalaco LLP
Michelene Vice Chair of BASF’s Appellate Section, sitting on the Board of the California Chapter of the
CFLS/ Appellate Thygesen's Lead Appellate 50 California Street, 34th
2 E. Insalaco $650/ Hr. AFCC and serving as Editor of its newsletter “Insights,” and being a past Chair of BASF’s
Specialist Attorney. From June 2019 Floor, San Francisco, CA
#161711 Family Law Section, a past Board Member of the ACFLS, and a past Member of the State
to April 2022 Insalaco was 94111
Bar’s Family Law Executive Committee (FlexCom). Ms. Insalaco was also formerly a
one of Thygesen's Family
Member of BASF’s Judiciary Committee, which helps to select judges in California. Ms.
Law Attorneys in this case.
Insalaco volunteers as a settlement panelist for San Francisco and Marin counties courts; is a
member of the Minor’s Counsel Panel in Contra Costa County, and has sat as a Judge Pro
Tem in San Francisco family court.
Ms. Insalaco’s current focus is family law appeals. Her published cases include C.T. v.
K.W. (2021) 71 Cal.App.5th 679; Sabato v. Brooks (2015) 242 Cal.App.4th 715; In re
Marriage of Blazer (2009) 176 Cal. App. 4th 1438; Ragghanti v. Reyes (2004) 123
Cal.App.4th 989; and In re Marriage of Edlund & Hales (1998) 66 Cal.App.4th 1454. Ms.
Insalaco successfully petitioned the California Supreme Court for review in the 2020 case
Erica Johnstone is a partner at Ridder, Costa & Johnstone LLP, a California law firm
focusing on intellectual property, internet, and privacy law. Erica specializes in representing
people who have been harmed through the use of technology. She litigates online issues
regarding the nonconsensual distribution of sexually explicit images, harassment, the
right to privacy, identity theft, impersonation, and defamation. Erica educates the public
and lawmakers on these issues, and is on the cutting edge in using the legal system to identify
and confront this new class of harms. She also served as part of then California Attorney
General Kamala Harris’s Task Force Against Cyber Exploitation. She is the Co-Founder of
Without My Consent, a 501(c)(3) nonprofit that develops educational materials to empower
victims of digital abuse to seek justice across the United States.
Erica T.
February 2019 to Present Ridder, Costa & Johnstone
3 Johnstone $550/hr. Internet Attorney Erica is licensed to practice law in states of New York and California. Before founding
(4+ Years) LLP
#242067 Ridder, Costa & Johnstone LLP, Erica was a litigation associate at Hinshaw & Culbertson,
and has also worked for an independent film producer in Los Angeles, California, and
covered local music for MTV. Erica graduated with honors from the University of North
Carolina School of Law and also attended Duke University, where she received an
undergraduate degree in Public Policy Studies.

Erica writes as a social media columnist for California Lawyer magazine. She has been
interviewed for publications such as The New York Times Magazine, The Wall Street
Journal, the New York Observer, USA TODAY, the San Francisco Chronicle, Fusion, and
Marie Claire magazine. Erica is a frequent speaker on digital abuse. She has spoken at
Stanford Law School, the National Constitution Center, the National Network to End

"Darrick T. Chase, Of Counsel" "Mr. Chase's practice includes all aspects of the trial and
settlement of complex marital dissolutions, including business valuation matters and other
complex asset matters, contests of pre-marital, cohabitation and separation agreements, pre-
judgment and post-judgment spousal support matters," "and high conflict custody and"
"visitation matters, including extensive experience with relocation issues" ". Mr. Chase
has extensive estate planning experience, and experience in resolving post-death estate and
KAYE • MOSER • trust disputes. Mr. Chase also counsels clients going through mediation, including assisting
HIERBAUM • FORD LLP clients in acquiring appropriate communication and negotiation skiUs. Mr. Chase has
Family Law Attorney December 2018 to January
Darrick T. 235 Montgomery Street, extensive experience litigating highly contested property division cases, support disputes, and
4 $615/hr. (Specialist in Child 2023 (Committed Suicide)
Chase #151256 27th Floor custody conflicts." "Mr. Chase has served as a Pro Tern Settlement Conference Judge for the
Relocation) (4+ Years)
San Francisco, California San Francisco Superior Court. Mr. Chase has extensive negotiation and hearing experience as
94104 a San Francisco Unified Family Court appointed Minors Counsel on behalf of minor children
going through high conflict custody and visitation disputes. Mr. Chase also serves as a Mentor
at the request of the San Francisco Unified Family Court assisting attorneys seeking to qualify
as Minors Counsel." "Mr. Chase practiced family law with the firm Sucherman and Collins
from 1991 through 1994 and with the Law Offices of Darrick T. Chase from 1994 through
2008. Mr. Chase is also serving an elected four year term as a Director and the current
President of the Bel Marin Keys Community Services District in Marin County, California"
 CA Attorneys
Hourly Rate Specialization Length of Representation Law Office CV
for Thygesen

With over 30 years of experience, Michael brings a thorough and practical approach to
solving legal problems.

As a family law attorney with experience in civil litigation and appellate law, he is highly
skilled at delivering messages in ways his clients, judges, and opposing counsel hear and
understand. He is reasonable and controlled under pressure, with a keen ability to spot flaws
in the opposition.
May 2022 to January 2023 McManis Faulkner
family law attorney
[8 Months] (withdrew on (Partner) Fairmont Plaza, In addition to his family law practice, Michael has tried cases in both state and federal court,
Michael Gannon with experience in
5 $800/ Hr. January 19, 2023, one day 50 W San Fernando St and handles appeals in the Ninth Circuit and the California Court of Appeal, on matters
Reedy #161002 civil litigation and
before Darrick Chase 10th Fl, San Jose, CA involving civil rights, constitutional issues, business litigation, land use, and family law.
appellate law,
committed Suicide) 95113 Admissions: State Bar of California, U.S. District Court, Northern, Central, Southern and
Eastern Districts of California, U.S. Ninth Circuit Court of Appeals and Federal Circuits,
U.S. Supreme Court Education J.D., University of San Francisco School of Law B.A.,
Stanford University Awards. The Best Lawyers in America® in the areas of Appellate
Practice, 2021-24; and Family Law Member of award winning team “The Best in Family
Law”, The Recorder, 2010 - 2019 Named to Northern California Super Lawyers, 2018-2023
Granted the American Jurisprudence Family Law Award from the University of San
Francisco, School of Law

Thygesen's
Substance of
Expert Hourly/Daily Rate
testimony
Witnesses

Was hired by Thygesen as

Erik K. Rasmussen, JD,
Expert Witness in Thygesen
CISSP
Erik Rasmussen, v. Wang , Superior Court
Global Head of
CISSP, JD for the State of California,
Cybersecurity and Risk
Global Head of San Francisco, 2019 (State Erik Rasmussen, CISSP, JD is a former Special Agent
Cyber Security Management Solutions
6 Cybersecurity $700/Hr. Family Law Case) AND for with the United States Secret Service with over 19 years of experience in fraud investigations,
Expert Witness Grobstein Teeple LLP
and Risk People v. Kailin Wang , cybersecurity, and computer forensics.
Los Angeles County
Management, Superior Court of California
6300 Canoga Avenue
GTLLP County of San Francisco,
Suite 1500W
2021
Woodland Hills CA 91367
(State Criminal Case)

Substance of
testimony. Ms.
Amman will be called
Hired by Thygesen for the 3- MOLLY AMMAN, JD,
to testify about a BACKGROUND: Retired FBI profiler, attorney, and Certified Threat Manager Molly
$500 hourly; or if on- Day Termination of CTM 3775 EP True
category of behavior Amman is now engaged in private practice, principally addressing matters such as behavioral
Molly Amman, site Visitation even Supervised Parkway, #262
7 that is unfamiliar to threat assessment, threat management, targeted violence prevention and analysis, domestic
JD, CTM presence is requested a Evidentiary Hearing set for West Des Moines, Iowa,
most but known in extremism, linguistic assessment and interviewing, and corporate violence prevention
daily fee of $8,000. February 27, 29, March 12, 50265
the threat assessment programming and policy.
2024 www.mollyamman.com
community as
stochastic
violence.

I am a licensed psychologist in California since 1982, and a board-certified

forensic psychologist (American Board of Professional Psychology) since 1991. I have
expertise in criminal forensic psychology, and have been consulting, teaching, testifying,
researching, andpreparing scientific studies and books in the following areas for the past
Hired for Thygesen's
thirty years: psychopathy, stalking, targeted violence, the relationship of mental disorder to
Request for 217 Evidentiary
criminality, and other topics at the nexus between psychology and the criminal law. I have
Hearing Re: Termination of
REID MELOY, Ph.D. published over 250 science articles in peer reviewed journals and 13 books, the first one being
Visitation even Supervised
A Forensic Psychological The Psychopathic Mind (Aronson, 1988) and most recently, the International Handbook of
Filed on 1/9/23 for 3-Day
Corporation Threat Assessment, 2nd edition (Oxford University Press, 2021) which won the Manfred
Evidentiary Hearing that
Guttmacher Award from the American Psychiatric Association this year. I was also awarded
J. Reid Meloy, $800 hourly; or if on- VIOLENCE RISK & was DENIED by Judge
(office address upon the Distinguished ContributionsAward from the American Academy of Forensic Psychology
Phd, Abpp, site THREAT Flores at the 02/23/23
8 request) this year. I am a former clinical professor of psychiatry (voluntary status) at the University of
Forensic presence is requested a ASSESSMENT OF Hearing (See FOAH entered
La Jolla, CA 92037 California, San Diego, School of Medicine, and a current faculty member of the San Diego
Psychologist daily fee of $10,000. KAILIN WANG. on 04/6/23; p.4, paragraph
Psychanalytic Center. For the past twenty years I have been a consultant to the Behavioral
11) Per Dr. Meloy's CV
Cell: 858–922-1528 Analysis Unit, FBI, Quantico. Dr. Meloy writes for Psychology Today. Dr.Meloy US. v.
People v. Kailin Wang
Email: Buster Hernandez (2020-2021)-retained by the prosecution. Testified at sentencing in federal
(2022- ) retained by
[email protected] court, Southern District of Indiana. Sentenced to 75 years in prison. And also on his CV
attorneys on a civil custody
People v. Kailin Wang (2022- ) retained by attorneys on a civil custody case and
case and criminal stalking
criminal stalking case.
case.
Driver v. Driver (2002-2004). Retained by the plaintiff in a termination of parental rights
case, Cook County Illinois jurisdiction. Testified for three days concerning the stalking
behavior of the ex-husband, who was also psychopathic. Judge terminated parental rights of
ex-husband.
 CA Attorneys
Hourly Rate Specialization Length of Representation Law Office CV
for Thygesen

Qualifications
1. I am a Clinical and Forensic Psychologist licensed by the State of California. I
have been in private practice as a licensed psychologist since 1987. In addition, I have
earned Board Certification in Forensic Psychology by the American Board of Forensic
Psychology (2008) and am a fellow of the American Board of Professional Psychology and
Hired for Thygesen's
the Society for Personality Assessment. Attached hereto as Exhibit A is my current
Request for 217 Evidentiary
curriculum vitae.
Hearing Re: Termination of
2. For over thirty years, a significant part of my professional practice has been in the
Visitation even Supervised
$550 hourly; or if on- area of family law, where I have performed over one hundred-fifty child custody evaluations,
Robert L. Filed on 1/9/23 for 3-Day
site served as a mediator, Parenting Coordinator, co-parenting counselor, parenting coach and
9 Kaufman, Phd, Evidentiary Hearing that
presence is requested a individual therapist. In addition, I have provided consultation to attorneys and made
Abpp was DENIED by Judge
daily fee of $10,000. numerous presentations regarding custody matters at national and international conferences,
Flores at the 02/23/23
for professional organizations, local family law groups and Family Court Services. Details of
Hearing (See FOAH entered
these activities also appear in my curriculum vitae.
on 04/6/23; p.4, paragraph
3. I have developed specific expertise in developing parenting plans for separated,
11)
divorced, and never married families who have infants, toddlers and/or young children. In
this area, I have published in professional journals, have made presentations to groups of
mediators, bench officers and mental health professionals. I have been asked on many
occasions to create and develop parenting plans via mediation and evaluation venues. I have
also been qualified as an expert in court for these subject areas on many occasions.

"Dr. Paul Elizondo is triple boarded by the American Board of

Psychiatry and Neurology (ABPN) in adult, child & adolescent,
and forensic psychiatry and currently hold a position as an
Assistant Clinical Professor (volunteer faculty) at the University
of California, San Francisco (UCSF) in the Department of
Psychiatry and Behavioral Sciences. In this role, he conducts
Paul M.
multiple weekly seminars for residents in psychiatry wherein
Elizondo III, $550 hourly; or if on- Hired for the last day 3230 Kerner Blvd. San
the subject of child development and the significance of the
D.O. site (1/5/22) Termination of Rafael, CA
10 parent-child relationship are regularly discussed. On a weekly
Forensic Child presence is requested a Visitation Even Supervised P (650)283-6777
basis, he provides psychiatric care to youth and their families
Psychiatrist daily fee of $10,000. Evidentiary Hearing [email protected]
who reside in Marin County or are incarcerated at the Marin
County Juvenile Hall. Also on a weekly basis, he also provides
psychiatric care to youth who are currently participating in
residential treatment for between two and twelve weeks.
Through these work experiences, he has had the privilege of
witnessing hundreds of functional and dysfunctional family
dynamics and their long-term sequelae."

Mark I. Levy, MD,

DLFAPA
Dr. Mark Levy is board certified by both the ABPN and
(Medical Director), Main
National Board of Physicians and Surgeons in Adult and
Office
Forensic Psychiatry. He is an Associate Professor of
Mark Levy, Forensic Psychiatric
$550 hourly; or if on- Psychiatry (volunteer faculty) at UCSF and teaches in the Law
M.D. Associates, LP
site and Psychiatry Fellowship of the Department of Psychiatry. He
11 Forensic 655 Redwood Highway,
presence is requested a is a Distinguished Life Fellow of the American Psychiatric
Psychiatrist Suite 271
daily fee of $10,000. Association and the Medical Director of Forensic Psychiatric Associates LP. He has practiced
Mill Valley, CA 94941
clinical psychiatry for 46 years, forensic psychiatry
P (415) 388-8040
since the middle 1980’s and has conducted well over 500 forensic psychiatric
F (415) 634-2400
evaluations and testified in 65 State and Federal civil trials.
www.fpamed.com
[email protected]

Thygesen's Utah
Attorneys

Intial appearance in the

Case: FDV-19-814465 on
6/25/19 UCCJEA
Mitchell J.
$650/ Hr. (Per Partner @ Olsen & Olsen, Evidentiary Hearing,
12 Olsen UT Bar # Family Law Utah Bar: 10/31/2011
Thygesen's 12/I/E, Atty.s at Law continously represented
13826
Thygesen on all Trial
Court matters and
Appeallate matters
 CA Attorneys
Hourly Rate Specialization Length of Representation Law Office CV
for Thygesen
Retained 8/1/2019 to
Present. The 8/1/19 date is
obtained from SF Sgt.
Martinez Police Report.
Rappaport Filed on 2019-
10-15ASSOCIATION OF
ATTORNEYS:
RAPPAPORT, DOUGLAS
LEE ADDED AS
ATTORNEY FOR
THYGESEN,
Martin Olsen, Partner @ Olsen & Olsen
13 $400/ Hr. Family Law CHRISTOFFER Utah Bar: 10/15/1991
UT #: 6015 Law, LLC
STANFORD. Has
continously represented
Thygesen at every one of
the 40 + hearings in FDV-
19-814465 (SF Superior
Family Law Matter), Lead
Atty. for the DVRO trial,
and acting as Victim's
Attorney in People v.
Wang 19016407 (PC 646.9
charges filed on 10/17/19)

Bryant J. 4/1/2020 Co-counel with

McConkie
14 McConkle, UT ($325/ Hr.) Family Law Attorney Michele Insalaco UT Bar #: 5/24/2005
, Hales & Gunn
#: 10408 for Thygesen's Appeals

Beau J. Olsen
15 $325/ Hr. Family Law Olsen & Olsen 3/3/19 Utah Bar: 10/18/2014
Utah Bar: 15213

Hired for a 5 minute

hearing scheduled for
March 18, 2019 the same
day Wang was forced to fly
Lindsay B.
C.A. GOLDBE back to Utah for Utah Date
16 Lieberman, NY $425/ Hr. Internet Law
RG PLLC Shelter DCFS hearing to Admitted in NY: 02/15/2012
Bar: 5020466
defend against Thygesen's
False Child Abuse
Allegations that was
Reversed on 11/4/19

Thygesen's
Private
Investigators
Chris Bertram
Utah Private
17 Utah Private $250/hr. December 2018-Present
Investigator
Investigator

Thygesen hired him to

pretend he was from
the Utah Public
Defenders Office
that’s currently
Patrick Adams representing me in the
Utah Private
18 Utah Private Utah Subpoena December 2018-Present
Investigator
Investigator forgery case insitgated
by Thygesen.
Thygesen had his use
Pre-Text method to
obtain my Mental
Health Records

Thygesen paid to fly

Christopher
Christopher Brenner
Brenner. Mr.
of Hillard and Heintz Director of
Brenner is a
19 now Jensen Hughs in Investigations at December 2018-Present
Director of
from Chicago for the Hillard
Investigations at
DV Trial 10/18/22 to
Hillard
10/20/22
 CA Attorneys
Hourly Rate Specialization Length of Representation Law Office CV
for Thygesen

Private Investigator,
Matthew Dennis.
(11/18/21 RT 3:1-3,
RT 6:1-28)
Matthew Dennis is a
20 Matthew Dennis Private Investigator Security Detail December 2018-Present
(PI) hired by the
Thygesen family to
surveillance the Wang
Family at Terra
Firma, and at Rally.

"Private Investigator,
Matthew Dennis.
(11/18/21 RT 3:1-3,
RT 6:1-28)
Matthew Dennis is a
Gregory
21 Private Investigator Security Detail December 2018-Present
Johnson
(PI) hired by the
Thygesen family to
surveillance the Wang
Family at Terra
Firma, and at Rally."

In April 2022, I was

employed by Jensen
Hughes, Inc. ("JH"),
which is a company
hired by Ridder, Costa As part of my duties
& Johnstone LLP at JH, I was
("RCJ"), to provide responsible for
TIFFANY
professional services monitoring any andl
BOSTROM
for the benefit of RCJ all Twitter
22 (Jensen Hughs December 2018-Present
(Erica Johnstone's accounts associated
formerly Hillard
Firm for Thygesen) in with Kailin Wang
and Heintz)
the advisement of their that were publicly
clients. Unless accessible on the
otherwise stated, I internet.
have personal
knowledge of the facts
set forth in this
declaration.
 CA Attorneys
Hourly Rate Specialization Length of Representation Law Office CV
for Thygesen

In April 2020, I was

employed by Hillard
Heintze LLC"), which
was a company hired
As part of my duties
by Ridder, Costa &
at HH, I was
Johnstone LLP
responsible for
TALIA ("'RCJ"), to provide
monitoring any and
BEECHICK professionals ervices
all Twitter accounts
23 (Jensen Hughs for the benefit of RCJ December 2018-Present
associated with Kailin
formerly Hillard in the advisement of
Wang that were
and Heintz) their clients. Unless
publicly accessible on
otherwise stated, I
the internet.
have personal
knowledge of the facts
set forth in this
declaration.

Private Investigator
JENNIFER https://www.221bpar
since 2019 has worked
24 MACKOVJAK, tners.com/who-we-
on the case on behalf
PARTNER are
of Thygesen

In October of 2019
Thygesen's PI Hillard
Adam Zoll Mr.
and Heintz
Zoll is a
Surrepticiously
25 Director of December 2018-Present
Obtained Wang's
Investigations at
DMV records to have
Hillard Heintze.
her Falsely
incriminated

In March of 2019
Thygesen hired Mark
Brenzinger to falsely
state that Wang made
Mark
the March 6, 2019
Brenzinger
26 "Kill Baby K" post December 2018-Present
Psychologist,
and had him lie to law
PsyD
enforcement and Utah
DCFS about Wang
have Severe Mental
Disorders
 EXHIBIT 1
Douglas Rappaport ($800/hr.) has been retained by Thygesen Continuously since August 2019.

Rappaport has appeared on behalf of Thygesen for 50+ hearings in FDV-19-814465

Rappaport has also appeared on behalf of Thygesen for 40+ hearing in People v. Wang Case no.
19016407 as Victim’s attorney
CA Attorneys
Hourly Rate Specializ.ation Length of Representation Law Office CV
for Thygesen

Practice Areas: Criminal Defense; Licensed in California since: 1988; Education: Golden
Gate University School of Law; Selected to Super Lawyers: 2009 - 2023; For the past two
decades, Douglas Rappaport has been practicing criminal law in both state and federal comts
Douglas L Rappaport Law
throughout the Western United States. Known for his relentless, thorough, ethical, and
Douglas Lee Ofcs Address: 260
Criminal Law/DV August 2019 to Present (4+ compassionate representation, Mr. Rappaport takes pride in achieving the best possible
1 Rappaport $800/ Hr California St, San
Family Years) outcome for each and every client, whether they face a simple fine or a life sentence. A
#136194 Francisco, CA 94111
Ce11ified C1iminal Law Expert, an AV-rated attorney and a member of the National
Phone: (415) 989-7900
Trial Lawyers Association's Top 100 Trial Lawyers, Mr. Rappaport specializes in all type!
of criminal matters and represents attorneys and other professionals before State Licensing
Boards
 
  
  

-- --
-- -
  

  
  

  
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
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

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




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


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



9/18/23, 2:49 AM Top Rated San Francisco, CA Criminal Defense Attorney | Douglas Rappaport | Super Lawyers

Criminal Defense attorneys / California / San Francisco

Douglas L. Rappaport
Top rated Criminal Defense attorney in San Francisco, California

Law Offices of Douglas L. Rappaport

---------

Practice Areas: Criminal Defense

Licensed in California since: 1988

Education: Golden Gate University School of Law

Selected to Super Lawyers: 2009 - 2023

Law Offices of Douglas L. Rappaport

260 California Street

Suite 1002
San Francisco, CA 94111
Phone: 415-989-7900
Email: Douglas L. Rappaport

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9/18/23, 2:49 AM Top Rated San Francisco, CA Criminal Defense Attorney | Douglas Rappaport | Super Lawyers
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First Admitted: 1988, California

Professional Webpage: http://sfcrimlaw.com/Contact.aspx

Special Licenses/Certifications:
• State Bar of California Certified Criminal Law Expert

Honors/Awards:
• Top 100 Trial Lawyers , National Trial Lawyers, 2012

• Premier 100, American Academy of Trial Attorneys , 2015

• Top 100 Trial Lawyers, National Trial Lawyers, 2014

• Top 100 Trial Lawyers, National Trial Lawyers, 2015

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15 YEARS
SUPER LAWYERS
Super Lawyers: 2009 - 2023

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 I MICHAEL REEDY (161002)
McMANIS FAULKNER
2 a Professional Corporation
ELECTRONICALLY
50 West San Fernando Street, 10th Floor
3 San Jose, California 95113 FILED
Superior Court of California,
Telephone: (408) 279-8700 County of San Francisco
4 Facsimile: (408) 279-3244
Email: [email protected] 11/18/2022
5 Clerk of the Court
BY: ANNIE TOY
DOUGLAS RAPPAPORT (136194) Deputy Clerk
6 LAW OFFICES OF DOUGLAS L. RAPPAPORT
260 California Street, Suite I 002
7 San Francisco, CA 94111
Telephone: (415) 989-7900
8 Facsimile: (415) 989-7950
Email: [email protected]
9
Attorneys for Petitioner,
10 CHRISTOFFER THYGESEN

11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
FOR THE COUNTY OF SAN FRANCISCO
13

14 UNIFIED FAMILY COURT

15
In re Matter of: CaseNo.: FDV-19-814465
16
CHRISTOFFER THYGESEN, DECLARATION OF DOUGLAS L.
17 RAPP APO RT IN SUPPORT OF
Petitioner, PETITIONER'S REQUEST FOR
18 PREY AILING PARTY FEES
and
19 Date: December 20, 2022
KAILINWANG, Time: 1:45 p.m.
20 Dept.: 404
Respondent. Judge: The Hon. Daniel Flores
21
22
23
24 I, Douglas L. Rappaport, do hereby declare:
25 1. I am submitting this declaration in support of Petitioner's request for prevailing party
26 fees.
27
28

In re MatterofThygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF DOUGLAS L.

RAPPAPORT IN SUPPORT OF PETITIONER'S REQUEST FOR PREY AILING PARTY FEES
 1 2. I am an attorney admitted to practice law in the State of California and before this Court.
2 I have been continuously licensed since 1988. I am a Certified Criminal Law Specialist

3 by the State Bar of California and one of the attorneys of record for Petitioner since July

4 2019. The scope of my engagement pertains to any and all issues necessary to ensure

5 Petitioner and his family's physical and emotional safety, including acting as lead

6 counsel at the October 18-20, 2022 trial on Petitioner's Request for a Domestic Violence

7 Restraining Order ("DVRO").

8 3. I am familiar with the work performed to date relating to Petitioner's DVRO request, and

9 I have reviewed my firm's billing statements in this case.

10 4. My hourly rate in this case is $800. I am familiar with the hourly rates of similarly-
11 experienced professionals in San Francisco and the foregoing is commensurate with their
12 rates.
13 5. The work involved here has been complex, especially given the thousands of pages
14 Respondent has filed in this case to date that directly relate to the DVRO request, which

15 has been pending since February 2019. Moreover, there could be no more important

16 issues than the safety of Petitioner and his family.

17 6. The following are summaries of the work completed to date which directly relate to the

18 ultimate issuance of the DVRO on October 21, 2022.

19 • Initial review of approximately 3,000 pages of online harassment and threats

20 posted by Respondent and over 20,000 pages of computer-generated documents

21 obtained pursuant to subpoena returns by Google, Faceboo~ Comcast, Charter

22 and others to link Respondent to the online harassment and threats.

23 • Preparation for the trial originally scheduled for October 22, 2019, including
24 drafting Motions in Limine, preparation and coordination of 39 potential

25 witnesses, including an expert witness in cyber investigations; creating trial

26 exhibits handling Respondent's Motion to Stay the proceedings.

27 • Investigation of on-going harassment and threats following the issuance of the

28 TRO on March 6, 2019, including but not limited to an August 2019 email to
2
In re Matter of Thygesen v. Wang, Case No.; FDV-19-814465; DECLARATION OF DOUGLAS L.
RAPPAPORT IN SUPPORT OF PETITIONER'S REQUEST FOR PREVAILING PARTY FEES
 1 DOUGLAS L. RAPPAPORT (SBN 136194)
Law Offices of Douglas L. Rappaport
2 260 California Street, Suite I 002
San Francisco, CA 94111
3 Telephone: 415-989-7900
Facsimile: 4 I 5-989-7950
4 ()Ci l 5 ZOl9
Attorney for Petitioner Cl.l:;i~KvF T~15 <.;Cur\T
5 CHRISTOFFER STANFORD THYGESEN NESTORPANELO ,
jjy ~ - oaputy C,11:rl(
6
SUPERIOR COURT OF THE STATE OF CALIFORNIA
7
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
8
CHRISTOFFER STANFORD THYGESEN, Case No. FDV-19-814465
9
Petitioner, TRIAL BRIEF
10
V.
11
KAILIN WANG,
12
Respondent.
13 I
----------------
14
1bis Trial Brief is offered pursuant to California Rule of Court 5.394.
15
I. Brief Summary of the Case
16
Background

Valentine's Day, 2018 was a day that would change Petitioner Christoffer Thygesen' s lite

forever. At twenty-five years old, he had recently graduated from Carnegie Mellon and moved from
19
the East Coast back to the San Francisco Bay Area where he began his first "real" job at a tech
20
company. He was lonely, and turned to Tinder, a dating/hook-up app. There, he connected with
21
Kailin Wang. Little did he know that Ms. Wang, who represented herself as an international tax
22
accountant in her late twenties, was in reality a thirty-six year old mentally ill serial stalker, obsessed
23
with having a baby with her victims.
24
In 2014 in New York, Ms. Wang was criminally charged after terrorizing her first victim,
25
Rory Will. According to court documents, Ms.Wang met Rory Will on Tinder-the same dating app
26
where she would later meet Petitioner--and after Mr. Will would not have unprotected intercourse
27

28

Trial Brief 1
 LAW OfHCES OF
DOUGLAS L. RAPPAPORT
260 CALIFORNIA STREET, SUJTE 1002
SAN FRANCISCO, CA 94lll
14151989-7900
FAX 14151 989-7950

June 22, 2020

Via FedEx

Donald du Bain, Assistant District Attorney

Office of the District Attorney
350 Rhode Island Street
North Building, Suite 400N
San Francisco, CA 94103

Re: People v. Kailin Wang

San Francisco Case Number 19016407-
Wo11g'sPerjury

Don,
As discussed, nonnally one more felony charge doesu't add much to the overall custody time
calculation, but charging felony perjury (PC §1 J8) here makes sense for two equally important
reasons. First, it makes your job so much easier because regardless of Wang's alleged defenses on
the hundreds ofinternet posts, you can easily convict her of perjury with very little effort. And more
importantly, given that Ms. Wang is unable to control her anger and has continued to harass Walker
Stone even while she is being prosecuted, it is a certainty that Christoffer Thygesen will not be her
last victim. A perjury conviction is exactly the scarlet letter that is needed to ensure that future
victims, prosecutors and judges understand who they are dealing with when Ms. Wang inevitably
finds herself back in court down the road.

Background
After meeting on Tinder, 25 year old Christoffer Thygesen and 35 year old Kailin Wang had a total
of two dates in late February and early March, 2018, both romantic. As a result, Ms. Wang became
pregnant and had a child,-. in November, 2018. Following the birth, Ms. Wang declared Los
Angeles was her residence on the birth certificate and filed a paternity/child support case in Los
Angeles. Christoffer got himself voluntarily served, and shortly thereafter she began stalking him.
She then sent Christoffer's attorney an email on December 28, 2018, stating that she and the baby
were between three states, California, Utah and New York, but she maintained residence in New
York. Consequently, she requested that Christoffer agree to transfer jurisdiction for the family law
case from Los Angeles to San Francisco for the convenience of both parties, and he agreed. (The
December 28, 2018 email is attached hereto as Exhibit "A")

003745
 Law Offices of
Douglas L. Rappaport
260 California Street, suite 1002
San Francisco, CA 94111
(415) 989-7900
[email protected]

January 18, 2023

VIA EMAIL ONLY

Kailin Wang
[email protected]

Re: Thygesen v. Wang

San Francisco County, Case No. FDV-19-814465
Meet & Confer Re: Reopening Discovery

Dear Ms. Wang,

On January 9, 2023, Petitioner filed pleadings in response to your FL-300 Request for Order to
increase time for supervised in-person visitation. File & Serve Xpress served these pleadings on you
that same day. The pleadings included our Responsive Declaration, a Memorandum of Points and
Authorities (“MPA”), and several declarations, including a declaration from Dr. J. Reid Meloy.

In the MPA, we notified the Court that we intend to file a motion requesting that the Court authorize
Dr. Meloy to conduct a clinical and forensic evaluation of you so that he has the best possible data
to issue a violence risk and threat assessment and to determine the possibility of future behaviors and
render a formal DSM0-5-TR diagnosis. (MPA, at 7:18-22, 17:12-14.) (Decl. of Dr. Meloy, ¶8). The
evaluation would consist of various tests and measures, as well as an in-person interview. The
evaluation would be expected to take 6-8 hours, and would be completed in one day. (Decl. of Dr.
Meloy, ¶ 8.)

In order to proceed with this evaluation and examination, discovery needs to be reopened. Discovery
in this case was closed on September 23, 2019, 30 days before the initial trial date of October 22,
2019. (Code Civ. Proc., § 2024.020.) Both Judge Wiley and Judge Flores have advised counsel that
if they want to conduct additional discovery, a motion to reopen discovery must be filed.

We are preparing a motion to reopen discovery on the limited issue of visitation, including what is
in the child’s best interest for visitation. If you agree to reopen discovery on this limited basis, and
to Dr. Meloy performing a clinical and forensic evaluation of you, then we agree that you would be
permitted to depose the experts on our witness list and conduct discovery on visitation as set forth
in Code Civ. Proc. § 2034.410 and San Francisco Local Rule 11.13(A). Equally, I also note that the
evaluation is a mechanism for you to establish you have no psychological issues warranting a
suspension of visitation, as you will likely argue.
Before filing a motion to reopen discovery, a party seeking to conduct additional discovery must
meet and confer with the opposing party or opposing counsel and make a reasonable and good faith
attempt to resolve any issue that would be raised in a motion to reopen discovery. (Code Civ. Proc.,
§§ 2024.050, 2016.040.) This letter constitutes our attempt to meet and confer with you in good
faith to resolve any issues in our motion to reopen discovery. Let us know if you have questions or
requests.

Because you will need to travel to California for the evaluation, we will advance to you the
reasonable costs and expenses for you to travel to the Bay Area for your place of examination, which
would be in the Bay Area. Advancing travel costs is required by law.

Our responsive pleadings identified witnesses we intend to present at the Section 217 hearing if the
Court grants our request for a 3-day hearing. Those witnesses include Petitioner, Terry Thygesen,
Dr. Meloy, and Dr. Robert Kaufman. We filed declarations signed by these witnesses that outline
the issues about which they will testify in response to your request to increase supervised visitation,
which Petitioner opposes. We also may call you and your parents as witnesses, as stated in our
pleadings.

Please let me know by 5 pm on Friday, January 20, 2023, whether you agree (1) to reopen discovery
on the limited issue of your visitation request and our affirmative relieve now before the court, and
(2) to allow Dr. Meloy to perform a clinical and forensic evaluation of you. He will need to perform
the evaluation in California, and he is available to do so on February 13, 2023, or later. If you agree,
we will prepare a Stipulation and Order and determine an appropriate date.

Going forward, please send all emails related to this issue to both myself and Mr. Chase only as well
as include just myself and Mr. Chase on all pleadings, which should be filed and served through
File&Serve Xpress per court orders.

If I do not hear from you by 5 pm on January 20, I will presume you oppose both requests and will
seek appropriate relief from the Court.

Thank you.

Very truly yours,

DOUGLAS L. RAPPAPORT

DOUGLAS L. RAPPAPORT, ESQ.

RE: Christoffer Thygesen v. Kailin Wang

Mon 1/6/2020 9:08 AM

To: du Bain, Donald (DAT)
Cc: Martinez, Michele (POL)
Don & Michelle,
Good morning. Thank you for this update and to poorly paraphrase Tennyson, ‘Tis be er to have obtained a
search warrant and not go en into the phone than never to have tried at all.’ If you do obtain access, there is no
doubt that it will contain a treasure-trove of incrimina ng informa on.
Doug

From: du Bain, Donald (DAT)

Sent: Friday, January 3, 2020 5:38 PM
To:
Cc: Mar nez, Michele (POL)
Subject: RE: Christoffer Thygesen v. Kailin Wang

Doug,

Thanks for your sugges on.

A er discussing the ma er, Michele and I have agreed to seek a search warrant for the defendant’s phone. Since
we don’t have the defendant’s password, our efforts may be fu le but we’ll try our best.

Best regards,
Don

Donald du Bain
Assistant District A orney
Office of the District A orney
350 Rhode Island Street
North Building, Suite 400N
San Francisco, CA 94103

The information contained in this electronic message may be confidential and may be subject to the attorney-client
privilege and/or the attorney work product doctrine. It is intended only for the use of the individual or entity to
whom it is addressed. If you are not the intended recipient, you are hereby notified that any use, dissemination or
copying of this communication is strictly prohibited. If you have received this electronic message in error, please
delete the original message from your e-mail system. Thank you

From:
Sent: Thursday, December 12, 2019 12:24 PM
To: du Bain, Donald (DAT) ; Mar nez, Michele (POL)
Subject: Christoffer Thygesen v. Kailin Wang

This message is from outside the City email system. Do not open links or attachments from untrusted sources.
Mr. Du Bain and Sergeant Martinez,

If you have not previously drafted a search warrant for Ms. Wang’s telephone, it may be beneficial to do so.
Just yesterday, December 11, 2019, Ms. Wang filed an Updated Responsive Declaration in the San Francisco
domestic violence restraining order matter. In her Declaration, she stated in Paragraph 9 that, “When Mr.
Thygesen had me arrested on 10/18/19, Ms. Wang also had her phone confiscated which had all of her
contacts and log in for her emails.” (A copy of this declaration is attached and paragraph 9 highlighted for
your reference.)

If probable cause didn’t exist before, it certainly does now after she herself acknowledged that the login
information for all of her email accounts was stored in her phone. In addition, I’m sure the phone is filled with
a treasure trove of incriminating evidence.

Just a thought….

Best,

Doug
 SAN MATEO COUNTY DISTRICT ATTORNEY'S OFFICE Page 1
400 COUNTY CENTER, 3RD FLOOR REDWOOD CITY, CA 94063 650-363-4636
NARRATIVE - Opening Narrative 21-0120-01

SUMMARY:
On 1/20/2021, I was assigned this case by Chief Inspector John Warren. I reviewed the attached
documentation and found that the case involved the passing of a fictitious subpoena by Suspect Wang.
Wang apparently created and submitted a fictitious Utah subpoena to a pre-school located in Menlo Park
in violation of PC 470(a)/(c) - Forgery and PC 166(a)(4) - violation of a restraining order. The records
indicate that there is a substantial history concerning Wang committing similar acts, domestic violence,
and stalking.

INVESTIGATION:
1/21/2021:
Because of a possible child abduction risk and/or threat to the personal safety of the involved parties in
this case, Senior Inspector Bill Massey sent an email (attached) to Attorney Doug Rappaport
(representing the victims) and Menlo Park Police Department Sgt. Ed Soares whereby he introduced
them to each other and encouraged them to open a dialog about ensuring the safety of the victims in this
case.

1/26/2021:
On 1/26/2021, I contacted Attorney Doug Rappaport regarding this case. He told me the following:

STATEMENT OF ATTORNEY DOUG RAPPAPORT:

Rappaport stated that he is representing Christoffer (sic) Thygesen and Thygesen’s son,
Thygesen. Thygesen had a brief relationship with Kailin Wang that resulted in their son
Thygesen (2 years old). Rapport said that Wang is “absolutely insane” and she has significant mental
health issues. Wang also has a history of becoming involved in relationships with men and then
committing crimes that have included stalking and the creation of false evidence. During one
relationship, Wang falsified evidence that resulted in a false arrest.

Rappaport said that Thygesen has dealt with numerous legal issues concerning Wang. Wang currently
has a stalking case filed against her by the San Francisco District Attorney’s Office. The next
appearance on the San Francisco stalking case is currently set for March. As a result of stalking case
and other issues, Thygesen currently possess full legal custody of their son. Wang is currently limited to
minimal supervised visits wherein she is not allowed to take photographs of their son because the court
has found her to be a flight risk.

Rappaport stated that he and Thygesen believe Wang is a danger to both Thygesen and their son. She
has made threats to kill their son in the past and she is mentally unstable.

Rappaport stated that Wang is believed to currently reside in Utah. Wang has listed her address 2481
Fairway Drive, Spanish Fork, Utah with the courts. Wang has also been utilizing the Utah courts for the
current child custody case where she is representing herself. As part of her custody case, Wang has
subpoena rights wherein she has previously legally utilized the system to subpoena records related to
their child. The process requires Wang to make a subpoena request through the court system. Other
party members are then given an opportunity to review the subpoena and raise an objection if desired.
Prepared By: Date: Approved By: Date:
14860 BROAD, MATT 01/27/2021 80202 MASSEY, BILL 01/28/2021
 SAN MATEO COUNTY DISTRICT ATTORNEY'S OFFICE Page 3
400 COUNTY CENTER, 3RD FLOOR REDWOOD CITY, CA 94063 650-363-4636
NARRATIVE - Opening Narrative 21-0120-01

which he provided to the SMDAO. The two legitimate subpoenas were a Comcast subpoena and a
subpoena for medical records. Both of which were legitimately obtained via the process previously
discussed.
Rappaport also stated that he and his client were concerned because Wang was not supposed to know
where their child was attending school and they did not know how she made that determination. They
therefore feared that Wang might be in the area, which possessed a safety concern based upon Wang’s
prior history and behavior.

I discussed the jurisdictional issues involving this case; primarily the fact that Suspect Wang appears to
reside in Utah. Rappaport stated that he did not have any contacts in Utah that he believed would take
this case seriously and he did not want the case to be investigated by San Francisco (jurisdiction with the
stalking criminal case and protective order) based upon his belief that the San Francisco District
Attorney’s Office would not prosecute the case in a manner that would result in any significant
repercussions for Wang.

During the interview, I told Rappaport that the San Mateo Co District Attorney’s Office did not possess
the capability to assure the safety of his client or the child. I further advised him to contact the Menlo
Park Police Department to discuss safety related issues. Rappaport stated he understood and did not
expect the SMCDAO to do anything other than investigate the alleged forgery allegation.

***END OF INTERVIEW***

1/27/2021:
On 1/27/2021, I compared the fictitious subpoena to the subpoena that was reportedly utilized to create
the fictious subpoena that was sent to the preschool. I observed the following:

Subpoena dated 6/4/2020 for Comcast records:

 The header and first page of this subpoena possessed the same information that was contained
on the reportedly fictitious subpoena.
 The second page of the subpoena was clearly different, wherein it requested records from
Comcast.
 The third pages of both subpoenas were identical. They both were dated 6/4/2020 and both
possessed an identical signature and court stamp/seal. The signature and stamp clearly appeared
to be the same document in both subpoenas.

Attorney Rappaport previously told me that the fictitious document was a combination of two prior
subpoenas / court orders. He said the second order was for medical records, was valid, and appeared to
be attached to the fictitious subpoena for the purpose of making the document look valid. I could not
find the order that was attached to the fictitious subpoena within the documents provided by Rappaport.

From further review of the documents provided by Attorney Rappaport, I observed that Suspect Kang
was prosecuted in Spanish Fork City, Utah for 50 counts of electronic communication harassment in

Prepared By: Date: Approved By: Date:

14860 BROAD, MATT 01/27/2021 80202 MASSEY, BILL 01/28/2021
 r.4ttorneys'Pees and Costs.
2
3 9. I have spent roughly eight hours to date in relation to this contempt proceeding,
including the initial spotting of the filings,meeting and conferring with Ms. Wang, obtaining
4
the filed items, conferring with co-counsel, andreviewing and editing this declaration and the
5
other contempt filings. Mr. Rappaport and attorneys working with him have spent roughly 18
6
hours to prepare the filing, including all of the forms, the affidavit of counts, and the legal
7
memo. We will spend further time to review Ms. Wang's rooponseto this OSC and prepare
8
reply papers; and thereafter Mr. Rap~port will appear at toe initial arraignment tlien the
9 substantive hearing. My hourly rate is $585 and Mr. Rappaport's is $750. We estimate total
IO fees to Mr. Thygesen of approximately $25,000. We will update the Comt as to the actual
11 time and fees involved as the case moved foiward.
12
13 I declare under penalty of perjury the laws of the State of Ca]j.fomiathat the foregoing
is true and correct and that this Declaration was executed on May_S_,2020.
14
15
16

17
18
19
20
21
22
23
24
25

26
27
28

Thyge.en & Wanl • No. FDV-19-B14465

4 Deel of DairickT. Chaacin Supportof OSC re Contempt

5
 1 DOUGLAS L. RAPPAPORT (SBN 136194)
Law Offices of Douglas L. Rappaport
2 260 California Street, Suite 1002
San Francisco, CA 94111
3 Telephone: 415-989-7900
Facsimile: 415-989-7950
4
Attorneys for Victim
5 CHRISTOFFER STANFORD THYGESEN

6
SUPERIOR COURT OF THE STATE OF CALIFORNIA
7
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
8

9 THE PEOPLE OF CALIFORNIA Case No. 19016407

10 Plaintiff VICTIM’S OBJECTION TO

DEFENDANT WANG’S REQUEST
11 v. FOR A CONTINUANCE OF THE
PRELIMINARY HEARING
12 KAILIN WANG,

13 Defendant Date: March 4, 2022

_____________________________________/ Dept: 20
14 Time: 9:00 A.M.

15
STATEMENT OF FACTS
16
It has been eight hundred and thirty-three days since Defendant Kailin Wang was first in
17
court on this case. She has now gone through three different counsel and has requested
18
approximately 22 continuances, including one prior continuance of a long cause preliminary hearing
19
that was set almost a year ago to the day.
20
Thereafter, on April 15, 2021, Ms. Wolf of the San Francisco Public Defender’s Office was
21
appointed to represent Defendant Wang. Since then, Ms Wolf has done an admirable job for her
22
client, filing a Motion to Release Subpoenaed Records on July 13, 2021 and a Motion to Compel
23
Discovery Compliance on August 4, 2021. Once these motions were resolved, on December 8, 2021
24
in Department 11, Defendant Wang requested that the case be sent to Department 20 to set the
25
preliminary hearing. On January 7, 2022 the preliminary hearing was scheduled for three full days
26
beginning on March 15, 2022.
27

28

1
 1 Now, two weeks before the scheduled start of the PX, Defendant Wang is again moving for

2 a continuance. This time, Defendant Wang has stated that two experts, Erik Rasmussen and Tim

3 Weaver, were recently disclosed to the defense on February 8, 2022 and that the defense requires

4 more time to retain their own expert. This appears to be inaccurate since on September 9,

5 2021–roughly five months ago-- Defendant Wang was Tweeting San Francisco District Attorney

6 Chesa Boudin, chiding his office for using expert Erik Rasmussen. Ms. Wang’s Tweet is attached

7 hereto as Exhibit “A.”

8 Nevertheless, the victim Christoffer Thygesen does not wish undermine Defendant Wang’s

9 ability to received a fair hearing. Consequently, although he objects to the continuance, he

10 understands that one may be granted. If this is the case, he respectfully requests that this Court

11 carefully voir dire Ms. Wolf to ascertain the reason for the request, how much additional time is

12 realistically needed to be fully prepared and to re-set the matter as quickly as practicably possible.

13

14 POINTS & AUTHORITIES

15 The victim, Mr. Christoffer Thygesen, has both a constitutional and statutory right to a

16 speedy trial and expeditious resolution of the case:

17 Cal. Const. Art. I, §28(b)(9) states, that "In order to preserve and protect a victim's rights to

18 justice and due process, a victim shall be entitled to. . .a speedy trial and a prompt and final

19 conclusion of the case and any related post-judgment proceedings." Cal. Const. Art. I, §28(b)(9),

20 emphasis added.

21 Similarly Cal. Penal Code §679.02 (a)(10) provides victims with the right "[t]o an

22 expeditious disposition of the criminal action."

23 Although there is no case law addressing the victim’s right to speedy resolution, as a general

24 matter, California’s Appellate Courts have stated that trial courts should afford Marsy's Law, a crime

25 victims' rights ballot initiative, a broad interpretation protective of victims' rights. People v .

26 Lombardo (App. 3 Dist. 2020) 269 Cal.Rptr.3d 62; Santos v. Brown (App. 3 Dist. 2015) 238

27

28

2
 EXHIBIT 2
Michelene Insalaco ($650/hr.) has been retained by Thygesen Continuously since June 2019.

Michelene Insalaco has appeared on behalf of Thygesen for 40+ hearings in FDV-19-814465

Michelene Insalaco is lead Appellate Attorney for Thygesen since June 2019-Present for 18 or
so Appeals/Writs
1nsaiaco earneo ner nacnernr s uegree rrom me umversny or Nncmgan ano ner J.u.
iv...-.

from the UC College of the Law, San Francisco. She has practiced exclusively in the area of
family law, at both the trial and appellate levels, for over 25 years. The California Board
of Legal Specialization certified Ms. Insalaco as a Family Law Specialist in 2003 and as
an Appellate Specialist in 2023. Ms. Insalaco is a Member or Fellow of many family law
and appellate organizations, including the Association of Certified Family Law Specialists
(ACFLS), the ACFLS Amicus Cormnittee, the Association of Family and Conciliation Courts
(AFCC), the International Academy of Family Lawyers, the Family Law and Appellate
(J1me2019 to Present) [4+
Sections of the Bar Association of San Francisco (BASF), the Contra Costa Bar Association,
Years] Insalaco has
and the Hague Convention Attorney Network. Her leadership roles include being the current
continously retained as Suchennan • Insalaco LLP
Michelene Vice Chair of BASF's Appellate Section, sitting on the Board of the California Chapter of the
CFLS/ Appellate Thygesen's Lead Appellate SOCalifornia Street, 34th
E. Insalaco $650/ Hr. AFCC and serving as Editor of its newsletter "Insights," and being a past Chair of BASF's
Specialist Attorney. From June 2019 Floor, San Francisco, CA
#161711 Family Law Section, a past Board Member of the ACFLS, and a past Member of the State
to April 2022 Insalaco was 94111
Bar's Family Law Executive Cormnittee (FlexCom). Ms. Insalaco was also formerly a
one ofThygesen's Family
Member ofBASF's Judiciary Cormnittee, which helps to select judges in California. Ms.
Law Attorneys in this case.
Insalaco volunteers as a settlement panelist for San Francisco and Marin counties courts; is a
member of the Minor's Counsel Panel in Contra Costa County, and has sat as a Judge Pro
Tern in San Francisco family court.
Ms. Insalaco's current focus is family law appeals. Her published cases include C.T. v.
K.W. (2021) 71 Cal.App.5th 679; Sabata v. Brooks (2015) 242 Cal.App.4th 715; In re
Marriage of Blazer (2009) 176 Cal. App. 4th 1438; Ragghanti v. Reyes (2004) 123
Cal.App.4th 989; and In re Marriage ofEdhmd & Hales (1998) 66 Cal.App.4th 1454. Ms.
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 Darrick T. Chase (SBN 151256)
Kaye • Moser • Hierbaum • Ford LLP
2 101 California Street, Suite 2300
3 San Francisco, CA 94111
Telephone: (415) 296-8868
4
Michelene Insalaco (SBN 161711)
5 SUCHERMAN • INSALACO LLP
101 Mission Street, Suite 1640
6
San Francisco, CA 94105
7 Telephone (415) 357-5050

8 Co-Counsel for Christoffer S. Thygesen

9

10 SUPERIOR COURT OF THE STATE OF CALIFORNIA

11 COUNTY OF SAN FRANCISCO

12

13 No. FDV-19-814465

14 In Re PETITIONER'S LONG CAUSE HEARING

BRIEF RE UCCJEA CUSTODY
15 Petitioner: Christoffer Stanford Thygesen JURISDICTION
16
and Date: June 25, 2019
17 Time: I :45 p.m.
Respondent: Kailin Wang Place: Dept. 404
18 The Honorable Richard C. Darwin
19

20 INTRODUCTION.

21

22 The parties are the parents of a very young child, Thygesen Wang, born in

23 November of 2018. There are two issues presented for hearing on June 25, 2019:

24
1) Is Respondent Kailin Wang's current challenge to the Court's March 6th findings on
25
UCCJEA custody jurisdiction procedurally proper? The findings were personally served to
26
Ms. Wang on March 18th, and hence her objections are not prop,er because she did not timely
27
seek a new trial or to reconsider, or appeal the decision, and it is now final and not subject to
28 collateral attack.

In re Thygesen & Wang- FDV-19-814465

Pet's Long Cause Hearing Brief re UCCJEA Custody Jwisdiction
 1

1 SUPERIOR COURT OF CALIFORNIA

2 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO

3 UNIFIED FAMILY LAW COURT

4 DEPARTMENT 404

5 ---oOo---

6 HONORABLE RICHARD C. DARWIN, JUDGE

7
8 CHRISTOFFER STANFORD THYGESEN, )
)
9 PETITIONER, )
)COURT NO. FDV-19-814465
10 vs. )
)
11 KAILIN WANG, )
RESPONDENT. )
12 ____________________________________ )

13 REPORTER'S TRANSCRIPT Of PROCEEDINGS

14 JUNE 25, 2019

15 APPEARANCES OF COUNSEL:
FOR PETITIONER:
16 KAYE, MOSER, HIERBAUM
BY: DARRICK TRACEY CHASE
17 101 California Street, Suite 2300
San Francisco, California 94111
18
RIDDER, COSTA & JOHNSTONE LLP
19 BY: ERICA JOHNSTONE
12 Geary Street, Suite 701
20 San Francisco, California 94108

21 SUCHERMAN & INSALACO LLP

BY: MICHELENE INSALACO
22 100 Spear Street
San Francisco, California 94105
23
FOR RESPONDENT:
24 LAW OFFICES OF SAMI MADDEN MASON
BY: SAMI MADDEN MASON
25 141 Bryce Canyon Road
San Rafael, California 94903
26
27 Reported By: Ann Delgado, CSR No. 11185

28

Ann Delgado, CSR No. 11185

-
 78

1 the parties are ordered to register. You have to do an intake

2 process with Rally to allow supervised visits to begin. I'm

3 going to have the petitioner for the moment -- given the

4 financial inequality -- petitioner will pay the fees for the

5 supervised visitation. They're not significant.

6 And at this point, the parties are going to have to go

7 back to 405 to set a trial; right? What is going to happen on

8 the trial date for the actual --

9 MS. INSALACO: We would like Your Honor to set the trial

10 date. We would like to proceed and get a trial date.

11 THE COURT: The trial date is going to be in 405. This

12 is going to be a long trial, just evidenced by how this

13 proceeding went. There is going to be a lot of testimony. My

14 guess is -- I can't -- if we were to do it in 404, we would

15 string you out over six-and-a-half days -- afternoons -- over

16 the course of three months and your trial would be in

17 November. I don't think anyone wants that.

18 MS. INSALACO: I submit that once we have the subpoenaed

19 documents it will be completely clear who posted the

20 threatening posts, and it will be quite simple because that's

21 the whole basis of --

22 MS. WANG: Plus impersonation posts made by

23 Christopher.

24 THE COURT: Okay. Look, I don't think I can try this

25 case. I don't think -- we have a separate trial department

26 solely for longer trials. This is going to be a longer trial.

27 So I can't do it in 404. I can't give you a trial date

28 anytime in the near future, and it will be a lots and lots of

Ann Delgado, CSR No. 11185

 79

1 afternoons. It just doesn't make sense. It'll be broken up

2 by days and days. I think you need to go back to 405.

3 MS. INSALACO: Can you give us a date to go back to 405?

4 THE COURT: We can go off the record.

5 (Discussion off the record.)

6 THE COURT: Back on the record.

7 MS. INSALACO: We would request there not be visits until

8 the DV hearing, because there are threats to kill the child.

9 And whether they are at Rally or not, the child is potentially

10 at risk until the court has heard the evidence and assessed,

11 perhaps, the psychological well-being of the respondent. It

12 could put the child at risk to have any visits even at

13 Rally.

14 THE COURT: That argument was made the last time we were

15 here. And I have ordered Rally supervised visitations in

16 other situations. I'm very confident that they are

17 well-equipped to make sure no harm will come to your son. So

18 I think you should feel confident. It's a hospital. There is

19 staff everywhere, and the whole visit is observed. So I am

20 confident that it is a safe environment for those visits.

21 Okay. Off the record.

22 (Proceedings concluded.)

23
24
25
26
27
28

Ann Delgado, CSR No. 11185

DocuSign Envelope ID: 491EF1E5-CCBB-4B02-83FB-17C5526DE180

FL-150
PETITIONER:CHRISTOFFER STANFORD THYGESEN CASE NUtllllER·

RESPONDENT:KAILIN WANG FDV-19-814465

OTHER PARTY/PARENT/CLAIMANT:

12. The following people live with me:

How the person is That pers,Jn's gross Pays some of the
Name Age related to me (ex. son) monthly income household expenses?
a.lilllll Thygesen Wang 3 Years Son 0.00 c::JYes @No
b. c::JYes D No
C. c::J Yes 0No
d. c::JYes LJNo
e. CJ Yes D No

13. Average monthly expenses D Estimated expenses [JO Actual expenses D Proposed needs
a. Home: h.Laundry and cleaning.... S ___ _
..
(1) [J[I Rent or CJ mortgage .. ,..... $ i. Clothes........... ................ $
If mortgage: j. Education.... ... ... . ... .. ... ... .. .. ... . .. .. ......... .....
---~
$ ___
50
_0
(a) average principal: $ __ _ k. Entenainment, !~ilts, and vacation .................. $ __ JOO
___
(bl average interest: l. Auto expenses and transportation
{2) Real property taxes ... $ (insurance, gas, repairs, bus, etc.) ................. $ ___ 150
_
0
( 3) Homeowner's or renter's insu ranee m. Insurance (life, ,~ccident, etc.: do not include
(ii not included above). $ 0 auto, home, or health insurance). ................. $ ___ _0
(4) Maintenance and repair ........................ .. s 0 n. Savings and in~·estments.. S ___ _0
b. Health-care costs not paid by insurance s 30 o. Charitable contributions... $ ---"" 50
$ p. Monthly payments listed in item 14
C. Child care" """"" """'"" ....... 1,617
(itemize below in 14 and inser1 total here). $ __ _919
d. Groceries and household supplies .. s • q. Other (specif)I): Visitation Fees. $ 301
e. Eating out.. ....................... .. s 200
r. TOTAL EJtPENSES (a-q) (do not add in
f. Utilities (gas, electric, water, trash) .. s *
the amounts in a(1)(a) and (b)J 5,417
g. Telephone, cell phone. and e-mail.. .... s .. s. Amount of expenses paid by others
$

$ **
•Rent includes these items. *'My l'arents sometimes buy clothes and toys.
14. lnstallmenl payments and debts not listed above
Paid to For Amount Balance Date of last payment
Allan and Terry Thygesen Personal loan for attorneys' fees. $ 12/3/2021
919 $369,113.11
$ $
$ $

$ $
$ $
$ $

15. Attorney fees {This information is required if either parly is requesling a/lomey fees)·
a. To date, I have paid my attorney this amount for fees and costs (speci'JI): $365,570.05: Total Feespaid to lawyers for custody/visitation
b. The source of this money was {specify): Savings, Sale of Stock, Personal Loan. issues.
C. I still owe the following fees and costs to my attorney (specify total owed): $ o.oo
through 1 0/3112021. l'os, 1013112021feesarc work in
progress

I co~fi rJ¥lihft~':!V~naijflrefffle is (specify): DouglasL llappaport$750; M ichelencI mlaco $650; DarrickChase$61 5

{
~
Date: December 10, 2021
MICHEL.ENE INSALACO ► /
(TYPE OR ~INT NAME)
L.. (SIGNATURE O• OEClARANTJ

Fl-',SO[Rev Jo.,..,yl, 20191 INCOME AND EXPENSE DECLARATION Page 3of 4

 Court of Appeal, First Appellate District Court of Appeal, First Appellate District
Charles D. Johnson, Clerk/Executive Officer Charles D. Johnson, Clerk/Executive Officer
Electronically RECEIVED on 9/22/2022 at 3:01:38 PM Electronically FILED on 9/22/2022 by C. Hoo, Deputy Clerk

Thygesen's
Attys (Has
Requested
Status/Dis Description of Appeals/Supreme Ct. Case, Chronologically Filing Wang's
for Oral
position Ordered by Disposition Date Date Attys
Argument
in every
Appeal

Michelene
6/29/2021 Case no. A158691 (Thygesen's Appeal of 07/18/19 UCCJEA
Insalaco/
1 (Reversed/ Order) Reversed/Remanded under FC 3406 on 06/29/21. 9/5/19 Pro Per p.1
Darrick T.
Remanded) Supreme Ct. Review Case no. S269846, denied on 10/13/21.
Chase

Case No. A163278_Wang v. Sup. Ct. Case (Writ of 07/29/21

9/12/2021 “Termination of All In-Person Visitation Order,” even Michelene
(Alternative Supervised Visitation) Alternative Writ issued on 09/12/21. Insalaco/
2 8/18/21 Pro Per p.7
Writ After remand a 5-Day Evidentiary Hearing was held on Janet
Issued) 10/22/22, 11/12/22, 11/18/22, 12/20/22, 01/05/22. Supervised Simmonds
Visitation Re-instated on 02/24/22, (Per 02/02/22 FOAH)

10/5/2021
(Statutory Michelene
Writ of
Case No. A163593_Wang v. Sup. Ct. Review of _Denied on Insalaco/
3 170.6 10/4/21 Pro Per p.10
10/05/21 (Writ of Denied CCP 170.6(a)(2)) Janet
Summarily Simmonds
Denied)

10/13/21 Case no. S269846_Supreme Ct. Review of Case no. A158691 No

4 7/14/21 Pro Per p.11
(UCCJEA) denied on 10/13/21. Appearance
Michelene
11/15/2021 Case No. A161993 _Appeal of 01/12/21 “Denial of Need-
Insalaco/
5 (Reversed/ Based Fees” (FC 7605) Pub. Op. Reversed/Remanded on 1/19/21 Pro Per p.12
Janet
Remanded) 11/15/21
Simmonds
 Case no. S271314_WANG v. S.C. (THYGESEN'S) Pet. for
Review of Case no. A163593 (CCP 170.6 Writ)_Denied on
12/15/21. Per 12/15/2021 Petition for review denied. Real party
in interest's request for judicial notice filed on November 3,
2021 is granted as to pages 1 through 850 and 855 through
864. The remainder of the request is denied.
Petitioner's request for judicial notice filed on November 8,
2021 is granted as to pages 1 through 224, 337 through 470,
483 through 486, 500 through 542, 546, 553 through 563, and Michelene
605through 610. The remainder of the request is denied. Insalaco/
6 12/15/21 Petitioner's request for judicial notice filed on November 16, 10/14/21 Pro Per p.17
Janet
2021 is granted as to pages 18through 28. The remainder of the Simmonds
request is denied.
Petitioner's request for judicial notice filed on November 18,
2021 is denied.
Petitioner's request for judicial notice filed on December 7,
2021 is denied.
The motion to strike the petition for review is denied.
The petition for review is denied.

Case # A164346_Wang v. Sup. Ct. (Writ of Second CCP

170.6 Denial)
The petition for writ of mandate, prohibition, supersedeas, or
other appropriate relief is denied. The Code of Civil Procedure
2/2/2022 section 170.6 peremptory challenges filed by petitioner on
Michelene
(CCP December 16, 2021 and January 3, 2022 in the trial court were Insalaco/
7 170.6 Writ premature because this court has not issued a remittitur in C.T. 1/13/22 Pro Per p.20
Janet
is v. K.W. (A161993). This court expresses no opinion whether a Simmonds
Premature) section 170.6 peremptory challenge filed after issuance of the
remittitur would be timely or otherwise proper.

Case Number S272404, Thygesen's Petition for Supreme Ct.

Review of A161993, 11/15/21 Published Opinion Reversed/
Remand of FC 7605 Need Based Atty. Fees. 02/09/2022
Petition for review denied. Case Number S272404 ruling on
Michelene
8 2/9/22 2/9/22: "The requests for judicial notice filed on December 30, 12/23/21 Pro Per p.23
Insalaco
2021, January 14, 2022, January 18, 2022, January 18, 2022,
January 28, 2022, and February 2, 2022 are denied. The
petition for review is denied."

Michelene
2/14/2022 Case No. A161992, on 02/14/22 Affirmed Appeal of Insalaco/
9 1/11/21 Pro Per p.25
(Affirmed) 01/05/21 Vex Lit (CCP 391(b)(1) Only) Order. Janet
Simmonds
 Oral (Consolidated) Case #'s A161991, # A163289 (8/6/21
Argument Order, Reduction of Video Parent-Time), # A163367
Michelene
Waiver sent (7/29/21 Order "Termination of all In-Person Visitation")
Insalaco/
10 on Filed 12/24/2020 by Wang appealing order from 11/03/2020, 2/16/21 Pro Per p.29
Janet
08/01/22 the "No Pictures of Child Order" from 08/27/20 Hearing
Simmonds
before Judge Wiley.

Case Number A165096,

05/03/2022 Notice of appeal lodged/received. Filed 04/01/2022
AOB due
by Respondent Kailin Wang in propria persona appealing Michelene
11 on 4/1/22 Pro Per p.43
judgments from 12/18/21, 02/02/2022, 02/11/2022, 02/15/2022 Insalaco
08/22/22
and 04/19/2022. Amended notice of appeal filed 04/21/2022
also attached.
A161993

In the Court of Appeal

of the State of California
First Appellate District, Division Four

=========================

KAILIN WANG
Appellant,
v.
CHRISTOFFER STANFORD THYGESEN
Respondent

=========================

Document received by the CA 1st District Court of Appeal.

Appeal from the Superior Court, County of San Francisco
Case N0. FDV-19-814465
The Honorable Monica F. Wiley Presiding

----------------------------------------------------------------

MOTION FOR SANCTIONS

---------------------------------------------------------------
Michelene Insalaco (SBN 161711)
Janet Simmonds (SBN 245506)
Sucherman • Insalaco LLP
101 Mission Street, Suite 1640
San Francisco CA 94105
(415) 357-5050
[email protected]
Counsel for Respondent
Christoffer Stanford Thygesen
 DECLARATION OF MICHELENE INSALACO

I, Michelene Insalaco, declare as follows:

1. I am an attorney licensed to practice law in California and am a
partner with Sucherman • Insalaco LLP, counsel for Respondent in the appeal
now pending before this Court. I have personal knowledge of the facts set
forth herein and in the foregoing Memorandum of Points and Authorities,
except as to those stated on information and belief and, as to those, I am
informed and believe them to be true. If called as a witness, I could and would
competently testify to the matters stated herein.
2. The chart below sets forth the individuals in my office who worked
on the Respondent’s Brief in this case and this motion, and time each
expended on various tasks. MI is lead appellate counsel Michelene Insalaco,

Document received by the CA 1st District Court of Appeal.

billed at $575 per hour; JS is partner Janet Simmonds billed at $500; YL is our
summer law clerk billed at $100; and TE is paralegal Tom Eberhart, billed at
$150.
3. The chart also includes the time and costs to obtain certified copies
of the pleadings in the chart in the foregoing Memorandum of Points and
Authorities, to the extent they were actually filed, from the superior court.
4. All information contained in that chart is true and correct.

Task MI JS YL TE Total

Review AA and compare to documents 4.6 $2,300

if office’s case file
Draft memo re authentication issues 1.0 $500
Review memo and formulate further 1.00 $575
action

8
 Research, complete form for certified 1.0 $150
copies, pull copies of pleadings, and
instructions to staff
Travel and wait time to order certified 6.8 $680
copies of pleadings (multiple trips
required due to issues at superior court)
Prepare first draft of fee motion and 4.00 $2,000
related facts and argument in
Respondent’s Brief
Review and edit motion and related 2.00 $1,150
sections of RB

TOTAL $7,355
Costs
Cost of Certified Copies $230

Document received by the CA 1st District Court of Appeal.

GRAND TOTAL $7,585

5. Attached at Exhibit A is a true and correct copy of First Amended

Information from the Fourth Judicial District Court in Utah County, State of
Utah, dated July 22, 2021.
6. Attached at Exhibit B is a true and correct copy of Ruling and Order
Denying Petitioner’s Motion to Disqualify the Assigned Judge from the Fourth
Judicial District Court in Utah County, Provo Department State of Utah, dated
July 13, 2021.

//

9
 I declare, under penalty of perjury under the laws of the State of
California that the foregoing is true and correct, and that this declaration is
executed in Orinda, California.

Dated: July 28, 2021 M. Insalaco

Michelene Insalaco
Sucherman • Insalaco LLP
Counsel for Respondent
Christoffer Stanford Thygesen

Document received by the CA 1st District Court of Appeal.

 EXHIBIT 3
Erica T. Johnstone ($500/hr.) has been retained by Thygesen Continuously since
February 2019.

Erica T. Johnstone has appeared on behalf of Thygesen for countless hearings in FDV-
19-814465, and in People v. Wang 19016407 she works 24/7 with a team of Private
Investigators who Monitors my Social Media Activity 24 Hours a Day 7 Days a week.
For Example Erica Johnstone works with 221 Partners a PI company out of Chicago, as
declared to by Exhibit A of Thygesen’s Updated Declaration filed on 11/20/23 which shows
his Investigators from 221 Partners Monitoring Social Media Activity of Reporters Thygesen
believes are associated with Wang from 7:05 p.m. throughout the night capturing posts at 11:05
p.m., and then again at 2:26 a.m. Thygesen claims he is unemployed yet has ability to pay for
Private Investigators to Monitor Wang and Reports and Court Watchers believed to be related
to Wang 24 hours a day, 7 days a week for 5 years, since December 2018.

nca o one 1sa partner at , osta one L , a onua aw mu

focusing on inteUcctual property, internet, and privacy law. Erica spedalius in representing
people who have been harmed through the use of ttthnology. She litigates online issues
regarding the noucousensual distribution of sexually explicit images, harassment, the
right to privacy, identity theft, impersonation, and defamation. Erica educates the public
and lawmakers on these issues, and is on the cutting edge in using the legal systan to identify
and confront this new class of harms. She also served as part of then California Attomcy
General Kam.alaHarris's Task Force Against Cyber Exploitation. She is the Co-Founc:lerof
Without My Consent, a 50l(c)(3) nonprofit that develops educational materials to empower
victims of digital abuse to seek justice across the United States.
EricaT.
February 2019 to Present Ridder, Costa & Johnstone
Johnstone $550/hr. Internet Attorney Erica is licensed to practice law in states of New York and California. Before fmu1ding
(4+Yca.-s) LLP
#242067 Ridder, Costa & Johnstone LLP, Erica was a litigation associate at Hinshaw & Culbertson,
and has also worked for an independent film producer in Los Angeles, California, and
covered local music for MfV. Erica graduated with honors from the University of North
Carolina School of Law and also attended Duke University, where she received an
undergraduate degree in Public Policy Studies.

Erica writes as a social media columnist for California Lawyer magazine. She has been
interviewed for publications such as The New York Times Magazine, The Wall Street
Journal, the Ncw York Observer, USA TODAY, the San Francisco Chronicle, Fusion, and
Marie daire magazine. Erica is a frequent speaker on digital abuse. She has spoken at
C i https://rcjlawgroup.com/erica-johnstone/ © c!J * J_~ • □

Erica Johnstone
[email protected]
(650) 466-6267

Erica Johnstone is a partner at Ridder, Costa & Johnstone LLP, a California law firm focusing on
intellectual property, internet, and privacy law. Erica specializes in representing people who have
been harmed through the use of technology. She litigates online issues regarding the
nonconsensual distribution of sexually explicit images, harassment, the right to privacy, identity
theft, impersonation, and defamation. Erica educates the public and lawmakers on these issues,
and is on the cutting edge in using the legal system to identify and confront this new class of
harms. She also served as part of then California Attorney General Kamala Harris's Task Force
Against Cyber Exploitation. She is the Co-Founder of Without My Consent, a 501 (c)(3) nonprofit
that develops educational materials to empower victims of digital abuse to seek justice across
the United States.

Erica is licensed to practice law in states of New York and California. Before founding Ridder,
Costa & Johnstone LLP, Erica was a litigation associate at Hinshaw & Culbertson, and has also
worked for an independent film producer in Los Angeles, California, and covered local music for
MTV. Erica graduated with honors from the University of North Carolina School of Law and also
attended Duke University, where she received an undergraduate degree in Public Policy
Studies.

Erica writes as a social media columnist for California Lawyer magazine. She has been
interviewed for publications such as The New York Times Magazine, The Wall Street Journal,
the New York Observer, USA TODAY, the San Francisco Chronicle, Fusion, and Marie Claire
magazine. Erica is a frequent speaker on digital abuse. She has spoken at Stanford Law School,
the National Constitution Center, the National Network to End Domestic Violence Tech Summit,
and the LAPD's Deaton Auditorium.
 1 MICHAEL REEDY (161002)
McMANIS FAULKNER
2 a Professional Corporation
ELECTRONICALLY
50 West San Fernando Street, 10th Floor
3 San Jose, California 95113 FILED
Telephone: (408) 279-8700 Superior Court of California,
County of San Francisco
4 Facsimile: (408) 279-3244
Email: [email protected] 11/18/2022
5 Clerk of the Court
BY: ANNIE TOY
DOUGLAS RAPPAPORT (136194) Deputy Clerk
6 LAW OFFICES OF DOUGLAS L. RAPPAPORT
260 California Street, Suite 1002
7 San Francisco, CA 94111
Telephone: (415) 989-7900
8 Facsimile: (415) 989-7950
Email: [email protected]
9
Attorneys for Petitioner,
10 CHRISTOFFER THYGESEN
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
FOR THE COUNTY OF SAN FRANCISCO
13

14 UNIFIED FAMILY COURT

15
In re Matter of: Case No.: FDV-19-814465
16
CHRISTOFFER THYGESEN, DECLARATION OF ERICA T.
17 JOHNSTONE IN SUPPORT OF
Petitioner, PETITIONER’S REQUEST FOR
18 PREVAILING PARTY FEES
and
19 Date: December 20, 2022
KAILIN WANG, Time: 1:45 p.m.
20 Dept.: 404
Respondent. Judge: The Hon. Daniel Flores
21

22

23

24 I, Erica T. Johnstone do hereby declare:

25 1. I am submitting this declaration in support of Petitioner’s request for prevailing party
26 fees.
27
28
1
In re Matter of Thygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF ERICA T. JOHNSTONE IN
SUPPORT OF PETITIONER'S REQUEST FOR PREVAILING PARTY FEES
 1 2. I am an attorney admitted to practice law in the State of California and before this Court.
2 I have been continuously licensed since 2006. I am a partner at Ridder, Costa &
3 Johnstone LLP, a law firm focusing on intellectual property, internet, and privacy law. I
4 have been working with Petitioner since February, 2019. My work on this case includes
5 ongoing investigation of online and internet activities by Respondent as it relates to her
6 campaign of harassment and stalking of Petitioner and his family. I appeared before the
7 Court as co-counsel of record at the October 18-20, 2022 trial on Petitioner’s Request for
8 a Domestic Violence Restraining Order (“DVRO”).
9 3. I am familiar with the work performed to date relating to Petitioner’s DVRO request, and
10 I have reviewed my firm’s billing statements in this case.
11 4. My hourly rate in this case is $500. I am familiar with the hourly rates of similarly-
12 experienced professionals in the Bay Area and the foregoing is commensurate with their
13 rates.
14 5. The work involved here has been complex, especially given the thousands of pages
15 Respondent has filed in this case to date that directly relate to the DVRO request, which
16 has been pending since February 2019. Moreover, there could be no more important
17 issues than the safety of Petitioner and his family.
18 6. The following are summaries of the work I and/or my office completed to date which
19 directly relate to the ultimate issuance of the DVRO on October 21, 2022.
20 • Design and implement the legal strategy for evidence capture and preservation
21 with an eye toward courtroom admissibility in a case that involves harassment,
22 stalking, identity theft, impersonation, fabricated evidence, false filings, and
23 “abuse” as that term is defined in the Domestic Violence Prevention Act of a
24 degree that is “almost unprecedented.” (10/20/2022 Ruling RT:3-7)
25 • Design and implement the legal strategy for capturing data through subpoenas
26 that would unmask through business records the anonymous personas perpetrating
27 the harassment, stalking, and abuse.
28 • Oppose Respondent’s motion to quash the subpoeanas that would forensically tie
2
In re Matter of Thygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF ERICA T. JOHNSTONE IN
SUPPORT OF PETITIONER'S REQUEST FOR PREVAILING PARTY FEES
 FDV-19-814465
CHRISTOFFER STANFORD THYGESEN VS. KAILIN WANG

MINI MINUTES FOR MAR-06-2019 08:30 AM FO

(404) 3/6/2019
Judge: Richard Darwin Clerk: Sadie Li
Reporter: Vicki Gross #5525 Bailiff: Deputy Anasse

Petitioner present with Darrick Chase and Erica Jahnstone. Respondent not served and not present. Petitioner's oral motion to
substitute service via email or via Respondent's parents' home address - DENIED. Personal service is required for restraining
order requests.
Petitioner's request to continue hearing and modify temporary restraining order - granted. Petitioner granted temporary sole
legal and physical custody of minor child, Thygesen Wang (DOB 11/26/18). The mother shall receive no visitations till
further orders of the Court.
Court signed Amended DV-110 Temporary Restraining Order and DV-116 Order on Request to Continue Hearing. File endorsed
copies provided to counsel.
Matter continued to 4/10/19 at 8:30am in Dept. 404 for Domestic Violence Restraining Order Hearing. Court finds good cause to
continue matter beyond 21 days.
DocuSign Envelope ID: F39B7326-C697-4996-A378-AB60F267168D

DOUGLAS RAPPAPORT (136194)

LAW OFFICES OF DOUGLAS L. RAPPAPORT
260 California Street, Suite 1002 ELECTRONICALLY
San Francisco, CA 94111 FILED
Superior Court of California,
Telephone: (415) 989-7900 County of San Francisco

Facsimile: (415) 989-7950 11/20/2023

Email: [email protected] Clerk of the Court
BY: JOSHUA MANDAPAT
Deputy Clerk

Attorney for Petitioner,

CHRISTOFFER THYGESEN

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SAN FRANCISCO

In re the Matter of: Case No.: FDV-19-814465

CHRISTOFFER THYGESEN UPDATE TO PETITIONER’S 11/13/23

DECLARATION (ID# 71391418) IN
Petitioner, OPPOSITION TO RESPONDENT’S
REQUEST TO INCREASE VISITATION
And AND REMOVE SUPERVISION

KAILIN WANG, Date: November 28, 2023

Time: 9:00 a.m.
Respondent. Dept.: 403
Judge: The Hon. Russell Roeca

I, Christoffer Thygesen, am the Petitioner in this case and the father of the Minor Child
(“MC”). This update to my November 13 responsive pleadings (ID# 71391418) is to inform the
Court of new unsafe conduct by Respondent Wang that has occurred since I filed my November
13 responsive pleadings. All dates are 2023 unless otherwise stated. Under penalty of perjury
under the laws of the State of California, I declare the following:
1
___________________________________________________________________________
In re the Matter of Thygesen v. Wang, Case No.: FDV-19-814465; UPDATE TO PETITIONER’S
11/13/23 DECLARATION (ID# 71391418) IN OPPOSITION TO RESPONDENT’S REQUEST
TO INCREASE VISITATION AND REMOVE SUPERVISION
DocuSign Envelope ID: F39B7326-C697-4996-A378-AB60F267168D

1. Since Ms. Wang was ordered on February 15 not to post MC’s identifying information
online, she continues to violate this Order repeatedly. Most recently, shortly after I served her
through File&ServeXpress with my opposition papers on November 13, Ms. Wang retaliated
against me by committing an even more egregious violation of the Court’s February 15th Order
and creating yet further risk to MC’s safety: She disseminated not only the name of the visitation
facility, but also the address as well as information about the visitation schedule to a third party,
who in turn posted it on X (Twitter). Ms. Wang is the only person who could have provided the
third party with this information. Ms. Wang then tweeted a hateful, untrue comment about me,
further amplifying the disclosure of the visitation information, and demonstrating her conduct
was by design, with reckless disregard for MC’s safety. (See Exhibit A.) The foregoing tweets
disclosing MC’s in-person visitation information have already been viewed over 700 times so
far.1

2. In another fit of rage today, November 20, at 12:39 p.m., Ms. Wang yet again tweeted
screenshots revealing six times the identity of the in-person visitation supervision facility, also
disclosing again schedule information, along with allegations that my family is “racist, hateful,
spiteful despicable.” (See Exhibit B.)

3. Ms. Wang’s conduct has further increased the already unacceptably high risk of stochastic
violence, which is at issue in the upcoming February 27 evidentiary hearing. For this reason, I
respectfully request that this Court take swift action to safeguard MC — prior to the next
in-person visitation on December 3.

r DocuSigned by:

DATE: November 20, 2023 ____________________________

L~42D~

Christoffer Thygesen, Petitioner

1
Ms. Wang then further increased the risk to MC by making false allegations that he is being abused and
having his toys taken away from him. These are wholly false allegations. The toys have not been
donated, given away, or thrown away; they have always been and remain in MC’s possession and control.
2
___________________________________________________________________________
In re the Matter of Thygesen v. Wang, Case No.: FDV-19-814465; UPDATE TO PETITIONER’S
11/13/23 DECLARATION (ID# 71391418) IN OPPOSITION TO RESPONDENT’S REQUEST
TO INCREASE VISITATION AND REMOVE SUPERVISION
DocuSign Envelope ID: F39B7326-C697-4996-A378-AB60F267168D

Retaliation and Escalation by Tweeting the Minor’s Rally Schedule Information

1. 11/13/23 at 7:05 p.m.

D 71391418 11/13/2023 7:05 File And FDV-19-814465 Christoffer D Memorandum of Points and Authorities 2023-11-13CTMPA in Opp to RFO1 Visitation
PM PST Sen,e Thygesen, Christoffer Stanford [view]
Stanford vs Kailin Wang Thygesen,
Vexatious litigant (SRl}-Thygesen, D ResponsiveDeclarationto Requestfor 2023-11-13CTFL320Deelin Opp to RFOl Visitation
Christoffer Order (~]

2. 11/13/23 at 11:07 p.m. 3. 11/14/23 at 2:26 a.m.

Post court.
Readyto play 20 case questions?
Cameras in Courtrooms!
@SusanBassi
•@ii..1/- 1. In California if you are not married, and end
up in family court the case is confidential?
2. Did you know Christopher Thygesen is the
son of the fomer CEOof @Google, now
Let's talk spoiled little rich kids and family court.
@DocuSign?/1
Ready to play 20 case questions?
RIHy schedulti lnformaUon
1. In California if you are not married, and end up
:::=;:.:.,TE77
in family court the case is confidential? _..,_~
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Daddy Allan Thygesen Aldo got Christoffer

Thygesen a job at Google that magically
disappeared as soon as he was ordered to pay
11:07PM· 11/13/23 from Earth· 687 Views
need-based attorney fees
5 Reposts 1 Quote 7 Likes
2:26AM • 11/14/23 from Earth• 81 Views
,..., n
Post your reply Post your reply

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DocuSign Envelope ID: F39B7326-C697-4996-A378-AB60F267168D

Document title: Kailin Wang = on X: "@SusanBassi @Google @DocuSign Daddy Allan

Thygesen Aldo got Christoffer Thygesen a job at Google that magically disappeared
as soon as he was ordered to pay need-based attorney fees" / X

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PDF REFERENCE #: oqThbHKnHBfum29HtX8w8G

 1

1 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

2 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
3 UNIFIED FAMILY LAW COURT
4 DEPARTMENT 404
5 ---oOo---
6 HONORABLE RICHARD C. DARWIN, JUDGE
7 ________________________________
8 IN RE THE MATTER OF )
)
9 CHRISTOFFER STANFORD )
THYGESEN, )
10 PETITIONER, ) CASE NO. FDV-19-814465
)
11 VS. )
)
12 KAILIN WANG, )
RESPONDENT. )
13
14
---oOo---
15
REPORTER'S TRANSCRIPT
16 OF
PROCEEDINGS
17
WEDNESDAY, MARCH 6, 2019
18
---oOo---
19 A P P E A R A N C E S:
FOR THE PETITIONER: KAYE•MOSER•HIERBAUM•FORD LLP
20 BY: DARRICK T. CHASE
101 California Street, Suite 2300
21 San Francisco, CA, 94111
22 RIDDER, COSTA & JOHNSTONE
BY: ERICA T. JOHNSTONE
23 12 Geary St., Suite 70
San Francisco, CA, 94108
24
25

26
27
28 REPORTED BY: VICKI GROSS, CSR
CERTIFICATE NO. 5525
 22

1 MR. CHASE: They have all received harassing communications,

2 yes.
3 Let me double-check one thing.
4 (Discussion off the record)
5 THE COURT: I am going to -- part of the DV-140, which is
6 the child custody and visitation order, says no visits for mom,
7 and then there is a separate supervised visits for mom.
8 MR. CHASE: We prefer no visits. We just, I wanted to make
9 sure that I covered everything on the forms.
10 THE COURT: I am going to cross out supervised visitation
11 because I think that's jumping the gun.
12 Now I am going to take off the extra section on these
13 findings because this is being done on an ex parte basis. So I
14 am not making any findings at this point other than he's
15 established, and the Court already did that, found that there was
16 domestic abuse sufficient to issue a temporary restraining order.
17 I don't want to make it that we've done anything beyond that. I
18 haven't made any findings. There's been no evidence, there has
19 not been an evidentiary proceeding, so I don't want to imply that
20 there has.
21 So it doesn't change what the relief I'm giving you. I just
22 want to make sure it's clear that I am not making those findings.
23 MR. CHASE: Yes.
24 THE COURT: And I will sign it.
25 MR. CHASE: And is the effecting order on there as well?
26 The granting of the orders, are these granted other orders part
27 of this order?
28 THE COURT: All I am taking off are the findings that you
3/22/22 1705 Received email from Erica Johnstone stating that she believes that Wang has
placed the child in danger and asked me to contact her for advice on how to
proceed. I responded to the email inQuiring why the child is in danger.
3/23/22 1035 I received an email from Erica Johnstone advising that Wang has publicly
posted the supervised visitation information for the child online. She stated that
the visitation information was previously confidential, and not public.
Johnston writes that the concern is that Wang is "inciting hatred toward
Thygesen and his family as well as encouraging others to believe that her child
was stolen and needs rescuing.·

I responded to Johnstone's email suggesting that they file a police report with
San Mateo PD, and that they may want to advise Rally that the schedule was
made public in case they need to take additional steps.

Emails and exhibits retained in case file.

SFF'D 298 (10176)•

004160

SAN FRANCISCO POLICE DEPARTMENT

CHRONOLOGICAL REPORT OF INVESTIGATION Page 35 of36
DATE TIME I ACTIVITY

417/22 0900 Received email from Doug Rappaport regarding the escalating behavior of
Wano.
RIDDER, COSTA & JOHNSTONE LLP
attorneys at law
12 Geary Street, Suite 701
San Francisco, CA 94108 Erica T. Johnstone, Esq.
Tel: (415) 391-3311 [email protected]
Fax: (415) 358-4975

May 5, 2019

VIA EMAIL ([email protected])

Karl Kronenberger
Kronenberger Rosenfeld, LLP
150 Post Street
San Francisco, CA 94108

Re: Thygesen v. Wang, No. FDV-19-814465 - Meet and Confer re:

Petitioner’s Subpoenas to Google, Charter & Comcast

Dear Karl,

Welcome. I look forward to working with you on this matter.

As a general reply to your letter, we stand by the proposed discovery order that
the court adopted, and the subsequent subpoenas issued, as thoughtfully tailored to
comply with the Stored Communications Act, 18 U.S.C. 2701, 2702 et seq. (“SCA”) and
the facts of this case.

Your characterization of Ms. Wang’s conduct as “posting comments about [my]

client’s prior desire to abort the baby,” suggests that you may not know all the facts of
this case. Any description I could offer here would fall far short of the ice cold terror and
devastation she has caused the Thygesen family by taunting them, anonymously, using
fictitious aliases, that Baby K was sick, had jaundice, was starving, was on welfare, and
that maybe they’d see him in the hospital; posting “baby pics” of a dismembered, 20+
week old aborted fetus; and making chilling statements that she already had been forced
to kill her baby and/or was going to kill the baby and herself –– all the while, in hiding,
evading service, and in some cases acting in clear violation of in-force restraining orders.

Your letter mischaracterizes this matter as a civil defamation/anonymous speech

case. This is a family court matter governed by California’s Domestic Violence
Prevention Act. The Domestic Violence Prevention Act (Family Code § 6200 et seq.)
(“DVPA”) empowers this Court to make findings and issue orders to prevent acts of
“abuse.”

Abuse is defined at Family Code § 6203(a) as any of the following: (1) To

intentionally or recklessly cause or attempt to cause bodily injury. (2) Sexual assault. (3)
To place a person in reasonable apprehension of imminent serious bodily injury to that
RIDDER, COSTA & JOHNSTONE LLP Karl Kronenberger
attorneys at law May 5, 2019
Page 5

Given the totality of the circumstances, on April 10, Judge Darwin, who has been
presiding over this matter since issuing the March 6, 2019 Amended DVTRO, found
good cause for Petitioner to serve third-party discovery on online service providers and
internet service providers, to obtain additional evidence concerning the identity and
location of the persons responsible for the communications and content posted online
related to this dispute. The Court found that this discovery was directly relevant and
essential to the fair resolution of this matter, and that the Petitioner’s interest in obtaining
this information via a subpoena outweighed the privacy interests of the anonymous party
who has posted such content.

D. Information About My Client

Finally, we want you to know that the statements that Christoffer

threatened/pressured her about an abortion, and how she became pregnant (i.e, that
Christoffer refused to wear a condom) are manifestly untrue. Among other things, (1)
Baby K is a now six-month-old baby; he was not aborted; (2) Christoffer never attempted
to force or coerce Ms. Wang into an abortion. With regard to Christoffer, Ms. Wang has
always been in control of her body, her decision, and whether or not she chose to
communicate her plans with him. He has only ever met Ms. Wang in person twice: they
met in person for the first time on the evening of Wednesday 2/28/2018 at The Snug in
San Francisco. On their first date, Ms. Wang made a point of telling Christoffer that she
normally dated older men who take her to expensive restaurants and hotels. On what was
to be their second and last date, on Sunday 3/1/2018, he took her to dinner at Bar Crudo.
(3) On those two occasions, they were intimate later in the evenings. Christoffer did not
refuse to wear a condom. She never asked him for a condom, so he assumed she was on
birth control pills and they ended up having unprotected intercourse. These two nights
together were the only times he has ever seen her in person outside of court. Their entire
text history is included in his 2/15/2019 DVTRO as Exhibit V. (4) Neither Christoffer nor
his family are racist in any way. (5) Our client has been pleading for the opportunity to
care for and provide for his son since he found out he was the father. In the same week
that Mr. Thygesen learned he was the father (February 11, 2019), he moved for full
custody and a protective order. He is fully prepared to take responsibility for his son, and
his entire family has been working tirelessly to ensure that the baby is safe, provided for,
and adored. Although we were able to rescue the baby in time (after your client said she
planned to kill the baby), your client’s fabricated evidence has made this much more
difficult.

E. Meet and Confer

With regard to the subpoenas:

• We are enclosing all responses and objections in Thygesen v. Wang, No. FDV-19-
814465 (Google [objection; scheduling meet and confer], Comcast [no response
yet], Stealth [response provided], CenturyLink [no response], TheDirty [response
provided]). In other proceedings, for example, in the LA paternity suit,
Medium.com provided subpoena responses. And in the now dismissed New York

5
 
  
  
  

  
  

  

  
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

  

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



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




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



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
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
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

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










 
  
  

  
  
  





- 

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- -
 



  


  
  










 
  
  

  


  
  

  

  


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  


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
 
  
  
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  
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
 EXHIBIT 4
Darrick T. Chase ($615/hr.) has been retained by Thygesen Continuously since
December 2018 continuously until January 23, 2023 when he committed suicide on the eve of
our Custody/Visitation hearing.
Darrick T. Chase has appeared on behalf of Thygesen for 50+ hearings for FDV-19-
814465, and has appeared for Thygesen in People v. Wang 19016407.
Mr. Chase’s practice includes extensive experience in high conflict custody and visitation
matters, including extensive experience with relocation issues. He was able to obtain an Ex
Parte custody order on March 6, 2019 to take Wang's 3.5 months old Baby and handed him to
Google Thygesens' now funded by DocuSign CEO Thygesen. Chase then colluded with now
sex offender Utah DCFS prosecutor Gary Lee Bell to obtain a warrant to put Baby K w/
Thygesen family to live in California, Thygesen never met the child before he obtained custody
ex parte, the plan and scheme of Darrick Chase, Thygesens $615/hr. agent.

••---•---' <>111 ,_,_ ·-• thf> o.•-••-••- ··-··-······-·· ·-· thf> "'-••-••-• ••-•••-••" '" •••

"Darrick T. Chase, Of Counsel" "Mr. Chase's practice includes an aspects of the trial and
settlement of complex marital dissolutions, including business valuation matters and other
complex asset matters, contests of pre-marital, cohabitation and separation agreements, pre-
judgment and post-judgment spousal support matters," "and high conflict rnstody and"
"visitation matters, including extensive expe1ienre with relocation issues"". Mr. Chase
has extensive estate planning experience, and experience in resolving post-death estate and
KAYE • MOSER• trnst disputes. Mr. Chase also cowisels clients going through mediation, including assisting
IDERBAUM • FORD LLP clients in acquiring appropriate communication and negotiation skiUs. Mr. Chase has
Family Law Attorney December 2018 to January
Darrick T. (Specialist in Child 2023 (Committed Suicide) 235 Montgomery Street, extensive experience litigating highly contested property division cases, support disputes, and
4 $615/hr.
Chase #151256 27th Floor custody conflicts." "Mr. Chase has seived as a Pro Tern Settlement Conference Judge for the
Relocation) (4+ Years)
San Francisco, California San Francisco Superior Court. Mr. Chase has extensive negotiation and hearing experience as
94104 a San Francisco Unified Family Court appointed Minors Cowisel on behalf of minor children
going through high conflict custody and visitation disputes. Mr. Chase also serves as a Mentor
at the request of the San Francisco Unified Family Court assisting attorneys seeking to qualify
as Minors Cowisel." "Mr. Chase practiced family law with the firm Sucherman and Collins
from 1991 tlu-ough 1994 and with the Law Offices of Darrick T. Qiase from 1994 through
2008. Mr. Chase is also seiving an elected four year tenn as a Director and the cnrrent
President of the Bel Marin Keys Co1mnunity Services District in Marin Cowity, California"
C o A Not Secure I http://www.kayemoser.com/darrick-t-chase/
Emphasizing Family Law,E:sfate Plamung, Tn1sts & Estates

Home People • Presentations and Publications .- Media News Contact

Awards
Darrick T. Chase, Of Counsel
Selected a Northern California Super Lawyer in
Mr. Chase's practice includes all aspects of the trial and settlement of complex 2012, 2014, 2015, and 2016-2020.
marital dissolutions, including business valuation matters and other complex asset
matters, contests of pre-marital, cohabitation and separation agreements, pre- RAT[OOV

judgment and post-judgment spousal support matters, and high conflict custody and SuperLawyers
visitation matters, including extensive experience with relocation issues. Mr. Chase
has extensive estate planning experience, and experience in resolving post--death Darrick T. Chase
estate and trust disputes. Mr. Chase also counsels clients going through mediation,
including assisting clients in acquiring appropriate communication and negotiation SELECTED IN 2020
THOMSON REUTERS
skills. Mr. Chase has extensive experience litigating highly contested property
division cases, support disputes, and custody conflicts.
RATE"01BY

Mr. Chase has served as a Pro Tern Settlement Conference Judge for the San
Francisco Superior Court. Mr. Chase has extensive negotiation and hearing
experience as a San Francisco Unified Family Court appointed Minors Counsel on
behalf of minor children going through high conflict custody and visitation disputes.
Mr. Chase also serves as a Mentor at the request of the San Francisco Unified 5 YEARS
Family Court assisting attorneys seeking to qualify as Minors Counsel.

Dam'ckwas also selected to 20 75 list of the

Mr. Chase practiicedfamily law ·with the firm Sucherman and Collins from 1991
NationalAssociation of DistinguishedCounsel.
through 1994 and with the Law Offices of Darrick T. Chase from 1994 through 2008.
Mr. Chase is also serving an elected four year term as a Director and the current
President of the Bel Marin Keys Community Services District in Marin Countyt Education
California.
• University of San Francisco School of Law

~ Send emailI (J.D., 1990)

• University of CaUfornia, Berkeley (B.A.,

Rhetoric, 1987)
9/18/23, 6:44 PM Fehring replaces Darrick Chase, who died on Jan. 21. The death was a suicide, according to the coroner's division of the Marin County Sheriff's .…

Google Fehring replaces Darrick Chase, who died on Ja ...

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Fehring replaces Darrick Chase, who died on Jan. 21. The death was a
suicide, according to the coroner's division of the Marin County Sheriff's
Office. Chase, 58, had served the board since 2007 and was an attorney
at a San Francisco law firm. Mar 30, 2023

Marin Independent Journal

mij https://www.marinij.com › 2023/03/30 › bel-marin-key...

Bel Marin Keys board appoints new member

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Patch
p https://patch.com › california › petaluma › actor-robi...

Actor Robin Williams Found Dead in Marin Home ...

Aug 11, 2014 — Actor Robin Williams was found dead in his Marin County home Monday
morning, according to the county coroner's bureau.
Missing: Fehring ‎replaces ‎Darrick ‎Jan. ‎21.

Pepperseeds.eu
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Untitled
... death, Humboldthafen ovg, Norad santa arcade, Buchstaben zum ausdrucken und ... county
sheriff inmate, Kumba realty orlando, Esame patente b teoria ...

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Bloomfield man's death during arrest by Sonoma County ...

May 15, 2020 — Bloomfield man's death during arrest by Sonoma County deputies ruled a
homicide. David Ward, 52, died after a November struggle as sheriff's ...
Missing: Fehring ‎replaces ‎Darrick ‎suicide,

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Coroner: David Pelaez-Chavez shot in head and chest by ...
Mar 14, 2023 — David Pelaez-Chavez was killed by gunshots to the head and chest and was on
methamphetamine at the time of his death, according to a report ...
Missing: Fehring ‎replaces ‎Darrick ‎21. ‎suicide,

https://www.google.com/search?q=Fehring+replaces+Darrick+Chase%2C+who+died+on+Jan.+21.+The+death+was+a+suicide%2C+according+to+the+coroner%27… 1/2
1 DARRJCK T. CHASE, ESQ. (CSB #151256)
KA YE•MOSER•HIERBAUM •FORD LLP
2 The Russ Building
235 Montgomery Street, 27 th Floor
3 San Francisco, CA 94104
Telephone: (415) 296-8868
4 Facsimile: (415) 495-1771
Email: [email protected]
5
Attorneys for Petitioner
6 CHRISTOFFER STANFORD THYGESEN

7
8
9 IN THE SUPERJOR COURT OF THE STATE OF CALIFORNIA

10 IN AND FOR THE COUNTY OF SAN FRANCISCO

11
CHRISTOFFER STANFORD THYGESEN ) CaseNo.FDV-19-814465
12 )
Petitioner, ) DECLARATION OF DARRICK T.
13 ) CHASE REGARDING PETITIONER'S
v. ) LONG CAUSE HEARING RE
14 ) UCCJEA JURISDICTION
)
15 KAILIN WANG )
) Date: June 25, 2019
16 Respondent. ) Time: I :45 p.m.
) Dept: 404
17 ) The Honorable Richard C. Darwin
)
18
19 I, DARRICK T. CHASE, declare as follows:

20 I. I am an attorney licensed to practice law in the State of California. I was admitted to the

21 California State Bar in December I 990.

22 2. I am representing Mr. Thygesen in this matter, and have been since on or about December 13,

23 2019.'<lf::(---~ Typo suppose to be "2018"

24 3. Attached hereto as Exhibit A is a true and correct copy of the birth certificate for -

25 Thygesen Wang. The birth certificate declares that Kailin Wang's Resident City is Los Angeles,

26 and Resident State is California. The Registration date on the Birth Certificate is December 4,

27 2018.

28 4. Attached hereto as Exhibit Bis a true and correct copy of the Summons and Complaint or

I.
 Statement of Christoffer Thygesen

NOTICE: Pursuant to Utah Code Ann. 76-8-504.5, you are notified that statements you are about to
make may be presented to a magistrate or judge in lieu of your sworn testimony at a preliminary
examination. Any false statement you make and that you do not believe to be true may subject you to
criminal punishment as a Class A misdemeanor.

1. My name is Christoffer Stanford Thygesen, and my date of birth is November 13, 1992.

2. I am the father of K.W., a child in common with Kailin Wang.

3. On or about December 12, 2018, I learned through my attorney Darrick Chase that there was an
individual by the name of Walker Stone who had filed a request for a Civil Harassment
Restraining Order against Kailin Wang in the San Francisco Superior Court.

4. I have never met Walker Stone, spoken with Walker Stone and/or communicated with Walker
Stone directly, indirectly, or by any other means.

5. Any claim by Kailin Wang, or by any person for that matter, that I may have collaborated with
Walker Stone in any way and for any reason is false, as I have not collaborated with Walker
Stone in any way and for any reason.

I swear or affirm that the above statements are true and correct to the best of my information,
knowledge, and belief.

_________________________________
Christoffer Thygesen

Florida
State of _____________________________ )

) ss
miami-dade
County of ___________________________ )

I, the undersigned Notary Public, do hereby affirm that Christoffer Thygesen personally appeared before
me on the _____
09 day of October, 2020, and provided me satisfactory identification and signed the above
Affidavit as his free and voluntary act and deed.

NATHALLIES I BRITTO
Notary Public - StaW of Florida

Commi~on " GG 199595

E:Npires on M:i,i:r, 22, 2022

_________________________________________ Notarized online using audio-video communication

Notary Public
 Kailin Wang· *· September 27, 2019
3
·1 ·1· · · · · · · · · · · · ·I N D E X
· · · ·IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA ·2· KAILIN WANG:· · · · · · · · · · · · · · · · · PAGE
·2 ·3· Examination by Mr. Chase· · · · · · · · · · · · 7
· · · · · · IN AND FOR THE COUNTY OF SAN FRANCISCO ·4
·5· · · · · · · · · · · E X H I B I T S
·3 ·6· NO.· · · · · · · · · ·DESCRIPTION· · · · · · ·PAGE
·4· ·CHRISTOFFER STANFORD· · · · · ) ·7· 1· · ·Notice of Taking Deposition of Kailin· · ·6
· · ·THYGESEN,· · · · · · · · · · ·) Videotaped deposition · · · · · Wang and for Production of Documents
·5· · · · · · · · · · · · · · · · ·) of: ·8· · · · and Things
· · · · · Petitioner,· · · · · · · ) ·9· 2· · ·Temporary Emergency (Ex Parte) Orders· · ·6
·6· · · · · · · · · · · · · · · · ·) KAILIN WANG · · · · · September 18, 2019
· · ·vs.· · · · · · · · · · · · · ·) 10
·7· · · · · · · · · · · · · · · · ·) Case No.: · · 3· · ·Temporary Emergency (Ex Parte) Orders· · ·6
11· · · · September 24, 2019
· · ·KAILIN WANG,· · · · · · · · · ) FDV-19-814465 12· 4· · ·List One - E-mail Accounts· · · · · · · ·95
·8· · · · · · · · · · · · · · · · ·) 13· 5· · ·List Two - E-mail Accounts· · · · · · · 124
· · · · · Respondent.· · · · · · · ) 14
·9· · · · · · · · · · · · · · · · ·) · · 6· · ·DNA Diagnostics Center - DNA Test Report133
10 15
11 · · 7· · ·E-mail from Darrick Chase to· · · · · · 138
· · · · · · · ·September 27, 2019 * 9:09 a.m. 16· · · · [email protected], dated
12 · · · · · December 27, 2018
13· · · · · · ·Location:· Regus Business Center 17
· · 8· · ·E-mail from Lanie Lee to Darrick Chase, 142
· · · · · · 180 North University Avenue, Suite 270 18· · · · dated December 28, 2018
14· · · · · · · · · · Provo, Utah 84601 19· 9· · ·Letter from Meltzer Lippe Goldstein &· ·183
15 · · · · · Breitstone, LLP to Darrick Chase, dated
16· · · · · · ·Reporter:· Kelly Fine-Jensen, RPR 20· · · · September 13, 2018, Re:· Subpoena Duces
17· · · · · · ·Videographer:· Amy Pollock, CLVS · · · · · Tecum
18 21
19 · · 10· · Paternity Petition· · · · · · · · · · · 188
20 22
· · 11· · Summons Paternity Non-Resident· · · · · 189
21 23
22 · · 12· · Family Offense Petition· · · · · · · · ·190
23 24
24 · · 13· · Family Offense Petition· · · · · · · · ·194
25 25
2 4

·1· · · · · · · · · ·A P P E A R A N C E S ·1· · · · · · · ·E X H I B I T S (Continued)

·2· NO.· · · · · · · · · ·DESCRIPTION· · · · · · ·PAGE
·2· FOR THE PETITIONER: ·3· 14· · Family Court Transcript, March 5, 2019· 195
·3· · · · · · · Darrick T. Chase ·4· 15· · Police Report, dated March 7, 2019· · · 196
· · · · · · · · KAYE MOSER HIERBAUM FORD, LLP ·5· 16· · Family Offense Petition· · · · · · · · ·197
·4· · · · · · · Attorney at law ·6· 17· · Family Court Transcript, March 8, 2019· 198
·7· 18· · Stanford Health Care Authorization for· 199
· · · · · · · · 235 Montgomery Street, 27th Floor · · · · · Use or Disclosure of Protected Health
·5· · · · · · · San Francisco, California 94104 ·8· · · · Information
· · · · · · · · Telephone:· (415) 296-8868 ·9· 19· · Consumerinfo.com, Customer Profile· · · 208
· · · · · Record
·6· · · · · · · E-mail:· [email protected] 10
·7 · · 20· · Account Summary· · · · · · · · · · · · ·212
· · FOR THE RESPONDENT: 11
·8 · · 21· · E-mail from [email protected] to 213
12· · · · [email protected], and others, dated
· · · · · · · · Kailin Wang (in pro per) · · · · · February 28, 2019
·9· · · · · · · 2481 Fairway Drive 13
· · · · · · · · Spanish Fork, Utah 84660 · · 22· · E-mail from [email protected] to· 213
14· · · · board@mpcsd, and others, dated
10· · · · · · · E-mail:· [email protected] · · · · · March 23, 2019
11 15
12· ALSO PRESENT: · · 23· · Summons· · · · · · · · · · · · · · · · ·214
13· · · · · · · John Wang 16
· · 24· · E-mail from [email protected] to· · · ·215
14 17· · · · Niels Thygesen, dated February 22, 2019
15 18· 25· · E-mail from [email protected]· · 217
16 · · · · · to [email protected], dated
19· · · · February 20, 2019
17 20· 26· · E-mail from Audrey Courson to Kailin· · 226
18 · · · · · Wang, dated September 18, 2019
19 21
20 · · 27· · Stanford Health Care Authorization for· 240
22· · · · Use or Disclosure of Protected Health
21 · · · · · Information
22 23
23 · · 28· · Stanford Health Care Authorization for· 243
24· · · · Use or Disclosure of Protected Health
24 · · · · · Information
25 25

CITICOURT
THE REPORTING GROUP
YVer1f
 OCT
1120!9 Fl-.305
ATTOR!.EYOR PAATY\·,TTl-40'.rrAnc-;;1;u Sf ATHU,'! Pa!) J51256 ~C'IC<n.'RrLJSHlNI.Y
,w.iE:DARRJCK T. CHASE
FIRIAIWI.E; KAYE•MOSER•HIERDAUM•FORD LLJ>
ADOREss235 Montgomery St., 27thFloor
STEiEET
crrv·SanFrancisco STATE.CA2!P CCOE. 94104 ]F K LE D
T£LEPHOIIE 110 .( 415) 296-8S68 FAX110 (415) 495-1771
Sup.:i::~r C1.iv;t ct CJ!iforni.1
C0\.-!11'✓ cf S,m Fr,1r:cisco
E-r,wL "°°"Ess [email protected]
ATTORIIEYFOR (.nom:) CHRJSTOFFER STANFORDTHYGESEN OCT152019
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
STREETAOOREss:400 McAllisterStreet
CLER:-<c).fJJ-/.~EOURT
,.wuNo ADOREss·400 McAllisterStreet
BY: // f VJ
cm Auo z1Pcooe San FranciscoCA 94102
7 /" D~lf.y Gl,.rk
BRANCHNAME:Unified FamilyCourt

PETITIONER:CHRJSTOFFER
STANFORDTHYGESEN
RESPONDENT:KAILIN
WANG
OTHER
PARENT/PARTY:
~ TEMPORARYEMERGENCY(EX PARTE)ORDERS CASENUMeER:

D Child Custody D Visitation (ParentingTime) D PropertyControl FDV-19-814465

[Kl Other (specify)~!-/).fiJilrR£NDING HEARING

1. TO (name(s)):RESPONDENT KAILINWANG
CJ Petitioner rn Respondent D Other Parent/Party D Other (specify):

A court hearing will be held on the Request for Order (form FL-300)servedwith this order, as follows:
a. Date:October 15, 2019 Time: I :30 p.m. W Dept.;.404'°40s' D Room:405
b. Address of court [}O same as noted above D other (specify):

2. Findings: Temporary emergency(ex parte) orders me neededto: (a) help preventan immediateloss or irreparableharm to a
party or to children in the case, (b) help preventimmediateloss or damageto propertysubject to dispositionin the
case, or (c) set or change procedurestor :.,hearingor trial.
COURTORDERS:The following temporary emergencyorders expireon the dale and time or the hearingscheduledin (1), unless
extended by court order:
3. 0 CHILO CUSTODY Ie.rnp.Qr_a[Y_physical
custody, care._andcontrol tq;_
a. Child's name Qatc_gf..fild.!:l Petitioner Respondent Other Party/Parent

D D D
D D D
D D D
D D D
D D D
D Continued on Attachment 3(a)
b. D Visitation (Parenting Time) The temporaryorders for physicalcustody, care, and control of the minor children in
(3) are subject to the other party's or parties' rights of visitation (parentingtime) as follows (specify):

THISIS A COURTORDER. D See Attachment 3(b)

Page 1 of2
FQrmAcfop!edforMandatoryU•e
JudicialCouncilof Cal~ornia TEMPORARYEMERGENCY(EX PARTE)ORDERS FamilyCode,§§ 2045,3062-3064,
FL-30S!Rev.July1, 2016) Cal.Rulesof Court,rules5.151-5.169
Wl'IVl.courts.ca.gov
WesllawOoc &Fom, Bui!dtr-
 -------PPIE~~~:crnum~r.oc'Ttti"~~~===------r---------___JF~L:::-3~0~s
TITIONER:CHRJSTOFFERSTANFORD THYGESEN CASE NUMSER:
RESPONDENT:KAil.,JN WANG
. OTHERPARENT/PARTY: FDV-19-814465

3. 0 CHILD CUSTODY (continued)

c. Travel restrictions
1
( ) Th~ party or parties with temporary physical custody, care, and control of minor children must not remove the minor
children from the state of California unless the court allows it after a noticed hearing.
2
( ) CJ Petitioner CJ Respondent D Other Parent/Party must not remove their minor children (specify):
(a) D from the slate of California.
(b) CJ from the following counties (specify):
(c) CJ other (specify):

d. CJ Child abduction prevention orders are attached (see form FL-341(8)).

e. (1) Jurisdiction: This court has jurisdiction to make child custody orders in this case under the Uniform Child Custody
Jurisdiction and Enforcement Act (part 3 of the California Family Code, commencing with section 3400).
(2) Notice and opportunity to be heard: The responding party was given notice and an opportunity to be heard as
provided by the laws of the State of California.
(3) Country of habitual residence: The country of habitual residence of the child or children is (specify):
CJ The United States of America D Other (specify):
(4) If you violate this order, you may be subject to civil or criminal penalties, or both.
4. 0 PROPERTY CONTROL
a. CJ Petitioner D Respondent D Other ParenUParty is given exclusive temporary use, possession, and
control of the following property that the parties D own or are buying CJ lease or rent

b. CJ Petitioner D Respondent CJ Other ParenUParty is ordered to make the following payments on the liens
and encumbrances coming due while the order is in effect:
Pay to: For: Amount:$ Due date:
Pay to: For: Amount:$ Due date:
Pay to: For: Amount:$ Due date:
Pay to: For. Amount:$ Due date:

5. OD All other existing orders, not in conflict with these temporary emergency orders, remain in full force and effect.
6. OD OTHER ORDERS (specify): CJ Additional orders are listed in Attachment 6.
SEE ATTACHMENT6.

Page 2of 2
/I
/.
1 In Re. Th~gesen vs. Wang .
,' San Francisco Countv s . • •
2 ATTACHMENT6-TE~~~~~; Case No. FDV-19-814465
EMERGENCY (EX PARTE) ORDERS
3 FOR GOOD CAUSE, THE COURT ORDERS.:,(l .
4 ~~~~
l. Issue sanctions, taki~~~~fablished the following claims: that
5 ~~~~S)
Respondent has repeat edlYharas'\"19~ ~'ii
tnreatened,
0
. • the peace and caused emotional
disturbed • harm
6 to Petitioner, his mother Terry, his father Alan, his and Respondent'schild- his sisters
7 Emma and Elise his brother James and his paternal grandparentsNiels and Inge Thygesen;
8 2. Evidence sanctions, prohibiting Ri~Q~nt from introducing the
9 following matters into evidence: That any third ~~~personated Respondent on-line; that any
10 third party sent emails, messages, friend~\~ts or otherwise published posts related to
11 Petitipner and his family. That Respondent is not permitted to call any witnesses at trial other
12 than those she disclosed at her deposition when asked; and
13 3. Terminating sanctions, rendering defaul~dgment against Respondent on

14 the following issues: that Respondent has threatened, ~~td,and disturbed the peace of .
~~'\)
15 Petitioner, his mother Terry, his father Al;%J'~~n- his sisters Emma and Elise, his

16 brother James and his paternal grandparents Niels and Inge Thygesen in a manner violating of

17 Family Code Section 6320 and warranting a permanent Domestic Violence Restraining Order,

18 including personal conduct orders, with the Order protecting the sa~
19 4. Respondent is precluded from testifyillSh.
'p~enting witnesses, and/or
~'\)~
20 otherwise commenting in any fashion, at trial, on the~t~cts for which she has asserted her 5th
fv~'
21 Amendment. ~ •

22 5. For other orders that the Court deems appropriate:

23
24
25
26
27
28

l.
9/18/23, 6:44 PM Fehring replaces Darrick Chase, who died on Jan. 21. The death was a suicide, according to the coroner's division of the Marin County Sheriff's .…

Google Fehring replaces Darrick Chase, who died on Ja ...

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Fehring replaces Darrick Chase, who died on Jan. 21. The death was a
suicide, according to the coroner's division of the Marin County Sheriff's
Office. Chase, 58, had served the board since 2007 and was an attorney
at a San Francisco law firm. Mar 30, 2023

Marin Independent Journal

mij https://www.marinij.com › 2023/03/30 › bel-marin-key...

Bel Marin Keys board appoints new member

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Actor Robin Williams Found Dead in Marin Home ...

Aug 11, 2014 — Actor Robin Williams was found dead in his Marin County home Monday
morning, according to the county coroner's bureau.
Missing: Fehring ‎replaces ‎Darrick ‎Jan. ‎21.

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Bloomfield man's death during arrest by Sonoma County ...

May 15, 2020 — Bloomfield man's death during arrest by Sonoma County deputies ruled a
homicide. David Ward, 52, died after a November struggle as sheriff's ...
Missing: Fehring ‎replaces ‎Darrick ‎suicide,

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Coroner: David Pelaez-Chavez shot in head and chest by ...
Mar 14, 2023 — David Pelaez-Chavez was killed by gunshots to the head and chest and was on
methamphetamine at the time of his death, according to a report ...
Missing: Fehring ‎replaces ‎Darrick ‎21. ‎suicide,

https://www.google.com/search?q=Fehring+replaces+Darrick+Chase%2C+who+died+on+Jan.+21.+The+death+was+a+suicide%2C+according+to+the+coroner%27… 1/2
1 DARRICK T. CHASE, ESQ. (CSB #151256)
KAYE•MOSER•HIERBAUM •FORD LLP
2 The Russ Building
235 MontgomeryStreet, 27th Floor
3 San Francisco, CA 94104
Telephone: (415) 296-8868
4 Facsimile: (415) 495-1771
Email: [email protected]
5
Attorneysfor Petitioner
6 CHRISTOFFER STANFORD THYGESEN

9 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 IN AND FOR THE COUNTY OF SAN FRANCISCO

11
CHRISTOFFER STANFORD THYGESEN, ) Case No. FDV-19-814465
12 )
Petitioner, ) EXPERT WITNESS DECLARATION
13 )
v. ) DATE:October22,23,24,31 and
14 ) November 7, 2019
) TIME: 9:00 a.m.
15 KAILIN WANG, ) LOCATION: Dept. 405
) TRIAL JUDGE: Honorable Monica Wiley
16 Respondent. )
)
17 )
)
18

19 To KailinWang,

20 I, DarrickT. Chase,declareas follows:

21 1. I am an attorneylicensed to practicelaw in California.I am counsel of recordfor

22 PetitionerMr.ChristofferStanfordThygesen ("Mr. Thyges,:n")in this matter.I make this

23 declarationpursuantto RespondentKailinWang's WrittenDemandfor Exchangeof Expert

24 WitnessInformationservedupon me by email on September 13, 2019, and pursuantto Code of

25 Civil Procedure Section 2034.260c.

26 Erik Rasmussen, CISSP

27 l. Qualification:Mr. ErikRasmussen,CISSP("Mr.ErikRasmussen")is qualifiedto be

28 an expert in this matter.For informationabout Erik Rasmussen's qualifications,please see his

EXPERTWITNESSDECLARATION
I.
I advance of providing deposition or trial testimony.
2 I declare under penalty of perjury under the laws of the State of California that the
3 foregoing is true and correct, and that this declaration was executed on October 3, 2019 in San
4 Francisco, California.
5

7
8
9
10 Thygesen flew in Erik
11 Rasmussen from Los
12 Angeles for both of our DV
13 Trials first in 2019, then in
14 2022, and he also hired him
15
for the San Francisco
16
District Attorneys Office
since 2019 See SFDA
17
Donald A. Dubain
18
Prosecutor disclosures
19

20

21

22

23

24

25
26

27

28

EXPERT WITNESS DECLARATION

3.
11/2/23, 8:59 PM darrick chase (from:marindatanow) - Search / X

Q darrick chase (from:marindatanow)

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marincountyconfidential @marindatanow · Feb 1
1/
This is sad and alarming.
From anyone
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On January 21, 2023 an elected official in Novato, Darrick Chase,
apparently died of a "penetrating shotgun wound to chest", in the garage of
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Anywhere
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The death was not reported by the local "paper of record"; logged only
recently by Coroner. Advanced search

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Brick Suit
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Congressmen Gaetz & +444)

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and community understanding. Darrick has
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served asa co-chair of the MeasureD

e
•
Committee and his areas of interest on the
Board include: improving BMK's water quality j M is listening

•
and access by pursuing new ways to improve
Israel War, Quantum +155
and maintain our waterways. This includes
looking for alternative sources of funding and
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marincountyconfidential @marindatanow · Mar 1

1/
Brandon Straka

#CHELLESHOCKED
• is speaking

+115)
Curiously, the website for the Bel Marin Keys Community Services District #PirateRadio
has not yet announced the death of Director Darrick Chase, a prominent Manscaping Hour has
attorney. But it has indicated that there's an immediate opening on the begun!
Board. But this opening was his seat?
~ Lisa S. Belanger, TNP & Critical Liberis listening
to serve on the Thursday Night +40
District Board
#ConspiracyTheories on 𝕏
BMKCSDBoard of The District is governed by a five-member
Directors!
Home IMMEDIATEOPENINGto s.erveon the
BMKCSDBoard of Directors! Ir,,r,1rnIAH QP[I\ING
Board of Directors elected to four-year terms:

• Vince Lattanzio,
Term expires: December 2022
J. Thomas
• is hosting

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:o ~l'I ,,,_,on til1: EHv'KCSJRo,ird of Dir1.'ctOr•, 1 John Mark Montobbio
Term expires: December 2022
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marincountyconfidential @marindatanow · Feb 1 #DETRANS

1/ The Stories of Detransitioners
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On January 21, 2023 an elected official in Novato, Politics · Trending

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marincountyconfidential @marindatanow · Mar 7

45 days have passed and @marinij still hasn't reported the violent death of
Darrick Chase, an elected official in Novato and a prominent attorney. But
I'm glad they're hyping the really important stuff, like how college students
are still drinking to excess.

Marin IJ @marinij · Mar 7

What is a ‘borg’? College drinking TikTok trend is ‘very concerning,’ can
lead to alcohol poisoning trib.al/NttLPWp

0 n 5 il,1 249

marincountyconfidential @marindatanow · Mar 30

This is wild.

1/
Tonight, ⁦@marinij⁩has FINALLY reported (indirectly) the passing of Mr.
Darrick Chase, a prominent attorney and elected official, in an article
about the appointment of his vacant CSD seat,

It's now 68 days AFTER his death.

marinij.com

1 5 4 609

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 EXHIBIT 5
Michael Gannon Reedy #161002 $800/ Hr. family law attorney with
experience in civil litigation and appellate law, May 2022 to January 2023 [8 Months]
(withdrew on January 19, 2023, one day before Darrick Chase committed Suicide) McManis
Faulkner (Partner) Fairmont Plaza, 50 W San Fernando St 10th Fl, San Jose, CA 95113

With over 30 years of experience, Michael brings a thorough and practical approach to
solving legal problems.

As a family law attorney with experience in civil litigation and appellate law, he is highly
skilled at delivering messages in ways his clients, judges, and opposing counsel hear and
understand. He is reasonable and controlled under pressure, with a keen ability to spot flaws
in the opposition.
May 2022 to January 2023 McManis Faulkner
family law attorney
[8 Months] (withdrew on (Partner) Fairmont Plaza, In addition to his family law practice, Michael has tried cases in both state and federal court,
Michael Gannon with experiencein
5 $800/ Hr. January 19, 2023, one day 50 W San Fernando St and handles appeals in the Ninth Circuit and the California Court of Appeal, on matters
Reedy #161002 civil litigation and
before Darrick Chase 10th Fl, San Jose, CA involving civil rights, constitutionalissues, businesslitigation, land use, and family law.
appellate law,
committed Suicide) 95113 Admissions: State Bar of California, U.S. District Court, Northern, Central, Southern and
Eastern Districts of California, U.S. Ninth Circuit Court of Appeals and Federal Circuits,
U.S. Supreme Court Education J.D., University of San Francisco School of Law B.A.,
Stanford University Awards. The Best Lawyers in America® in the areas of Appellate
Practice, 2021-24; and Family Law Member of award winning team "The Best in Family
Law", The Recorder, 2010 - 2019 Named to Northern California Super Lawyers, 2018-2023
Granted the American Jurisprudence Family Law Award from the University of San
Francisco, School of Law
9/18/23, 3:31 AM Michael Reedy | San Jose Law Firm | McManis Faulkner | Jim McManis | William Faulkner

McManis-Faulkner

Michael Reedy
PARTNER

Email [email protected]
Phone 408.279.8700

Focus
Family Law, Litigation, Appellate

Clients hire Michael Reedy for his legal insight

and logical mind. With over 30 years of
experience, Michael brings a thorough and
practical approach to solving legal problems.
As a family law attorney with experience in civil litigation and appellate law, he is highly
skilled at delivering messages in ways his clients, judges, and opposing counsel hear
and understand. He is reasonable and controlled under pressure, with a keen ability to
spot flaws in the opposition.

In addition to his family law practice, Michael has tried cases in both state and federal
court, and handles appeals in the Ninth Circuit and the California Court of Appeal, on
matters involving civil rights, constitutional issues, business litigation, land use, and
family law. He is highly principled and puts his clients’ needs and objectives at the
forefront of every matter. He fights hard and fights to the end to get the best result.

https://www.mcmanislaw.com/people/lawyers/michael-reedy 1/4
9/18/23, 3:31 AM Michael Reedy | San Jose Law Firm | McManis Faulkner | Jim McManis | William Faulkner

“Be sure you put your feet in the right place, then stand firm.” Abraham Lincoln

Credentials
ADMISSIONS
• State Bar of California
• U.S. District Court, Northern, Central, Southern and Eastern Districts of California
• U.S. Ninth Circuit Court of Appeals and Federal Circuits
• U.S. Supreme Court

EDUCATION
• J.D., University of San Francisco School of Law
• B.A., Stanford University

Experience
REPRESENTATIVE MATTERS
• Defended two mothers sued for defamation in connection with their protests at
family court. The clients won when the case was dismissed as a SLAPP suit, a
decision upheld by the Court of Appeal.
• On several occasions, successfully represented attorneys sued for malicious
prosecution. The clients prevailed on motions before trial.
• Settled numerous family law cases to the client’s satisfaction with little or no litigation.
• Assisted in winning sanction awards for hundreds of thousands of dollars in two
family law cases when opposing parties refused to cooperate.
• Obtained annulment in a family law case.
• Critical member of trial team in recent federal court case that resulted in a favorable
jury verdict after less than one hour of deliberation.

REPORTED CASES
• Mann v. Department of Motor Vehicles (1999) 76 Cal.App.4th 312.
• Zhao v. Wong (1996) 48 Cal.App.4th 1114.
• Fenwick & West v. Superior Court of Santa Clara County (1995) 43 Cal.App.4th
1272.

Awards & Honors

AWARDS
• The Best Lawyers in America® in the areas of Appellate Practice, 2021-24; and
Family Law

https://www.mcmanislaw.com/people/lawyers/michael-reedy 2/4
9/18/23, 3:31 AM Michael Reedy | San Jose Law Firm | McManis Faulkner | Jim McManis | William Faulkner

• Member of award winning team “The Best in Family Law”, The Recorder, 2010 -
2019
• Named to Northern California Super Lawyers, 2018-2023
• Granted the American Jurisprudence Family Law Award from the University of San
Francisco, School of Law
Articles & Blogs
ARTICLES
• “In a Time of Great Uncertainty, Community Strengthens Us” Daily Journal
• “Pet Peeves In Your Divorce” Daily Journal
• “Why Heightened Emotions and Conflict Help No One in a Divorce” Daily Journal
• "Basics of a Sound Appeal" The Recorder
• "Google, Oracle to Disclose Payments" The San Francisco Daily Journal
• "Winning Appeals in Family Law" The Recorder

BLOGS
Lead with Kindness – In Life, In Law
Championship Culture
Why Ratcheting Up Emotions Serves No One In A Divorce
The Path to Equality -- Yesterday and Today
Kindness - In Life, In The Law
Lincoln the Storyteller

Speaking Engagements
• Moderator, “How Different Courts of Law are Adapting to COVID 19 Pandemic”,
Honorable William A. Ingram Inn of Court, 2020
• Moderator, “Life and Legacy of Supreme Court Justice John Paul Stevens”,
Honorable William A. Ingram American Inn of Court, 2020

Professional & Community Contributions

Michael is an active member and Past President of American Inns of Court, the
Honorable William A. Ingram Inn and served on a team of lawyers, judges and law
students who won a prestigious First Place award from the American Inns of Court. He
is a member of the Santa Clara County Bar Association and serves on its Appellate
Courts Committee. He previously served as a board member of the American Civil
Liberties Union, Santa Clara County Chapter. Recently, Michael served as Chair of the
Board of Directors at Saint Francis High School in Mountain View.
Focus
https://www.mcmanislaw.com/people/lawyers/michael-reedy 3/4
 FL-150
PETITIONER: Christoffer Thygesen CASENUMBER:
RESPONDENT: Kailin Wang FDV-19-814465
OTHER PARTY/PARENT/CLAIMANT:

12. The following people live with me:

How the person is That person's gross Pays some of the
Name Age related to me (ex: son) monthly income household expenses?
Thygesen Wang 3 Son n a Yes No
D Yes D No
0 Yes O No
0 Yes· 0 No
□ Yes D No

13. Average monthly expenses □ Estimated expenses (II Actual expenses 0 Proposed needs

a. H~W □ i.
2
• SOO h. Laundry and cleaning * ...........................................
.$•------~
(1 If Rent or mortgage ................ ·-----~~ ..,$_~------5~0~
i. Clothes ..........................................................................
mortgage: j. Education ..................................................................
• $..._______ ______.QL..
(a) average principal: $.______ ~
"" k. Entertainment, gifts, and vacation ...........$_____ ~J~D~DL..
(b) average interest: ..,________
... 0..._
(2 ) Real property taxes _$_____
..................................... ~CL./.
Auto expenses and transportation
(insurance, gas, repairs, bus, etc.) ..............,$
_____ 2....
.... 2""'5
....
(3) Homeowner's or renter's insurance
m. Insurance (life, acc·1dent,etc.; do not include
(if not iocl ucled above) ...................................
$ ----~-~ 0 auto, home, or health insurance) .._$---"------'o"--. •
(4) Mainienance and repair .............................
$ 0 S . d. $ 1 7 o fl
b. Health-care costs not paid by insurance $ 1 3 Q n. avings an invest men 1s ...................................
.._ ____ --+-,
_,__._,._,,
....

1.~ bb ~:~~~~~~~ea~~~~~:~:zt~~ in·i~~~..1·4................. 50

c. Child care $
............................................................. $
d. Groceries and household supplies ..........$ - - - (itemize below in 14 and insert total here) .'li.._ ____ 1--+-,
....,3..,.0,._,,0.,__·
e. EaUng out .....................................
,....... ~
h.................. 3Q o q. Other (specify): V.is.i.ta.tion ...E'.ees.............$ 9 O2
.f. Utilities (gas, electric, water, tras ) ...... ;n 20 ..___,.-~ _ _,_,_,_
• g. Telephone, cell phone, and e-mail ............
:.$
______ 3_S_r. TOTAL EXPENSES (a-q) (do not add in .
the amounts in a(1)(a) and (b))

s. Amount of expenses paid by others *

*My parents sometimes buy clothes and toys.
I do laundry at their house.
14. Installment payments and debts not listed above
Paid to For Amount Balance Date of last payment
Allan & Terry Thygesen $ 1,300 $ 443,888.72 8/30/2022 .
$ $
$ $
$ $
$ $
$ $
Total fees paid to lawyers
15. Attorney fees (This is required if either party is requesting attorney fees.): for custody/visitation
a .. To date, I have paid my attorney this amount for fees·and costs (specify):$ 449, 559i.S-fries.
b. The source ot this money was (specify): Savings, Sale of Stock, Personal Loan
c. I still owe the following fees and costs to my attorney (specify total owed): ~ Through 713112 2
d. My attorney's hourly rate is (specify): $ 7 5 0

I confirm this fee arrangement.

Date: 8 / 3 1 / 2 0 2 2

Michael Reedy ►
(TYPE OR PRl~T NAMEJ

FL·\50 (Rev. January,. 2019) INCOME AND EXPENSE DECLARATION Page 3 ol 4

CfB" I Essential
ceb.aNII ,0 Forms·
 1 MICHAEL REEDY (161002)
McMAN1S FAULKNER
2 a Professional Corporation
50 West San Fernando Street, 10th Floor ELECTRONICALLY
3 San Jose, California 95113 FILED
Telephone: (408) 279-8700 Superior Court of California,
County of San Francisco
4 Facsimile: (408) 279-3244
Email: [email protected] 01/09/2023
5 Clerk of the Court
BY: TIM KYU
DOUGLAS RAPPAPORT (136194) Deputy Clerk
6 LAW OFFICES OF DOUGLAS L. RAPPAPORT
260 California Street, Suite 1002
7 San Francisco, CA 94111
Telephone: (415) 989-7900
8 Facsimile: (415) 989-7950
Email: [email protected]
9
Attorneys for Petitioner,
10 CHRISTOFFER THYGESEN
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
FOR THE COUNTY OF SAN FRANCISCO
13
14 UNIFIED FAMILY COURT

15
In re the Matter of: Case No.: FDV-19-814465
16
CHRISTOFFER THYGESEN, PETITIONER'S REQUEST FOR FAMILY
17 CODE SECTION 217 EVIDENTIARY
Petitioner, HEARING ON VISITATION AND BEST
18 INTERESTS OF THE CHILD
and
19 Date: January 23, 2023
KAILIN WANG, Time: 9:00 a.m.
20 Dept.: 404
Respondent. Judge: The Hon. Daniel Flores
21

22

23 Petitioner, Christoffer Thygesen ("Petitioner"), hereby requests an evidentiary hearing to

24 permit him to present live testimony and to cross-examine Respondent, Kailin Wang
25 ("Respondent"), pursuant to Family Code section 217, with respect to the issues of temporary
26 child custody and visitation orders for the parties' minor child; what is in the best interests of the
27 minor child in regard to Respondent's request to expand her in-person supervised visitation and
28

In re the Matter o/Thygesen v. Wang, Case No.: FDV-19-814465; PETITIONER'S REQUEST FOR FAMILY
CODE SECTION 217 EVIDENTIARY HEARING ON VISITATION AND BEST INTERESTS OF THE CHILD
 I MICHAEL REEDY (161002)
McMANIS FAULKNER
2 a Professional Corporation ELECTRONICALLY
50 West San Fernando Street, I 0th Floor
3 San Jose, California 95113 FILED
Superior Court of California,
Telephone: (408) 279-8700 County of San Francisco
4 Facsimile: (408) 279-3244
Email: [email protected] 01/09/2023
Clerk of the Court
5 BY: TIM KYU
DOUGLAS RAPPAPORT (136194) Deputy Clerk
6 LAW OFFICES OF DOUGLAS L. RAPPAPORT
260 California Street, Suite I 002
7 San Francisco, CA 94111
Telephone: (415) 989-7900
8 Facsimile: (415) 989-7950
Email: [email protected]
9
Attorneys for Petitioner,
IO CHRISTOFFER THYGESEN
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12

13 FOR THE COUNTY OF SAN FRANCISCO

14 UNIFIED FAMILY COURT

15
In.re the Matter of: Case No.: FDV-19-814465
16
CHRISTOFFER THYGESEN, MEMORANDUM OF POINTS AND
17 AUTHORITIES IN OPPOSITION TO
Petitioner, REQUEST TO EXPAND VISITATION;
18 REQUEST FOR AFFIRMATIVE RELIEF
and (FC §213); REQUEST FOR FAMILY
19 CODE SECTION 217 EVIDENTIARY
KAILIN WANG, HEARING RE: VISITATION (FC §217)
20
Respondent. Date: January 23, 2023
21 Time: 9:00 a.m.
Dept.: 404
22

23

24 II~--------------~
25
Ill
26
Ill
27
Ill
28

In re the Matter ofThygesen v. Wang, Case No.: FDV-19~814465; MPA IN OPPOSITION TO REQUEST TO
EXPANDVISITATION,REQUESTFOR AFFIRMATIVERELIEF; REQUESTFOR 217 EVID. HEARING
 1 TABLE OF CONTENTS

2 INTRODUCTION ...................................................................................................................... 4
3 REASONS FOR DENYING RESPONDENT'S REQUEST ..................................................... 4

4
I. The Court's issuance of a DV-130 Restraining Order and Findings ......................4
5
2. The Court needs to first hear from qualified experts regarding
6 Respondent's mental health and the risks she poses without risking
the minor's child's physical and psychological safety in the interim .................... 5
7
3. There is additional new evidence that Respondent is very dangerous ................... 6
8
4. The Court's action taken to date to protect the child shows that it
9
knows something is profoundly wrong with Respondent, and new
10 information would only heighten that concern ...................................................... 6

11 LEGAL ARGUMENT ................................................................................................................ 7

12 A. Petitioner is entitl_edto an evidentiary hearing (Family Code§ 217) ..................... 8

13 I. Background on Family Code Section 217 ................................................... &

14 2. Application of Family Code Section 217 ................................................... 9
15 B. Petitioner Requests Alternative Affirmative Relief to Ensure the
16 Child's Health, Safety, and Welfare (Family Code§ 213) .................................. 10

17 C. It is in the Child's Best Interest to Temporarily Suspend Visits With •

Respondent (Fam. Code §§ 303 l(c), 3100, 3020(a)-(b), and 3011) ................... 11
18
1. The health, safety, and welfare of the child (Fam. Code
19 301 l(a)(l)) ......................................................................................... 12
20 2. Any history of physical abuse against the child, the other
21 parent, their own parents, a cohabitant, or a person with
whom the person seeking custody has a dating
22 relationship (Fam. Code 301 l(a)(2)(A)(i)-(iii)) ................................. 14

23 3. The nature and amount of contact with both parents (Fam.

Code 3011 (a)(3)) ............................................................................... 15
24
4. Any habitual or continual illegal use of controlled substances
25 of alcohol (Family Code 301 l(a)(4)) ................................................. 16
26
5. Any other factors the court deems relevant .._............................................ 16
27
CONCLUSION ......................................................................................................................... 17
28
2
In re the Matter o/Thygesen v. Wang, Case No.: FDV-19-814465; MPA IN OPPOSITION TO REQUEST TO
EXPAND VISITATION, REQUEST FOR AFFIRMATIVE RELIEF; REQUEST FOR 2 I 7 EVID. HEARING
 1 TABLE OF AUTHORITIES
2
Cases
3
Boddie v. Connecticut,
4 (1971) 401 U.S. 371 ..................................................................................................................10
5 Elkins v. Superior Court,
(2007) 41 Cal.4th 1337 ...........................................................................................................8. 9
6
Gray v. Whitmore,
7 (1971) 17 Cal.App.3d 1 ............................................................................................................10
8 Montenegrov. Diaz,
(2001) 26 Cal.4th 249 ...............................................................................................................11
9
Statutes
10
Fam. Code§ 3020(c).............................................................................................................4. 6. 17
11
CodeofCiv. Proc. §2032.310 ........................................................................................................7
12
Fam. Code§ 3011 (a)(3) ...........................................................................................................2, 15
13
Fam. Code§ 301 l(a)(I) ............................................................................................................2. 12
14
Fam. Code§ 301 l(a)(2)(A)(i)-(iii) ...........................................................................................2. 14
15
Fam. Code§ 3020(a)(c) ................................................................................................................14
16
Fam.Code§§3031(c),3100,3020(a)-(b),and3011 ...............................................................2. 11
17
Fam. Code,§ 217 subd. (a) ..............................................................................................................8
18
Fam.Code§3011(a)(4) ............................................................................................................2, 16
19
Fam. Code§ 217 ....................................................................................................................passim
20
Fam. Code§ 217(c)...........................................................................................................•...........10
21
Family Code section 301 l(a)(2)(A)(iii) ......................................................................................6. 8
22
Fam. Code§ 213 ..................,..........................................................................................2, 4, 10, 11
23
Fam. Code§ 3020 (a)-(c) ..............................................................................................................12
24
Fam.Code§3100 .........................................................................................................................12
25
Fam. Code§ 3011 .........................................................................................................................12
26
Fam. Code§ 3020 .........................................................................................................................12
27
28
3
In re the Matter ofThygesen v. Wang, CaseNo.: FDV-19-814465;MPAIN OPPOSITION
TO REQUESTTO
EXPANDVISITATION,REQUESTFORAFFIRMATIVE
RELIEF;REQUESTFOR217 EVID.HEARING
 into a LLC within several months after his daughter lost custody to his only grandchild whom he
2 and his wife raised during the first few months of the child's life.)
3 Subsequent Abduction Plot: There is evidence of what law enforcement has deemed a

4 possible abduction plot after discovering that Respondent secretly issued forged subpoenas to the

5 U.S. Department of State for the child's passport and to his pre-school for his records, including

6 his schedule. Respondent is currently being criminally prosecuted for this conduct in Utah (State

7 ofUtahv. Wang, UtahCountyCaseNo.211100167).

8
CONCLUSION
9

10 _Withdue respect for the protections issued by this Court for the minor child !p)d in the

11 paramount interest of the child's health, safety and welfare, Petitioner respectfully requests that

12 the Court: (1) deny Respondent's request for additional visitation; (2) grant Petitioner's

13
forthcoming motion for Dr. Meloy to conduct a full psychological examination and threat
14
assessment of Respondent; (3) grant Petitioner's request for a Family Code section 217
15
evidentiary hearing where the Court can hear expert testimony and all relevant evidence
16
including the results of the psychological examination about the risks to the child posed by
17
18 contact with Respondent; and (4) temporarily suspend all visitation since the child's safety, both

19 physical and psychological, cannot be ensured, as mandated by Cal. Fam. Code§ 3020(c), and
20 the until the Court has the evidence required to fully understand the risks that Respondent poses.
21
22 DATED: January 9, 2023
McMANIS FAULKNER
23

24

25
26 Attorneys
Christoffer
27

28
17
In re the Matter ofThygesen v. Wang, Case No.: FDV-19~814465; MPA IN OPPOSITION TO REQUEST TO
EXPAND VISITATION, REQUEST FOR AFFIRMATIVE RELIEF; REQUEST FOR 217 EVID. HEARING
 Our friend, Darrick Chase.....FDV-19-814465 Thygesen vs. Wang

Doug Rappaport <[email protected]>

6 ~ Reply <~ ReplyAll ➔ Forward] j-ij E
•
~---~~----~-----
To Department 404; Frances Yokota; Daniel A Flores 5un 1/22/2023 10:26 AM

I I WARNING: This email was generated from an externali source. You should only open files from a trustworthy source.

It is with a very heavy hea.rt that I have to share the news that Darrick Chase passed away. I know that he always liked court staff very much and I think that everyone felt the
same·way about him. Following the withdrawal of Michael Reedy as the family law attorney representing Mr. Thygesen, Darrick was going to handle this role, albeit
reluctantly given the excessive demands and pressure, and was intending to appear on Monday. In his absence, 1·will be conducting the hear:ing as I'm .sure Darrkk would
want us to continue to keep this case moving forward. At this point, his passing is not public 1 and I would request that his death not be discussed in open court until his
family has had the opportunity to share this information themselves.

Best,
Doug

Law Offices of Douglas L. Rappaport

260 California Street, Suite 1002
San Francisco, CA 94111
Tel: 415-989-7900
Fax: 415-989-7950
email: [email protected]

This email message is for the sole use of the intended recipient and contains confidential and privileged information. Any unauthorized review, use, disclosure or distribution
is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message, Thank you.
 EXHIBIT 6
Thygesen hired four [4] Utah attorneys Mitchell Olsen ($350/hr.), Beau
Olsen, Martin Olsen, and Bryant J McConkie who represented Thygesen
continuously since March 2019 up until October 2022 who represented Thygesen
in Juvenile Court Case no. 1170844, , the Utah Paternity 194400718, amongst
other trailing cases.
Case no. 194400718 has over 1,000 docket entries and Utah Judge Low
held over 40+ Hearings and Thygesen was represented at every one single one of
the 40+ hearings.
Thygesen's Utah
Attorneys

Intial appearance in the

Case: FDV-19-814465 on
6f25/19 UCCJEA
~
$650/ Hr. (Per Partner @ Olsen & Olsen, Evideotiary Hearing,
12 ..QIS!IIUTBar# Family Law Utah Bar: 101311201I
Thygesen's 1211/E, Atty_s at Law continously represented
13826
Thygesen on all Trial
Court matters and
Appeallate matters

CA Attorneys
Hourly Rate Specialization Length of Representation Law Office CV
for Thygesen
Ketamed 811/2019 to
Present The 8/1/19 date is
obtained from SF Sgt.
Martinez Police Report.
Rappaport Filed on 2019-
10-ISASSOCIATION OF
ATTORNEYS·
RAPPAPORT,DOUGLAS
LEE ADDED AS
ATTORNEY FOR
THYGESEN,
Martin~ Partner @ Olsen & Olsen
13 $400/Hr. Family Law CHRISTOFFER Uiah Bar: 10/15/1991
UT#: 6015 Law, LLC
STANFORD.Has
continously represented
Thygesen at every one of
the 40 + hearings in FDV-
19-814465 (SF Superior
Family Law Matter), Lead
Atty. for the DVRO trial,
and acting as Victim's
Attorney in People v.
Wang 19016407 (PC 646.9
,, ............
,.... ,.....,

1lm!!!..L 4/1/2020 Co-counel with

McConkie
14 ~UT ($3251 Hr) Family Law Attorney Michele Insalaco UT Bar #: 5/24/2005
, Hales&Gwin
#: 10408 for Thygesen's Appeals

Beau J. Olsen
IS $3251 Hr. Family Law Olsen & Olsen 3/3/19 Uiah Bar: 10/18/2014
Utah Bar: 15213
 4TH DISTRICT COURT - PROVO
UTAH COUNTY, STATE OF UTAH

CHRISTOFFER THYGESEN vs. KALIN WANG

CASE NUMBER 194400689 UCCJEA Child Cus Jur **** PRIVATE ****

CURRENT ASSIGNED JUDGE

DAROLD MCDADE

CURRENT ASSIGNED COMMISSIONER

MARIAN ITO

PARTIES
Petitioner - CHRISTOFFER THYGESEN
Represented by: BEAU OLSEN
Represented by: MITCHELL OLSEN
Represented by: MARTIN OLSEN
Represented by: BRYANT MCCONKIE

Respondent - KALIN WANG

ACCOUNT SUMMARY
Total Revenue Amount Due: 35.00
Amount Paid: 35.00
Amount Credit: 0.00
Balance: 0.00
REVENUE DETAIL - TYPE: JUDICIAL DOCUMENT AP
Original Amount Due: 35.00
Amended Amount Due: 35.00
Amount Paid: 35.00
Amount Credit: 0.00
Balance: 0.00

REVENUE DETAIL - TYPE: TELEPHONE/FAX/EMAIL

Original Amount Due: 22.50
Amended Amount Due: 0.00
Amount Paid: 0.00
Amount Credit: 0.00
Balance: 0.00
Account Adjustments Sum To Date Amount Reason
2019-09-06 -22.50 Account is being zeroed out as
the requestor never paid fee.

CASE NOTE
Backups: 194400711 CS; 194400718 PA; 194400734 PO

PROCEEDINGS
03-13-2019 **** PRIVATE **** Filed: : Certified California Order
03-13-2019 **** PRIVATE **** Filed: Petition: Verified Petition For
Expedited Enforcement of Child Custody Determination and
Registration of Child Custody Determination

11-21-2020 04:23 PM Page 1 of 4

11
MITCHELL J. OLSEN, JR
Utah State Bar No. 13826
OLSEN & OLSEN Attorneys at Law, LLC
Attorneys for Respondent
8142 South State Street
Midvale, Utah 84047
Telephone: (801) 255-7176

DISTRICT COURT OF THE STATE OF UTAH

FOURTH JUDICIAL DISTRICT UTAH COUNTY

KAILIN WANG, DECLARATION OF ATTORNEY FEES

AND COSTS
Petitioner,

vs. Civil No. 194400718

CHRISTOFFER THYGESEN, Judge Thomas Low

Commissioner Marian Ito
Respondent.

MITCHELL J. OLSEN JR. being first duly sworn, deposes and says:

1. That I am the attorney for the Respondent.

2. That I am licensed to practice law in the State of Utah.

3. That my Utah State Bar Number is 13826.

4. That all of the statements hereinafter set forth within this declaration are made by

me on the basis of my personal and direct knowledge of the matters to which said statements

pertain. If called as a witness by a court of competent jurisdiction, I am able to and shall testify

as to each and all of said matters in the manner hereinafter set forth within this declaration.

5. That I am a citizen of the United States and a resident of the State of Utah, over

the age of 18 years.

 6. That my hourly rate is $335.00/ hour.

7. That I have been practicing law for approximately 12 years, and my hourly rate is

fair and reasonable based upon my experience.

8. That on April 29, 2022, the court awarded Respondent his attorney fees and costs

he incurred related to this case.

9. That Respondent has requested no less than $48,769 in attorney fees, which is the

same amount that Petitioner alleges she has spent on attorney fees.

10. That as Respondent's attorney, I bill him for preparing pleadings, reviewing

pleadings, answering pleadings, writing letters, reviewing correspondence, meeting with my

client, preparing for court hearings, court hearings, phone calls, emails, and preparing the

Declaration of Mitchell J. Olsen JR For Attorney Fees.

11. That I bill in six minute increments.

12. That I keep a daily log of the time that I spend on each case, each day.

13. That I have submitted a monthly bill to my client each and every month.

14. That my billing time is specific to hearings after Petitioner was found to be a

vexatious litigant in April of 2020.

15. That this declaration is not inclusive of all my time, and is merely focused on

hearings and hearing preparation.

16. That we have had at least the following hearings in this case, since Petitioner was

found to be a vexatious litigant: April 29, 2022; December 9, 2021; November 16, 2021;

November 12, 2021; November 9, 2021; August 27, 2021; July 29, 2021; May 20, 2021; May

10, 2021; December 22, 2020; April 30, 2020; June•2, 2020; May 14, 2020.

17. That some of the hearings listed above were mu Itipie hours.
 18. That the two-day evidentiary hearing was also set no less than four times.

19. That these hearings and preparation for hearings took a significant amount of

time, included complex issues, and required substantial time to review Petitioner's plethora of

filings.

20. That I have billed Respondent a total of 235 .9 hours since Petitioner was found to

be a vexatious litigant for hearings, hearing preparation, and trial preparation only.

21. That this amount of time does not account for associate time, or for me reviewing

and drafting memorandums.

22. That based on hearings and hearing prep alone since Petitioner was declared a

vexatious litigant, my billings are $79,026.50.

23. That this amount is reasonable based upon the above mentioned factors and the

complexity of this case.

24. That my client has further demonstrated that his request is reasonable by only

requesting an amount for attorney's foes in the amount of $48,769 which is the amount that

Petitioner has admitted to having paid for her Utah litigation against him.

25. That my client has also incurred $3,272.98 in litigation and copying expenses

with Salt Lake Legal, which were incurred in November of 2021 and May of 2020.

26. That my client has also incurred at least $2,134.25 in transcription fees, which

were necessary as a result of Petitioner's distortion of the actual orders of the court.

27. That I am, therefore, requesting an award of $48,769 in attorney fees, $3,272.98

in litigation costs, and $2,134.25 in transcription fees, for a total of $54,176.23.

28. That I declare under criminal penalty under Utah Code §78B-18a-106 and the laws

of the state of Utah that the foregoing is true and correct.

 DATED this 23rd day of May, 2022.

OLSEN & OLSEN

Isl Mitchell J Olsen

MITCHELL J OLSEN
Attorney for Respondent

CERTIFICATE OF SERVICE

I hereby certify that on May 23, 2022, I caused the foregoing DECLARATION OF
ATTORNEY FEES AND COSTS To be electronically filed with the clerk of the above court, I
also emailed said filing to the following

Kailin Wang
Petitioner
[email protected]

Isl Beau J. Olsen

MARTIN N. OLSEN
Utah State Bar No. 6015
BEAU J. OLSEN
Utah State Bar No. 15213
OLSEN & OLSEN, L.L.C.
Attorneys for Petitioner
8142 South State Street
Midvale, Utah 84047
Telephone: (801) 255-7176
[email protected]

IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT

IN AND FOR UTAH COUNTY, STATE OF UTAH

VERIFIED PETITION EXPEDITED

CHRISTOFFER THYGESEN, ENFORCEMENT OF CHILD
CUSTODY DETERMINATION AND
Petitioner, REGISTRATION OF CHILD
CUSTODY DETERMINATION
KALIN WANG,
Civil No.
Respondent.
Honorable
Commissioner

Petitioner, CHRISTOFFER THYGESEN, complains and for cause of action and alleges

against Respondent as follows:

RESIDENCY AND PROCEDURAL POSTURE

1. That the Petitioner is a resident of California.

2. That upon information and belief, Respondent is a resident of California or New

York.

3. That Petitioner resides at 294 Ewing Terrace, San Francisco, California 94118.
 2. That the Court grant Petitioner immediate physical custody of the minor child, if

the minor child is removed from his custody at the March 18, 2019 shelter hearing.

3. That the Court issue a writ of assistance that includes the following: (1) for law

enforcement to assist Petitioner in obtaining immediate physical custody of the minor child, if

the minor child is removed from Petitioner’s custody; (2) to allow Petitioner to accompany law

enforcement to obtain physical custody of the minor child, if the minor child is removed from his

custody; and, (3) for law enforcement to assist in ensuring the safety and well being of the minor

child, Respondent, Petitioner, and other interested parties.

4. That the Court and state of Utah enforce the Amended Temporary Restraining

Order and Child Custody Order (the California Protective Order).

5. That the Court schedule a hearing on the first day possible after service.

6. That if Respondent’s Utah counsel refuses to accept service, then an order

allowing Respondent to be served by email be issued.

DATED March 13, 2019.

OLSEN & OLSEN, L.L.C.

/s/ Martin N. Olsen

MARTIN N. OLSEN
Attorney for Petitioner
 VERIFICATION

CHRISTOFFER STANFORD THYGESEN, being first duly sworn, deposes and says

that he is the Petitioner in the above-entitled matter, that he has read the foregoing VERIFIED

PETITION EXPEDITED ENFORCEMENT OF CHILD CUSTODY DETERMINATION

AND REGISTRATION OF CHILD CUSTODY DETERMINATION and knows the

contents thereof, that the same is true to the best of his knowledge and belief under criminal

penalty under Utah Code § 78B-5-705 and the laws of the State of Utah.

/s/ Christoffer Stanford Thygesen

CHRISTOFFER STANFORD THYGESEN
(Signed by Martin Olsen with permission of
Petitioner via email 3/3/2010
Petitioner

Typo
suppose to
be
3/3/2019,
Thygesen
Hired a
Team of
Utah
Attorneys
before he
obtained Ex
Parte
Custody on
3/6/2019 in
San
Francisco

     
    
       
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that Father be awarded sole physical and legal custody of the child, (3) that Mother receive

written permission to travel with the child, (4) that California had jurisdiction to make custody

orders pursuant to the UCCJEA, (5) that Mother has a history of domestic violence, and (6) that

Father, with assistance of Utah Police or other appropriate authorities, was allowed to retrieve the

child.

On or about March 7, 2019, Father, under the guidance and direction of Utah DCFS and

CPS, obtained custody of the minor child from Mother’s parents. After obtaining custody, and

consistent with State statute, the State scheduled a shelter hearing for March 12, 2019. Out of

necessity, and with no other foreseeable way to obtain custody of the child, the Father worked

with Utah authorities to ensure the safety of the minor child. Now, the minor child is in the

custody of the Father and any outstanding custody issues should be resolved in California.

STATEMENT OF FACTS

1. The minor child was born on November 28, 2018. See Exhibit A.

2. The resident city of the Mother is Los Angeles, California. Id.

3. The resident State of Mother is California. Id.

4. On December 11, 2018, Mother filed for child support services and paternity in

the state of California. See County of Las Angeles v. Thygesen, Dept. Of Child

Support Services, case # 18CWCS16140 (Las Angeles Sup. Ct.) (“Paternity

Action”)

5. By Mother filing for child support services and paternity, she verified to the court

that she was a resident of Los Angeles County, State of California.

2
MITCHELL J. OLSEN
Utah State Bar No. 13826
BEAU I.OLSEN
Utah State Bar No. 15213
OLSEN & OLSEN, L.L.C.
Attorneys for Mr. Thygesen
8142 South State Street
Midvale, Utah 84047
Telephone: (801) 255-7176
[email protected]

IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT

IN AND FOR UTAH COUNTY, STATE OF UTAH

KAILIN WANG , OBJECTION AND STATEMENT OF

DISCOVERY
Petitioner,

vs. Civil No. 180400131

Judge Thomas Low

WALKER P. STONE

Respondent.

COMES NOW , Christoffer Thygesen, by and through his counsel of record, Mitchell J.

Olsen, and pursuant to the Utah Rules of Civil Procedure, hereby Objects to Kallin Wang's Ex

Parte Subpoena in the matter of Wang v. Stone, a Stalking Injunction sought by Ms. Wang which

has been closed since May of 2018 Although Mr. Thygesen is not a party in Wang v. Stone, Ms.

Wang sent notice to Mr. Thygesen and the subpoena specifically references case #194400718

where Mr. Thygesen is a litigant.

REQUESTED REl,IEF AND SUPPORTING ARGUMENTS

On April 23, 2021, Mr. Thygesen's counsel received a Request to Submit for Decision on

Ms. Wang's Ex Parte Request for Subpoena, in case# 180400131. See Exhibit A. Ms. Wang's
pleading alleges that the Ex parte Request for Subpoena was filed on April 23, 2021 with this

Court. Mr. Thygesen, as not a party to this action, is unsure if said motion was filed.

:Mr.Thygesen has not been served with the subpoena and respectfully requests that Kailin

Wang's Ex Parte Subpoena be quashed on the following basis: this case is closed, the subpoena

fails to comply with Utah Rules of Civil Procedure, Ms. Wang is using this case to circumvent

discovery orders in case #194400718 and that Ms. Wang can not issue subpoenas in her criminal

case on her own.

This Case Is Closed

A final order was entered in this case on May 7, 2018. Since that date, this case has been

closed and subpoenas or any other discovery would be inappropriate.

The Subpoena Fails to Comply With Utah Rules of Civil Procedure

Subpoenas are subject to notice requirements under Rule 5 of the Utah Rules of Civil

Procedure and Rule 45 of the Utah Rules of Civil Procedure. Here, Ms. Wang has filed an Ex Parte

Request for Subpoena which is inappropriate and not consistent with the rules. Ms. Wang is required

to serve all the litigants and persons subject to the subpoena and allow an appropriate time for each

party to review the subpoena and give each party an opportunity to object to the subpoena. This did

not and has not occurred.

Furthermore, it appears that this subpoena is an attempt to obtain information to be used in

case# 194400718. In that case, currently pending before Judge Low, is Mr. Thygesen's Statement

of Discovery related to Ms. Wang's improper subpoenas. Therefore, the court should not issue any

subpoenas in this case or any other cases involving Mr. Thygesen until Judge Low rules on Mr.

2
Thygesen' s Statement of Discovery related to Ms. Wang's improper subpoenas.

MEET AND CONFER REQUIREMENT AND PROPORTIONALITY

Mr. Thygesen's counsel has made requests on numerous occasions, in open court, to

Petitioner that she follow proper procedure, but Petitioner fails to cooperate. The request is

proportional under Rule 26(b)(2).

CONCLUSION

Therefore, based on the foregoing, Mr.Thygesen requests that the subpoena be quashed and

he be awarded his fees for filing this Statement of Discovery and Objection.

DATED: April 27, 2021.

OLSEN & OLSEN Attorneys at Law

/s/ Mitchell J. Olsen

MITCHELL J. OLSEN
Attorney for Mr. Thygesen

3
 CERTIFICATE OF SERVICE

I hereby certify that on April 27, 2021, I caused the foregoing OBJECTION AND

STATEMENT OF DISCOVERY to be electronically filed with the clerk of the above court using

the Utah Trial Court/ECF System, which sent notification of such filing, to the following:

Kailin Wang
voplan3 l [email protected]

/s/ Beau Olsen

4
 lMITCHELLJ. OLSEN
Utah State Bar No. 13826
OLSEN & OLSEN Attorneys at Law~LLC
Attorneys for Mr. Thygesen
8142 South Sr.ateStreet
Midvale, Utah 84047
Telephone: (801) 255-7176

IN 11:IE DISTRICT COURT OF THE FOURTH JUDICIAL DIS1RICT

IN AND FOR UTAH COUNTYc,STATE OF UTAH

lKAILIN WANG, lORDER QUASHING SUBPOENA

Petitioner,
lCivil No. 180400131
vs.
Judge Thomas Low
WALKERP. STONE,

Respondent.

THIS MATI'ER, having come before the Court pursuant to Mr. Thygesen's Objection

and Statement of Discovery to Ms. Wang's ex pane subpoenas, the Court having reviewed and

considered said Motion and all relevant materials in the file, and the Court being fully informed

in the premises, and for good cause shown therefor, HEREBY ORDERS:

That Ms. Wang's Ex Pane Subpoena is quashed.

END OF ORDER
••ENTERED ON mE DATE AND AS JNDJCATED
BYTHE SEAL or TIIE COURTAT TOP OF PAGE 1°

April 27, 2021 00:31 PM 1 of 2

 CERTIFICATE OF SERVICE

I hereby certify that on April 21, 2021J I caused the foregoing ORDER QUASIDNG
SUBPOENA, to be electronically filed with the clerk of the above court using the Utah Trial
Court/ECF System, which sent notification of such filing and to be emailed to the following:

Kailin Wang
[email protected]

/s/ Beau Olsen

April 27, 2021 03:31 PM 2 of 2

 4TH DISTRICT COURT - PROVO
UTAH COUNTY, STATE OF UTAH

CHRISTOFFER THYGESEN vs. KALIN WANG

CASE NUMBER 194400689 UCCJEA Child Cus Jur **** PRIVATE ****

CURRENT ASSIGNED JUDGE

DAROLD MCDADE

CURRENT ASSIGNED COMMISSIONER

MARIAN ITO

PARTIES
Petitioner - CHRISTOFFER THYGESEN
Represented by: BEAU OLSEN
Represented by: MITCHELL OLSEN
Represented by: MARTIN OLSEN
Represented by: BRYANT MCCONKIE

Respondent - KALIN WANG

ACCOUNT SUMMARY
Total Revenue Amount Due: 35.00
Amount Paid: 35.00
Amount Credit: 0.00
Balance: 0.00
REVENUE DETAIL - TYPE: JUDICIAL DOCUMENT AP
Original Amount Due: 35.00
Amended Amount Due: 35.00
Amount Paid: 35.00
Amount Credit: 0.00
Balance: 0.00

REVENUE DETAIL - TYPE: TELEPHONE/FAX/EMAIL

Original Amount Due: 22.50
Amended Amount Due: 0.00
Amount Paid: 0.00
Amount Credit: 0.00
Balance: 0.00
Account Adjustments Sum To Date Amount Reason
2019-09-06 -22.50 Account is being zeroed out as
the requestor never paid fee.

CASE NOTE
Backups: 194400711 CS; 194400718 PA; 194400734 PO

PROCEEDINGS
03-13-2019 **** PRIVATE **** Filed: : Certified California Order
03-13-2019 **** PRIVATE **** Filed: Petition: Verified Petition For
Expedited Enforcement of Child Custody Determination and
Registration of Child Custody Determination

11-21-2020 04:23 PM Page 1 of 4

11
MARTIN N. OLSEN
Utah State Bar No. 6015
BEAU J. OLSEN
Utah State Bar No. 15213
OLSEN & OLSEN, L.L.C.
Attorneys for Petitioner
8142 South State Street
Midvale, Utah 84047
Telephone: (801) 255-7176
[email protected]

IN THE DISTRICT COURT OF THE FOURTH JUDICIAL DISTRICT

IN AND FOR UTAH COUNTY, STATE OF UTAH

VERIFIED PETITION EXPEDITED

CHRISTOFFER THYGESEN, ENFORCEMENT OF CHILD
CUSTODY DETERMINATION AND
Petitioner, REGISTRATION OF CHILD
CUSTODY DETERMINATION
KALIN WANG,
Civil No.
Respondent.
Honorable
Commissioner

Petitioner, CHRISTOFFER THYGESEN, complains and for cause of action and alleges

against Respondent as follows:

RESIDENCY AND PROCEDURAL POSTURE

1. That the Petitioner is a resident of California.

2. That upon information and belief, Respondent is a resident of California or New

York.

3. That Petitioner resides at 294 Ewing Terrace, San Francisco, California 94118.
 2. That the Court grant Petitioner immediate physical custody of the minor child, if

the minor child is removed from his custody at the March 18, 2019 shelter hearing.

3. That the Court issue a writ of assistance that includes the following: (1) for law

enforcement to assist Petitioner in obtaining immediate physical custody of the minor child, if

the minor child is removed from Petitioner’s custody; (2) to allow Petitioner to accompany law

enforcement to obtain physical custody of the minor child, if the minor child is removed from his

custody; and, (3) for law enforcement to assist in ensuring the safety and well being of the minor

child, Respondent, Petitioner, and other interested parties.

4. That the Court and state of Utah enforce the Amended Temporary Restraining

Order and Child Custody Order (the California Protective Order).

5. That the Court schedule a hearing on the first day possible after service.

6. That if Respondent’s Utah counsel refuses to accept service, then an order

allowing Respondent to be served by email be issued.

DATED March 13, 2019.

OLSEN & OLSEN, L.L.C.

/s/ Martin N. Olsen

MARTIN N. OLSEN
Attorney for Petitioner
 VERIFICATION

CHRISTOFFER STANFORD THYGESEN, being first duly sworn, deposes and says

that he is the Petitioner in the above-entitled matter, that he has read the foregoing VERIFIED

PETITION EXPEDITED ENFORCEMENT OF CHILD CUSTODY DETERMINATION

AND REGISTRATION OF CHILD CUSTODY DETERMINATION and knows the

contents thereof, that the same is true to the best of his knowledge and belief under criminal

penalty under Utah Code § 78B-5-705 and the laws of the State of Utah.

/s/ Christoffer Stanford Thygesen

CHRISTOFFER STANFORD THYGESEN
(Signed by Martin Olsen with permission of
Petitioner via email 3/3/2010
Petitioner

Typo
suppose to
be
3/3/2019,
Thygesen
Hired a
Team of
Utah
Attorneys
before he
obtained Ex
Parte
Custody on
3/6/2019 in
San
Francisco

     
    
       
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that Father be awarded sole physical and legal custody of the child, (3) that Mother receive

written permission to travel with the child, (4) that California had jurisdiction to make custody

orders pursuant to the UCCJEA, (5) that Mother has a history of domestic violence, and (6) that

Father, with assistance of Utah Police or other appropriate authorities, was allowed to retrieve the

child.

On or about March 7, 2019, Father, under the guidance and direction of Utah DCFS and

CPS, obtained custody of the minor child from Mother’s parents. After obtaining custody, and

consistent with State statute, the State scheduled a shelter hearing for March 12, 2019. Out of

necessity, and with no other foreseeable way to obtain custody of the child, the Father worked

with Utah authorities to ensure the safety of the minor child. Now, the minor child is in the

custody of the Father and any outstanding custody issues should be resolved in California.

STATEMENT OF FACTS

1. The minor child was born on November 28, 2018. See Exhibit A.

2. The resident city of the Mother is Los Angeles, California. Id.

3. The resident State of Mother is California. Id.

4. On December 11, 2018, Mother filed for child support services and paternity in

the state of California. See County of Las Angeles v. Thygesen, Dept. Of Child

Support Services, case # 18CWCS16140 (Las Angeles Sup. Ct.) (“Paternity

Action”)

5. By Mother filing for child support services and paternity, she verified to the court

that she was a resident of Los Angeles County, State of California.

2
 IN THE FOURTH JUDICIAL DISTRICT COURT

IN AND FOR UTAH COUNTY, STATE OF UTAH

--oo0oo--

____________________________________
)
KAILIN WANG, )
)
Plaintiff, )
) Case No. 194400718
VS. )
)
CHRISTOFFER STANFORD THYGESEN, )
)
Defendant. ) TRANSCRIPT OF:
____________________________________) TEMPORARY ORDERS

BEFORE THE HONORABLE MARIAN ITO

Fourth District Court

137 North Freedom Boulevard
Provo, Utah 84601

October 18, 2019

1 Dad which we believe is significant in terms of a child this

2 age.

3 The next one, Your Honor, is the distance between the

4 Utah and the California Courts. Again, as we said before, it's

5 about a 12-hour drive. We're not sure how that really plays

6 into the analysis of the Court.

7 Next is the financial condition of the parties.

8 Neither party, Your Honor, is employed at this time and both of

9 their pleadings state the same. So there is equal financial

10 burden for both parties as it relates to the litigation of this

11 case.

12 THE COURT: Didn't your client in his pleadings

13 indicate that while he is unemployed, he is still able to

14 provide for his son --

15 MR. OLSEN: Uh-huh.

16 THE COURT: -- he is still able to pay for Mom to

17 have the supervised-parent time?

18 MR. OLSEN: Correct.

19 THE COURT: He's able to do these things but he

20 doesn't have a job?

21 MR. OLSEN: That's with the assistance of family and

22 friends. So it would go the same way for Mom. So however

23 she's getting out to California with the assistance of family

24 and friends. My client has been able to provide that

25 supervision as well as provide for the child with the

Noteworthy Reporting 801.634.5549 23

1 assistance of family and friends.

2 THE COURT: So what you're saying is he's living off

3 of the generosity of his family and friends?

4 MR. OLSEN: At this point, correct, Your Honor.

5 Correct. Which go both ways.

6 Next, Your Honor, as we relate to financial

7 circumstances, we talked about that. Agreement of the parties,

8 Your Honor, we addressed the email that she sent towards the

9 end of December where she says, you know, if we can't have

10 jurisdiction in New York, let's do it in California. That was

11 to counsel in California. So that email is in the record.

12 Counsel in California said, "We can do it in California." So

13 we would argue that -- that would be an agreement of the

14 parties to have jurisdiction in California. We do believe that

15 is relevant.

16 The nature and location of the evidence. And, Your

17 Honor, we think this is probably the most important and

18 probative evidence that the Court has before it as it relates

19 to an inconvenient forum.

20 Your Honor, the only thing that you have left in the

21 State of Utah that is both relevant and pertinent for ongoing

22 litigation would be the grandparents have a home in Spanish

23 Fork. Mom lives there, but it's not her home. Grandparents

24 live there. That's the only thing that you really have left in

25 the State of Utah that would be relative or probative for the

Noteworthy Reporting 801.634.5549 24

EXHIBIT 7
Per Declaration of Darrick T. Chase and Douglas Rappaport, filed on 10/03/19 and again
in October 2022 Erik Rasmussen Internet Expert Witness Thygesen hired Rasmussen for both
case FDV-19-814465 and People v. Wang 19016407

“Fees: Mr. Erik Rasmussen charged back in 2019 $485 per hour for consulting services
to the retaining attorney. Mr. Erik Rasmussen charged back in 2019 $700 per hour for
providing deposition testimony. Mr. Erik Rasmussen charges $700 per hour for providing
testimony at trial. For both depositions and trial testimony, travel expenses shall also be
charged. Payment is required in.”
Thygesen's
Substance of
Expert Hourly/Daily Rate
testimony
Witnesses

Was hired by Thygesen as

Erik K. Rasmussen, JD,
Expert Witness in Thygesen
CJSSP
Erik Rasmussen, v. Wang, Superior Court
Global Head of
CJSSP, JD for the State of California,
Cybersecurity and Risk
Global Head of Sau Francisco, 2019 (State Erik Rasmussen, CISSP, JD is a fonner Special Agent
Cyber Security Management Solutions
6 Cybersecurity $700/Hr. Family Law Case) AND for with the United States Secret Service with over 19 years of experience in fraud investigations.,
Expert Witness People ,,_Kailin Wang, Grobstein Teeple LLP
and Risk cybersecurity, aud computer forensics.
Los Angeles County
Management, Superior Court of California
6300 Canoga Avenue
GTLLP County of San Francisco,
Suite 1500W
2021
Woodland Hills CA 91367
(State Criminal Case)
11/22/23, 6:28 PM (2) Erik Rasmussen, CISSP, JD | LinkedIn
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on ’
Q. Home
::
My Network
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Jobs
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Messaging Notifications Me For Business
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’
p GROBSTEIN
--,'I TEEPLE

'''i
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Experience
Member
ICIT (Institute for Critical Infrastructure Technology) · Full-time
Sep 2023 - Present · 3 mos
Remote
Grobstein Teeple LLP
5 yrs 10 mos
• Principal (Equity), Head of Cybersecurity and Risk
Management Solutions
Full-time
Apr 2020 - Present · 3 yrs 8 mos
Los Angeles Metropolitan Area
• Principal, Head of Cybersecurity and Risk Managment
Solutions
Jun 2018 - Apr 2020 · 1 yr 11 mos
Greater Los Angeles Area
• Partner, Head of Cybersecurity and Risk Management
Solutions
Feb 2018 - May 2018 · 4 mos
Greater Los Angeles Area

Advisory Board Member

■ Flashpoint
Aug 2015 - Mar 2019 · 3 yrs 8 mos
Member
ASIS International
Feb 2018 - Feb 2019 · 1 yr 1 mo
Los Angeles, California
Managing Director
Kroll · Full-time
Jan 2016 - Dec 2017 · 2 yrs
Washington DC/Los Angeles
Show all 14 experiences ➔

Education
IEII The Citadel
Master of Science - MS, Leadership Studies
11.:11
2022
Student, The Graduate College
Seattle University School of Law
LI2000
Doctor of Law (JD)
- 2003
Show all 4 education ➔

Licenses & certifications

Private Security Agent (Security Guard)
Bureau of Security and Investigative Services
Issued Nov 2023 · Expires Nov 2025
https://www.linkedin.com/in/erik-rasmussen-cissp-jd-9b38977b/ 2/5
 The DA is using Thygesen's Privately Paid Expert
Witness, Erik Rasmussen by Allan Thygesen
President of Google America's using the Alleged
Victim Funded Investigator!

Wow, Chesa your office is using Google's own

expert witness Erik Rasmussen by Allan Thygesen
1 CHESA BOUDIN SBN 284577 President of Google America's for my Criminal
District Attorney Proceedings, talk about handouts, why isn’t your
2 DONALD du BAIN SBN 155131 office prosecuting the serious crimes in your own
Assistant District Attorney
3 350 Rhode Island Street city ?, but instead prosecuting me, a Utah resident
North Building, Suite 400N with No Criminal record, in efforts to help a Google
4 San Francisco, California 94103 Executive’s sons’ Child Custody Case??? You’ve
Telephone: 628-652-4184 spent over thousands of hours on my case, of your
5 Facsimile: 628-652-4001 office’s budget, of Tax Payer dollars, and there is
Email: [email protected]
6 not a single crime of physical violence, nor $ lost,
Attorneys for the People your office had my bail set at $750,000 with t help of
7 Google executive Allan Thygesen, now your also
IN THE SUPERIOR COUB using his personal $700/Hr. Expert Witness, Erik
8 Rasmussen as the Star Expert Witness for
IN AND FOR THE C
9 Prelim??? Unreal

10
THE PEOPLE OF THE STATE OF ) Court No.: 19016407
11 CALIFORNIA, )
) PEOPLE'S RESPONSE TO
12 Plaintiff, ) DEFENDANT'S MOTION TO
) COMPEL DISCOVERY
13 V. ) COMPLIANCE AND
) APPLICATION TO SEAL
14 KAILIN WANG, ) DECLARATION
)
15 Defendant. ) Date: August 19, 2021
Dept: 11
16 Time: 9:00 A.M.

17 STATEMENT OF THE CASE

18 Defendant's Motion to Compel Discovery, filed on August 9, 2021, asserts that the
prosecutor has failed to provide discovery in response to item 12(c) - (g) of her discovery
19
request, emailed on April 22, 2021 and attached as Exhibit A of her motion.
20
Defendant's Application to Seal Declaration in Support of Motion to Compel was also
21
filed on August 9, 2021.
22 The People's response to Defendant's informal discovery request, emailed on April 26,
2 3 2021, was attached as Exhibit B to Defendant's motion.
24 STATEMENT OF FACTS
Defendant's informal discovery request lists a number of individuals and organizatiom
25
under item 12(c)-(g). The only individuals listed who are potential witnesses either at the v
26
preliminary hearing or trial are Erik Rasmussen, who is an expert witness, and members of the
 Thygesen family. As explained in the People's informal response, all relevant written or
1 recorded statements of these witnesses, to the extent they exist, had already been discovered to

2 defense counsel at the time of her informal discovery request. Defense counsel has withdrawn
her request for communications and correspondence with Erik Rasmussen.
3
The other individuals listed are either attorneys or private investigators employed by the
4
Thygesen family. No attorney is expected to be called as a witness for the People. It is
5
theoretically possible that a listed, private investigator could be called as a witness for the People
6 at trial under Evidence Code section 1101(b) but the People are not in possession of any of their
7 recorded or written statements.

8 The organizations listed are other law enforcement agencies that have been involved in
the investigation of criminal activity in Utah or family law litigation between Christoffer
9
Thygesen and Defendant. All reports and recordings that have been provided to SFPD or SFDA
10
by those organizations had already been provided to defense counsel at the time of her informal
11
discovery request.
12 ARGUMENT
13 Prosecutor is not required to canvass sources or outside agencies for discovery

14 Penal Code section 1054.1 specifically defines the matters the district attorney must
disclose to the defendant. The prosecutor's obligation extends under this statute only to
15
information "in the possession of the prosecuting attorney or if the prosecuting attorney knows it
16
to be in the possession of the investigating agencies." (Ibid.)
17
Section 1054 et seq. dictates "an almost exclusive procedure for discovery in criminal
18 cases" in this state. [Citations.] It provides "the only means for [a] defendant to compel
discovery 'from prosecuting attorneys, law enforcement agencies which investigated or
19 prepared the case against the defendant, or any other persons or agencies which the
prosecuting attorney or investigating agency may have employed to assist them in
20 performing their duties.' "[Citation.] However, "[t]hese provisions do not regulate
discovery from third parties," which must be sought by way of subpoena duces tecum.
21
[Citations.]
22
(People v. Superior Court (Dominguez) (2018) 28 Cal.App.5th 223, 233.)
23
Hence the prosecutor has no general obligation to seek out information from other
2 4 agencies or sources for the benefit of the defense. (In re Little.field (1993) 5 Cal.4th 122, 135;

25 see, e.g., Rezek v. Superior Court (2012) 206 Cal.App.4th 633 [defense may use Pitchess
2 6 procedure to obtain witness statements in police personnel files when prosecutor does not
possess them].)
-------------------
From:
Sent:
du Bain, Donald (DAT)
Monday, April 26, 2021 5:07 PM
To:
Subject: Kailin Wang #19016407

1111
The following information is provided in response to your discovery request, which was emailed on 4/22/21:

Items numbers 1-11: All discoverable materials, which were provided to Bay Area Criminal Lawyers, consist of 3,150
pages of bate-stamped documents, CD-Rslabeled 1- 14, and DVD-Rslabeled A- M.

Item number "12. Additionally:"

(a) See page 3048 of bate-stamped discovery.
(b) See CD-R#14.
(c) Erik Rasmussen is likely to be retained as an expert for the People, but he has not yet provided any information
on the case to either SFPDor SFDA. I don't recognize any of the other names on your list as potential witnesses
for the Peo~le and, thus, communications with them are not discoverable under either Penal Code section
1054.1 or Brady.
(d) All relevant written or recorded statements between SFDA/SFPDand Christopher Thygesen involving Kailin
Wang have been provided i'n discovery. Other members of the Thygesen family are not currently expected to be
called as witnesses; furthermore, none of them has provided any relevant information that has not already been
provided in discovery.
(e) Not discoverable under either Penal Code section 1054.1 or Brady.
(f) Not discoverable under either Penal Code section 1054.1 or Brady .
. (g) Not discoverable under either Penal Code section 1054.1 or Brady.

Best regards,
Don du Bain

Donald du Bain
Assistant District Attorney
Office of the District Attorney
350 Rhode Island Street
North Building, Suite 400N
San Francisco, CA 94103
Tel: 415-558-2449
Email: [email protected]

The informatidn contained in this electronic message may be confidential and may be subject to the attomey-c!ient
privilege and/or the attorney work product doctrine. It is intended only for the use of the individual or entity to whom it is
addressed. ff you are not the intended recipient, you are hereby not{fied that any use, dissemination or copying of this
communication is strictly prohibited. ff you have received this electronic message in error, please delete the original
messagefi·om your e-mail .system. Thank you

1
1 DARRICK T. CHASE, ESQ. (CSB #151256)
KAYE•MOSER•HIERBAUM •FORD LLP
2 The Russ Building
235 Montgomery Street, 27th Floor
3 San Francisco, CA 94104
Telephone: (415) 296-8868
4 Facsimile: (415) 495-1771
Email: [email protected]
5
Attorneys for Petitioner
6 CHRISTOFFER STANFORD THYGESEN

9 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 IN AND FOR THE COUNTY OF SAN FRANCISCO

11
CHRISTOFFER STANFORD THYGESEN, ) Case No. FDV-19-814465
12 )
Petitioner, ) EXPlERT WITNESS DECLARATION
13 )
v. ) DATE: October 22, 23, 24, 31 and
14 ) Novt::mber7, 2019
) TIME: 9:00 a.m.
15 KAILIN WANG, ) LOCATION: Dept. 405
) TRIA.LJUDGE: Honorable Monica Wiley
16 Respondent. )
Chesa your office is using a victim funded
17
$700/hr. personal expert, as the star
18 witness for the trial????

19 To Kailin Wang,

20 I, Darrick T. Chase, declare as follows:

21 1. I am an attorney licensed to practice law in California. I am counsel of record for

22 Petitioner Mr. Christoffer Stanford Thygesen ("Mr. Thygesen") in this matter. I make this

23 declaration pursuant to Respondent Kailin Wang's Written Demand for Exchange of Expert

24 Witness Information served upon me by email on Septemb1;:r13, 2019, and pursuant to Co e of

25 Civil ProcedureSection2034.260c.

26 Erik Rasmussen CISSP

27 1. Qualification: Mr. Erik Rasmussen, CISSP ("Ivlr. Erik Rasmussen") is qualified to be

28 an expert in this matter. For information about Erik Rasmussen's qualifications, please see his

EXPERT WITNESS DECLARATION

I.
1 Curriculum Vitae attached hereto as Exhibit A.
2 2. Area of Expertise: I am informed and believe and thereon state that Mr. Erik

3 Rasmussen is an expert in the field of cybersecurity.

4 3. Substance of Testimony: Mr. Erik Rasmussen will be called to testify about:

5 Technical background on the internet and technology at issue in this case; Explanation of

6 methods for attributing anonymous postings/messages to individuals; Explanation and analysis of

7 computer data including subscriber information, login records, and IP address records, to include

8 both IPv4 and IPv6 addresses, provided by technology companies (websites/platforms, content

9 delivery networks, internet service providers, email providers, service providers) relating to the
10 identity of the person responsible for various internet postings and internet/email contacts.

11 Explanation and analysis of subpoenaed records and webfogs; geolocation tools; email addresses,

12 social media accounts, search engine optimization; anonymization services.

13 4. Agreement to Testify: Mr. Erik Rasmussen has agreed to testify as an expert at the

14 upcoming trial scheduled to commence at 9:00 a.m. on October 22, 2019 in Department 405 of

15 the San Francisco Superior Court.

16 5. Sufficient Familiarity: Mr. Erik Rasmussen will be sufficiently familiar with this

17 action to permit the other party to depose him in a meaningful way concerning the testimony he

18 is expected to give at trial, including his expected expert opinions and the basis of his expert

19 opinions.

20 6. Fees: Mr. Erik Rasmussen charges $485 IJ.erhour for consulting services to the

retaining attorney. Mr. Erik Rasmussen charges $700 per lh.ourfor providing deposition

testimony. Mr. Erik Rasmussen charges $700 per hour for providing testimony at trial. For both

depositions and trial testimony, travel expenses shall also be charged. Payment is required in

24
When the victim of an alleged crime contributes Thygesen's own Expert Witness to the costs
25 of the district attorney's investigation, ? such assistance to the prosecutor's office the
character and magnitude renders it unlikely that defendant will receive fair treatment during
26 all portions of the criminal proceedings.
27

28

EXPERT WITNESS DECLARATION

2.
1 advance of providing deposition or trial testimony.
2 I declare under penalty of perjury under the laws of the State of California that the

3 foregoing is true and correct, and that this declaration was executed on October 3, 2019 in San

4 Francisco, California.

5
6

8
9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
26

27

28

EXPERT WITNESS DECLARATION

3.
 1 DOUGLAS L. RAPPAPORT (SBN 136194)
Law Offices of Douglas L. Rappaport
2 260 California Street, Suite 1002
San Francisco, CA 94111
3 Telephone: 415-989-7900
Facsimile: 415-989-7950
4
Attorney for Petitioner
5 CHRISTOFFER STANFORD THYGESEN

6 SUPERlOR COURT OF THE STATE OF CALIFORNIA

7 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO

8
CHRISTOFFER STANFORD THYGESEN, Case No. FDV-19-814465
9
Petitioner, WITNESS LIST: EXHIBIT A TO
10 PETITIONER'S TRIAL BRIEF
V.
11
KAILIN WANG,
12
Respondent.
13 I
----------------
14
PETITIONER'S LIST OF POTENTIAL WITNESSES
15
The defense intends to call the following persons to testify in the trial of the above-captioned
16
matter, or their names may be mentioned in the testimony.
17
18 Immediate family members:

19 1. Christoffer Thygesen. Petitioner Christoffer Thygesen may be called to testify

20 about his interactions with Ms. Wang, his experiences parenting and caring for Baby K, the

21 impact of Ms. Wang's abuse, evidence authentication.

22 2. Allan Thygesen. Christoffer's father/ Baby K's grandfather. Mr. Allan Thygesen

23 may be called to testify about his interactions with Ms. Wang, his experiences grandparenting

and caring for Baby K, the impact of Ms. Wang's abuse, evidence authentication.
24
3. Terry Thygesen. Christoffer's mother/ Baby K's grandmother. Mrs. Terry
25
Thygesen may be called to testify about her interactions with Ms. Wang, her experiences
26
grandparenting and caring for Baby K, the impact of Ms. Wang's abuse, evidence authentication.
27
4. Elise Thygesen. Christoffer's sister/ Baby K's aunt. Ms. Elise Thygesen may be
28
called to testify about her interactions with Ms. Wang, the impact of Ms. Wang's abuse, her
-1-
1
([email protected]).
2
28. Stacey Jones. Christoffer's mother's former colleague. Ms. Jones may be called
3
to testify about the receipt of unwanted communications - and the content delivered to her-
4
via email aliases [email protected] and [email protected].
5
29. Caroline Lucas. Christoffer's mother's former colleague. Ms. Lucas may be called
6
to testify about the receipt of unwanted communications - and the content delivered to her -
7
via email aliases [email protected] and [email protected].
8
30. David Ackerman. Christoffer's mother's former colleague. Mr. Ackerman may be
9 called to testify about the receipt of unwanted communications - and the content delivered to
10 him -via email aliases [email protected] and [email protected].
11 31. Scott Saywell. Christoffer's mother's former colleague. Mr. Saywell may be
12 called to testify about the receipt of unwanted communications - and the content delivered to
13 him - via email aliases [email protected] and [email protected].
14 32. Sherwin Chen. Christoffer's mother's former colleague. Mr. Chen may be called
15 to testify about the receipt of unwanted communications - and the content delivered to him -
16 via email aliases [email protected] and [email protected].
17 Chesea this the same Expert Witness Google
Thygesen is using in our Child Custody Case,
18 Investigation: where I am in Pro Per
19 33. Alex Feerst. Mr. Feerst is the former Head of Legal at A Medium Corporation.

20 34. Justin Paine. Mr. Paine is the Director of Trust and Safety at Cloudflare.

21 35. Christopher Brenner. Mr. Brenner is a Director of Investigations at Hillard

22 Heintze.

23 36. Adam Zoll. Mr. Zoll is a Director of Investigations at Hillard Heintze.

24 37. Jennifer L. Mackovjak. Ms. Mackovjak is seasoned civil and criminal investigator

25 and leads Hillard Heintze's Investigations Practice.

26 38. Ellen McDonald. Ms. McDonald is a Senior Analyst at Hillard Heintze.

27 39. Erik Rasmussen. Erik Rasmussen is an expert in the field of cybersecurity. As

28 provided-in Petitioner Thygesen' s expert witness disclosure, Mr. Rasmussen may be called to

-5-
1
provide: Technical background on the internet and technology at issue in this case; Explanation
2
of methods for attributing anonymous postings/messages to individuals; Explanation and analysis
3
of computer data including subscriber information, login records, and IP address records, to
4
include both IPv4 and IPv6 addresses, provided by technology companies (websites/platforms,
5
content delivery networks, internet service providers, email providers, service providers) relating
6
to the identity of the person responsible for various internet postings and internet/email contacts.
7
Explanation and analysis of subpoenaed records and weblogs; geolocation tools; email addresses,
8 social media accounts, search engine optimization; anonymization services.
9 Respondent reserves the right to supplement this list and/or call other witnesses in rebuttal.
10
The above list of potential witnesses constitutes those that the defense intends to call as
11
of today's date. However, investigation continues, and as additional witnesses are discovered, the
12

13 names and addresses will be provided without de~la_,

14 DATED: October 15, 2019

15
Attorney for Petitioner
16
CHRISTOFFER STANFORD THYGESEN
17

18

19

20

21

22

23

24

25

26

27

28

-6-
 IN THE FOURTH JUDICIAL DISTRICT COURT

IN AND FOR UTAH COUNTY, STATE OF UTAH

--oo0oo--

____________________________________
)
KAILIN WANG, )
)
Plaintiff, )
) Case No. 194400718
VS. )
)
CHRISTOFFER STANFORD THYGESEN, )
)
Defendant. ) TRANSCRIPT OF:
____________________________________) TEMPORARY ORDERS

BEFORE THE HONORABLE MARIAN ITO

Fourth District Court

137 North Freedom Boulevard
Provo, Utah 84601

October 18, 2019

1 Dad which we believe is significant in terms of a child this

2 age.

3 The next one, Your Honor, is the distance between the

4 Utah and the California Courts. Again, as we said before, it's

5 about a 12-hour drive. We're not sure how that really plays

6 into the analysis of the Court.

7 Next is the financial condition of the parties.

8 Neither party, Your Honor, is employed at this time and both of

9 their pleadings state the same. So there is equal financial

10 burden for both parties as it relates to the litigation of this

11 case.

12 THE COURT: Didn't your client in his pleadings

13 indicate that while he is unemployed, he is still able to

14 provide for his son --

15 MR. OLSEN: Uh-huh.

16 THE COURT: -- he is still able to pay for Mom to

17 have the supervised-parent time?

18 MR. OLSEN: Correct.

19 THE COURT: He's able to do these things but he

20 doesn't have a job?

21 MR. OLSEN: That's with the assistance of family and

22 friends. So it would go the same way for Mom. So however

23 she's getting out to California with the assistance of family

24 and friends. My client has been able to provide that

25 supervision as well as provide for the child with the

Noteworthy Reporting 801.634.5549 23

1 assistance of family and friends.

2 THE COURT: So what you're saying is he's living off

3 of the generosity of his family and friends?

4 MR. OLSEN: At this point, correct, Your Honor.

5 Correct. Which go both ways.

6 Next, Your Honor, as we relate to financial

7 circumstances, we talked about that. Agreement of the parties,

8 Your Honor, we addressed the email that she sent towards the

9 end of December where she says, you know, if we can't have

10 jurisdiction in New York, let's do it in California. That was

11 to counsel in California. So that email is in the record.

12 Counsel in California said, "We can do it in California." So

13 we would argue that -- that would be an agreement of the

14 parties to have jurisdiction in California. We do believe that

15 is relevant.

16 The nature and location of the evidence. And, Your

17 Honor, we think this is probably the most important and

18 probative evidence that the Court has before it as it relates

19 to an inconvenient forum.

20 Your Honor, the only thing that you have left in the

21 State of Utah that is both relevant and pertinent for ongoing

22 litigation would be the grandparents have a home in Spanish

23 Fork. Mom lives there, but it's not her home. Grandparents

24 live there. That's the only thing that you really have left in

25 the State of Utah that would be relative or probative for the

Noteworthy Reporting 801.634.5549 24

 p GROBSTEIN
---. TEEPLE
FILED DATE: 2/15/2023 10:04 PM 2019CH00990

Erik K. Rasmussen, JD, CISSP

Global Head of Cybersecurity and Risk Management Solutions
Grobstein Teeple LLP
[email protected]

Areas of Expertise

Mr. Rasmussen oversees the cybersecurity and risk management solutions practice at the firm. Mr.
Rasmussen began his professional career as a deputy prosecuting attorney, then spent over nine (9)
years as a Special Agent with the Secret Service and several years in consulting and the financial
services industry. Mr. Rasmussen’s practice focuses on the following key areas:

• Cyber Risk Assessments – Mr. Rasmussen assists companies in maturing their

information security programs, incident response planning and mapping security controls
to frameworks like NIST, PCI or the CIS Critical Security Controls (CSCs) 20.
• Chief Information Security Officer (CISO) and Chief Security Officer (CSO)
Advisory Services – By serving as a virtual or consulting CISO/CSO, Mr. Rasmussen
helps companies create, implement, and review information security and physical security
policies and procedures, developing security elements like incident response teams and
insider threat programs, assisting in transitional hiring, conduct physical security
assessments and administer table top exercises and other simulations for measuring the
maturity of an organization’s security posture.
• Digital Forensics and Incident Response – Mr. Rasmussen has led hundreds of
investigations into network intrusions to steal payment cards, deploy ransomware, and
compromise data that is a risk to national security. Mr. Rasmussen is trained and
knowledgeable about mobile forensics, server/network forensics, general computer
forensics, cloud forensics and live forensics through the use of endpoint detection tools
and industry standard digital forensics software and tools.
• Penetration Testing – Mr. Rasmussen leads a team that conducts both internal and
external penetration testing to identify vulnerabilities and to generally system security,
conducts open-source intelligence gathering for testing or risk exposure, deep/dark web
searches, threat intelligence sharing for testing purposes, and “red team” / “purple team”
exercises.
• Expert Witness Consulting – Mr. Rasmussen provides expertise in both state and
federal legal proceedings by way of authoring court declarations, being deposed on behalf
of clients, preparing clients for litigation by advising on various cybersecurity matters,
and professional opinion/advice on forensic investigations or regulatory frameworks.
 Litigation Experience

• John Doe v. Serbian Orthodox Diocese of Western America, Superior Court for the State
FILED DATE: 2/15/2023 10:04 PM 2019CH00990

of California, Los Angeles, 2022 (State Civil Case).

• In the Matter of: First American Title Insurance Company, Respondent, New York State
Department of Financial Services, 2021 (State Civil Case).
• In Re: Marriott International Customer Data Security Breach Litigation, District of
Maryland, Southern Division, 2021 (Federal Civil Case).
• Honor Finance, LLC, Honor Finance Holdings, LLC v. Spireon, Inc., Superior Court of
the State of California, County of Orange, 2021 (State Civil Case).
• CMZ of Hawaii, Inc. v. Pacific Foundation, Inc., District of Hawai’i, 2021 (Federal Civil
Case).
o Testified by deposition.
• People v. Kailin Wang, Superior Court of California County of San Francisco, 2021
(State Criminal Case).
• United States v. Joshua Thomas Bales, Western District of Washington, 2021 (Federal
Criminal Case).
• Emmalee Forrester et al v. Clarenceville School District et al, Eastern District of
Michigan, 2020 (Federal Civil Case).
• Rachel Sims v. Little Rock Plastic Surgery P.A., Eastern District of Arkansas, 2020
(Federal Civil Case).
• Iacovacci v. Brevet Holdings et al, Southern District of New York, 2020 (Federal Civil
Case).
o Testified by deposition.
• Quid, Inc. v. Primer Technology, Inc. et al, Superior Court for the State of California, San
Francisco, 2020 (Arbitration).
o Testified by deposition.
• Danford v. Lowes, Western District of North Carolina, 2019 (Federal Civil Case).
• Mitchell v. Marketing Corporation of America d/b/a Fine Art Models, St. Clair County
Circuit Court, Michigan (State Civil Case).
o Testified at trial.
• Thygesen v. Wang, Superior Court for the State of California, San Francisco, 2019 (State
Family Law Case).
• In re Jonathan Edward Anderson and Amanda Marie Anderson / Jeremy W. Faith,
Chapter 7 Trustee, Plaintiff v. Samantha L. Caron and James S. Caron, Central District
of California, 2019 (Federal Bankruptcy Case).
• Waldbaum v. Slodzinski, et al. Circuit Court of Maryland, Baltimore City, 2019 (State
Civil Case).
• Laughlin v. Sinai Hospital, Circuit Court of Maryland, Baltimore City, 2018 (State Civil
Case).
• Chelsea Hamilton v. Wal-Mart Stores, Inc. et al, Central District of California, 2018
(Federal Civil Case).
• Ortolani v. Freedom Mortgage Corporation, Central District of California, 2018 (Federal
Civil Case).

5
 • Game of Drones: New Breach Detection Methods, IBM i2 Summit for a Safer Planet, Washington, DC,
September 2015.
• Best Practices in Cyber Threat Information Sharing, NG Security Summit, San Antonio, Texas, May 2015.
• Identifying and Mitigating Threats to E-Commerce Payment Processing, Visa Inc. Webinar, Ashburn, Virginia,
March 2015.
• The Lifecycle of Cybercrime, RSA, San Francisco, February 2013.
• The Faces of Fraud: An Inside Look at the Fraudsters and Their Schemes, RSA, San Francisco, February 2012.
• Electronic Crime and the Underground Economy, San Fernando Valley Chapter of the Institute of Internal
Auditors, Los Angeles, California, March 2008.

Expert Testimony and Court Experience

• In the Matter of First American Title Insurance Company, Respondent, New York State Department of Financial
Services, 2021 (State Civil Case).
• In Re: Marriott International Customer Data Security Breach Litigation, District of Maryland, Southern Division,
2021 (Federal Civil Case).
• Honor Finance, LLC, Honor Finance Holdings, LLC v. Spireon, Inc., Superior Court of the State of California,
County of Orange, 2021 (State Civil Case).
• CMZ of Hawaii, Inc, v. Pacific Foundation, Inc., District of Hawai'i, 2021 (Federal Civil Case).
• People v. Karlin Wang, Superior Court of California County of San Francisco, 2021 (State Criminal Case).
• United Slates v. Joshua Thomas Bales, Western District of Washington, 2021 (Federal Criminal Case).
• Emmalee Forrester et al v. Clarenceville School District et al, Eastern District of Michigan, 2020 (Federal Civil
Case).
• Rachel Sims v. Little Rock Plastic Surgery P.A., Eastern District of Arkansas, 2020 (Federal Civil Case).
• lacovacci v. Brevet Holdings et al, Southern District of New York, 2020 (Federal Civil Case).
• Quid, Inc. v. Primer Technology, Inc. et al, Superior Court for the State of California, San Francisco, 2020
(Arbitration).
• In Re: Riverside Christian Schools, Debtor/Todd A. Frealy, Chapter 7 Trustee, United State Bankruptcy Court,
Central District of California, Riverside Division, 2020 (Federal Bankruptcy Case).
• Danford v. Lowes, Western District of North Carolina, 2019 (Federal Civil Case).
• Mitchell v. Marketing Corporation ofAmerica d/bIa Fine Art Models, St. Clair County Circuit Court, Michigan
(State Civil Case).
• Thygesen v. Wang, Superior Court for the State of California, San Francisco, 2019 (State Family Law Case).
• In re Jonathan Edward Anderson and Amanda Marie Anderson I Jeremy W. Faith, Chapter 7 Trustee, Plaintiff v.
Samantha L. Caron and James S. Caron, Central District of California, 2019 (Federal Bankruptcy Case).
• Waldbaum v. Slodzinski, et al. Circuit Court of Maryland, Baltimore City, 2019 (State Civil Case).
• Laughlin v. Sinai Hospital, Circuit Court of Maryland, Baltimore City, 2018 (State Civil Case).
• Chelsea Hamilton v. Wal-Mart Stores, Inc. et al, Central District of California, 2018 (Federal Civil Case).
• Ortolani v. Freedom Mortgage Corporation, Central District of California, 2018 (Federal Civil Case).
• KCG Holdings v. Rohit Khandekar, Southern District of New York, 2017 (Federal Civil Case).
• Alexis v. Rogers, District Court for Southern California, 2017 (Federal Civil Case).
• United States v. Sergey Vovnenko, District of New Jersey, 2013 (Federal Criminal Case).
• United States v. Andriy Derkach, Eastern District of Virginia, 2012 (Federal Criminal Case).
• United States v. Robert Bentley, Northern District of Florida, 2007 (Federal Criminal Case).
• United States v. Marcus McGrath, Central District of California, 2007 (Federal Criminal Case).
• United States v. Kevin M. Dale, et. Al., Western District of Washington, 2006 (Federal Criminal Case).
 1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
2 FOR THE COUNTY OF SAN FRANCISCO
3 BEFORE THE HONORABLE MONICA F. WILEY, JUDGE PRESIDING
4 DEPARTMENT 405
5 Thygesen flew in Erik Rasmussen
6 IN RE: ) from Los Angeles for both of our
) DV Trials first in 2019, then in
7 CHRISTOPHER THYGESEN, ) 2022, and he also hired him for
)
8 PETITIONER, ) the San Francisco District
) Attorneys Office since 2019 See
9 vs. ) No.
SFDAFDV-19-814465
Donald A. Dubain
) Prosecutor disclosures
10 KAILIN WANG )
RESPONDENT. )
11 ___________________________________)
12
13
REPORTER'S TRANSCRIPT OF PROCEEDINGS
14
OCTOBER 22, 2019
15
16 APPEARANCES:

17 FOR PETITIONER: RAPPAPORT & SHERIDAN

By: DOUGLAS L. RAPPAPORT, ESQ.
18 260 California Street, Suite 1002
San Francisco, California 94111
19
20 KAYE MOSER HIERBAUM FORD, LLP
BY: DARRICK T. CHASE, ESQ.
21 235 Montgomery Street, FL 27
San Francisco, California 94104
22
23 FOR RESPONDENT: LAW OFFICE OF CHERIE WALLACE
By: CHERIE WALLACE, ESQ.
24 (SPECIAL APPEARANCE)
300 Montgomery Street, Suite 660
25 San Francisco, California 94104
26
27 ROCIO M. LOPEZ, CSR #11194
Official Court Reporter
28

NOT FOR REPRODUCTION PER GOVERNMENT CODE 69954(D)

 1

1 CASE NUMBER: FDV-19-814465

2 CASE NAME: Christopher S. Thygesen vs
3 Kailin Wang
4 San Francisco, CA October 22, 2019
5 DEPARTMENT 405 Hon. MONICA F. WILEY, Judge
6 REPORTER: ROCIO M. LOPEZ, CSR NO. 11194
7 TIME: a.m. Session
8 APPEARANCES:
9 Petitioner, CHRISTOPHER S. THYGESEN,
10 present with counsel, DOUGLAS RAPPAPORT,
11 and DARRICK T. CHASE, Attorneys at Law.
12 Respondent, KAILIN WANG, present with
13 counsel, CHERIE WALLACE, specially
14 appearing. Also present Erica Johnston.
15
16 THE COURT: We are on the record in the matter
17 of Christopher Thygesen and Kailin Wang. I would ask
18 counsel to please state your appearances for the record.
19 MR. RAPPAPORT: Good morning, Your Honor.
20 Douglas Rappaport on behalf Mr. Christopher Thygesen,
21 along with Erica Johnstone and Darrick Chase.
22 THE COURT: Good morning.
23 MS. WALLACE: Good morning, Your Honor.
24 Cherie Wallace appearing with Ms. Wang
25 especially. Your Honor, it is our intention to request
26 a continuance this morning.
27 THE COURT: I did receive yesterday an
28 Ex Parte request for a continuance in this matter, and I

NOT FOR REPRODUCTION PER GOVERNMENT CODE 69954(D)

 7

1 appears, she is moving to stay the proceedings according

2 to the heading of her motion. It is that she previously
3 knew that the San Francisco Police Department was
4 investigating her for crimes related to Mr. Thygesen.
5 She had said as much in her moving papers, she had a
6 Fifth amendment privilege at her deposition knowing that
7 she was being investigated.
8 She waived that Fifth amendment
9 privilege. So, consequently, to now stay the
10 proceedings because coincidently, she was arrested. She
11 knew she was being investigated. So this motion is not
12 quite so simple on its face.
13 And at the very least, it needs to be
14 briefed. However, I believe it should be denied quite
15 frankly. She should have told us very early on. I
16 asked her, "What is your intention? Are you" -- I said
17 question mark. "In light of your arrest, is it your
18 intention to proceed with trial on October 22nd?"
19 So consequently with no answer, we had to
20 have our expert witness who comes from Los Angeles to
21 fly up here to prepare -- he is prepared to testify.
22 We are all here for trial.
23 Had Ms. Wang simply sent an e-mail
24 saying, no. I'm arrested. I'm going to ask for a
25 continuance, we very well might have agreed, but today
26 is the day for trial. This has been set. This was set
27 on July 17th. She's known since -- she has known
28 subsequently that she's being investigated. In fact,

NOT FOR REPRODUCTION PER GOVERNMENT CODE 69954(D)

 The DA is using Thygesen's Privately Paid Expert Witness,
Erik Rasmussen by Allan Thygesen President of Google
America's using the Alleged Victim Funded Investigator!

Wow, Chesa your office is using Google's own expert witness

Erik Rasmussen by Allan Thygesen President of Google
America's for my Criminal Proceedings, talk about handouts,
why isn’t your office prosecuting the serious crimes in your
own city ?, but instead prosecuting me, a Utah resident with
1 CHESA BOUDIN SBN 284577
No Criminal record, in efforts to help a Google Executive’s
District Attorney sons’ Child Custody Case??? You’ve spent over thousands of
2 DONALD du BAIN SBN 155131
hours on my case, of your office’s budget, of Tax Payer
Assistant District Attorney
dollars, and there is not a single crime of physical violence, nor
3 350 Rhode Island Street
$ lost, your office had my bail set at $750,000 with t help of
North Building, Suite 400N
Google executive Allan Thygesen, now your also using his
4 San Francisco, California 94103
personal $700/Hr. Expert Witness, Erik Rasmussen as the
Telephone: 628-652-4184
Star Expert Witness for Prelim??? Unreal
5 Facsimile: 628-652-4001
Email: [email protected]
6
Attorneys for the People
7
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
IN AND FOR THE COUNTY OF SAN FRANCISCO
9

10
THE PEOPLE OF THE STATE OF ) Court No.: 19016407
11 CALIFORNIA, )
) PEOPLE'S RESPONSE TO
12 Plaintiff, ) DEFENDANT'S MOTION TO
) COMPEL DISCOVERY
13 V. ) COMPLIANCE AND
) APPLICATION TO SEAL
14 KAILIN WANG, ) DECLARATION
)
15 Defendant. ) Date: August I 9, 2021
Dept: 11
16 Time: 9:00 A.M.

17 STATEMENT OF THE CASE

18 Defendant's Motion to Compel Discovery, filed on August 9, 2021, asserts that the
prosecutor has failed to provide discovery in response to item 12(c)- (g) of her discovery
19
request, emailed on April 22, 2021 and attached as Exhibit A of her motion.
20
Defendant's Application to Seal Declaration in Support of Motion to Compel was also
21
filed on August 9, 2021.
22 The People's response to Defendant's informal discovery request, emailed on April 26,
23 2021, was attached as Exhibit B to Defendant's motion.
24 STATEMENT OF FACTS
Defendant's informal discovery request lists a number of individuals and organizatiom
25
under item 12(c)-(g). The only individuals listed who are potential witnesses either at the w
26
preliminary hearing or trial are Erik Rasmussen, who is an exRert witness, and members of the
 Thygesen family. As explained in the People's informal response, all relevant written or
1 recorded statements of these witnesses, to the extent they exist, had already been discovered to

2 defense counsel at the time of her informal discovery request. Defense counsel has withdrawn
her request for communications and con·espondence with Erik Rasmussen.
3
The other individuals listed are either attorneys or private investigators employed by the
4
Thygesen family. No attorney is expected to be called as a witness for the People. It is
5
theoretically possible that a listed, private investigator could be called as a witness for the People
6 at trial under Evidence Code section 1101(b) but the People are not in possession of any of their
7 recorded or written statements.

8 The organizations listed are other law enforcement agencies that have been involved in
the investigation of criminal activity in Utah or family law litigation between Christoffer
9
Thygesen and Defendant. All reports and recordings that have been provided to SFPD or SFDA
10
by those organizations had already been provided to defense counsel at the time of her informal
11
discovery request.
12 ARGUMENT
13 Prosecutor is not required to canvass sources or outside agencies for discovery

14 Penal Code section 1054. l specifically defines the matters the district attorney must
disclose to the defendant. The prosecutor's obligation extends under this statute only to
15
information "in the possession of the prosecuting attorney or if the prosecuting attorney knows it
16
to be in the possession of the investigating agencies." (Ibid.)
17
Section 1054 et seq. dictates "an almost exclusive procedure for discovery in criminal
18 cases" in this state. [Citations.] It provides "the only means for [a] defendant to compel
discovery 'from prosecuting attorneys, law enforcement agencies which investigated or
19 prepared the case against the defendant, or any other persons or agencies which the
prosecuting attorney or investigating agency may have employed to assist them in
20 performing their duties.' "[Citation.] However, "[tJhese provisions do not regulate
21 discovery from third parties," which must be sought by way of subpoena duces tecum.
[Citations.)
22
(People v. Superior Court (Dominguez) (2018) 28 Cal.App.5th 223, 233.)
23
Hence the prosecutor has no general obligation to seek out information from other
2 4 agencies or sources for the benefit of the defense. (In re Littlefield (1993) 5 Cal.4th 122, 135;

2 5 see, e.g., Rezek v. Superior Court (2012) 206 Cal.App.4th 633 [defense may use Pitchess

2 6 procedure to obtain witness statements in police personnel files when prosecutor does not
possess them].)
-------------------
From:
Sent:
du Bain, Donald (DAT)
Monday, April 26, 2021 5:07 PM
To:
Subject: Kailin Wang #19016407

1111
The following information is provided in response to your discovery request, which was emailed on 4/22/21:

lte ms numbers 1- 11: All discoverable materials, which were provided to Bay Area Criminal Lawyers, consist of 3,150
pages of bate-stamped documents, CD-Rslabeled 1 - 14, and DVD-Rslabeled A- M.

Item number "12. Additionally:"

(a) See page 3048 of bate-stamped discovery.
(b) See CD-R#14.
(c) Erik Rasmussen is likely to be retained as an exi:iert for the PeoRle, but he has not yet Rrovided any information
on the case to either SFPDor SFDA. I don't recognize any of the other names on your list as potential witnesses
for the People and, thus, communications with them are not discoverable under either Penal Code section
1054.1 or Brady.
(d) All relevant written or recorded statements between SFDA/SFPDand Christopher Thygesen involving Kailin
Wang have been provided in discovery. Other members of the Thygesen family are not currently expected to be
called as witnesses; furthermore, none of them has provided any relevant information that has not already been
provided in discovery.
(e) Not discoverable under either Penal Code section 1054,1 or Brady.
(f) Not discoverable under either Penal Code section 1054.1 or Brady.
. (g) Not discoverable under either Penal Code section 1054.1 or Brady.

Best regards,
Don du Bain

Donald du Bain
Assistant District Attorney
Office of the District Attorney
350 Rhode Island Street
North Building, Suite 4OON
San Francisco, CA 94103
Tel: 415-558-2449
Email: [email protected]

The injhrma1io11conlained in this electronic message may be confidential and may be subject to the atlomey-client
privilege and/or the alforney work product doctrine. ft is intended onlyfor lhe use of the indiv;dual or entity to whom U is
addressed. !jyou are not the intended recipienl, you are hereby not{fied that any use, dissemination or copying of this
communicalion is strictly prohibited. ljyou have received this electronic message in error, please delete the original
message.from your e-mail .\ystem. Thankyou

1
1 DARRICK T. CHASE, ESQ. (CSB #151256)
KA YE•MOSER•HIERBAUM •FORD LLP
2 The RussBuilding
235 Montgomery Street, 27th Floor
3 San Francisco, CA 94104
Telephone: (415) 296-8868
4 Facsimile: (415) 495-1771
Email: [email protected]
5
Attorneys for Petitioner
6 CHRISTOFFER STANFORD THYGESEN

9 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 IN AND FOR THE COUNTY OF SAN FRANCISCO

11
CHRISTOFFER STANFORD THYGESEN, ) Case No. FDV-19-814465
12 )
Petitioner, ) EXPlERTWITNESS DECLARATION
13 )
v. ) DATE: October 22, 23, 24, 31 and
14 ) November 7, 2019
) TIME: 9:00 a.m.
15 KAILIN WANG, ) LOCATION: Dept. 405
) TRIAL JUDGE: Honorable Monica Wiley
16 Respondent. )
Chesa your office is using a victim funded
17
$700/hr. personal expert, as the star
18 witness for the trial????

19 To Kailin Wang,

20 I, Darrick T. Chase, declare as follows:

21 l. I am an attorney licensed to practice law in California. I am counsel of record for

22 Petitioner Mr. Christoffer Stanford Thygesen ("Mr. Thyges,:n") in this matter. I make this

23 declaration pursuant to Respondent Kailin Wang's Written Demand for Exchange of Expert

24 Witness Information served upon me by email on September 13, 2019, and pursuant to Co e of

25 CivilProcedureSection2034.260c.

26 Erik Rasmussen, CISSP

27 l. Qualification: Mr. Erik Rasmussen, CISSP ("Mr. Erik Rasmussen") is qualified to be

28 an expert in this matter. For information about Erik Rasmussen's qualifications, please see his

EXPERTWITNESSDECLARATION
I.
1 Curriculum Vitae attached hereto as Exhibit A.
2 2. Area of Expertise: I am infonned and believe and thereon state that Mr. Erik
3 Rasmussen is an expert in the field of cybersecurity.
4 3. Substance of Testimony: Mr. Erik Rasmussen will be called to testify about:
5 Technical background on the internet and technology at issue in this case; Explanation of
6 methods for attributing anonymous postings/messages to individuals; Explanation and analysis of
7 computer data including subscriber information, login rec()rds, and IP address records, to include
8 both 1Pv4 and 1Pv6addresses, provided by technology companies (websites/platforms, content
9 delivery networks, internet service providers, email providers, service providers) relating to the
10 identity of the person responsible for various internet postings and internet/email contacts.
11 Explanation and analysis of subpoenaed records and webl,ogs;geolocation tools; email addresses,
12 social media accounts, search engine optimization; anonymization services.
13 4. Agreement to Testify: Mr. Erik Rasmussen hru::agreed to testify as an expert at the
14 upcoming trial scheduled to commence at 9:00 a.rn. on October 22, 2019 in Department 405 of
15 the San Francisco Superior Court.
16 5. Sufficient Familiarity: Mr. Erik Rasmussen wiU be sufficiently familiar with this

17 action to permit the other party to depose him in a meaningful way concerning the testimony he
18 is expected to give at trial, including his expected expert opinions and the basis of his expert
19 optruons.
20 6. Fees: Mr.Erik Rasmussen charges $485 per hour for consulting services to the
21 retaining attorney. Mr. Erik Rasmussen charges $700 per Utourfor providing deposition
22 testimon~. Mr. Erik Rasmussen charges $700 per hour for providing testimony at trial. For both
23 depositions and trial testimony, travel expenses shall also be charged. Pay:mentis required in
24
When the victim of an alleged crime contributes Thygesen's own Expert Witness to the costs
25 of the district attorney's investigation, ? such assistance to the prosecutor's office the
character and magnitude renders it unlikely that defendant will receive fair treatment during
26 all portions of the criminal proceedings.
27
28

EXPERT WITNESSDECLARATION
2.
1 advance of providing deposition or trial testimony.

2 I declare under penalty of perjury under the laws of the State of California that the

3 foregoing is true and correct, and that this declaration was executed on October 3, 2019 in San

4 Francisco, California.

5 I

8
9

IO
11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
26

27

28

EXPERT WITNESS DECLARATION

3.
 EXHIBIT 8
221B Partners, a Private Investigations Company a group of known Investigator hired by Thygesens
since December 2018-Present t falsely incriminate Wang. As part of their duties they capture tens of thousands
of pages of Page Vault Social Media Exhibits where Thygesen pays them hourly to Stalk my Twitter, Facebook,
Linkedin, and other Court Watcher, Reporters and Social Media Activity, including thousands of pages of
Social Media Activity that has nothing to do with Thygesen. These PI’s range from $300-$500/hr.

221B Partners, a Private Investigations Company made up of members from Jensen Hughes Formerly
Hillard and JENNIFER MACKOVJAK, PARTNER who Thygesen listed as one of the 7 Expert Witnesses
for Thygesen’s DV Trial per his Trial Brief filed on 10/15/19 has worked with the Thygesens continuously
since December 2018-Present.

221B Partners CHRIS BRENNER, SENIOR DIRECTOR has also worked for Thygesens since
December 2018-Present and was flown in by Thygesen from Chicago to appear in person for our DV Trial
10/18/22 through 10/20/22, he was present in the San Francisco Superior Court Dept. 416 for all three days.

221B Partners ADAM ZOLL, SENIOR DIRECTOR has worked for Thygesens since December
2018-Present, and has conducted Private Investigations, Skip Tracing, Pre-Texting for Thygesen including
obtaining Wang’s DMV records, Minors Birth Certificate before Christoffer’s DNA test came back, amongst
other PI activities.
11/22/23, 6:30 PM Who We Are — 221B Partners

HOME WHO WE ARE WHAT WE DO CONTACT US

BLOG/NEWS PRIVACY POLICY

WHO WE ARE

221B Partners works with clients across a range of industries to help

them solve problems by providing information and intelligence to
support their decision-making processes. Whether a client is
considering a complex business transaction or potential partnership,
interested in augmenting its legal strategy, or facing internal or
external business risks including fraud, competition, unfair market
practices, or virtual or actual threats to their brand integrity or
employees, 221B Partners can help. We design and implement
custom, legal and ethical research strategies to support successful
resolutions and outcomes.

OUR EXPERIENCE

Our partners’ backgrounds include more than 50-years’ combined

experience domestically and internationally across law enforcement,
journalism, public-interest research, and investigations consulting.
We hold undergraduate and advanced academic degrees in
criminal justice, public administration, Russian/Soviet studies, and
journalism.

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11/22/23, 6:30 PM Who We Are — 221B Partners

JENNIFER MACKOVJAK, PARTNER

There were moments when Jennifer was investigating

narcotics trafficking and violent crimes, insurance fraud,
identity theft, homicides and arresting suspects in major
crimes cases in New York City as a senior detective
investigator in the Manhattan District Attorney’s Office when
she would stop and remember her bookshelf as a young girl
in Cleveland. Lined across it were back-to-back copies of
books detailing the heroics and imaginative sleuthing of Leroy
Brown, the eponymous hero of the Encyclopedia Brown
mysteries which inspired her as a young reader.

READ MORE +

p: 312.810.6257 | e: [email protected] | l: LinkedIn

ANDREW KEITH, PARTNER

In the practice of corporate investigations, Andrew discovered

an unanticipated outlet for the tools he nurtured and relied on
as a restless expatriate and journalist more than two decades
ago. 221B Partners’ clients benefit from his tenacious curiosity
hitched to his storytelling ability. He combines these with the
professional and interpersonal improvisational skills, all of
which were developed as he navigated the fluid and shifting
social and economic landscape in Russia, where Andrew
began his career.

READ MORE +

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11/22/23, 6:30 PM Who We Are — 221B Partners

p: 312.806.6257 | e: [email protected] | l: LinkedIn

AMANDA MARIGLIANO, SENIOR DIRECTOR + OPERATIONS

MANAGER

Fortunate to have landed at an investigations firm early on in

her professional career, Amanda was taught and mentored
by some of the best investigators in the industry, including
221B founding partners, Jennifer and Andrew.

READ MORE +

p: 312.806.6257 | e: [email protected] | l: LinkedIn

CHRIS BRENNER, SENIOR DIRECTOR

Like his colleagues, Chris’ career path was influenced by early

exposure to fictional problem solvers including Encyclopedia
Brown, The Three Investigators, Sherlock Holmes and John
Grisham’s protagonists. When he wasn’t busy reading, you
could find Chris tinkering: He sent his first email over a 14.4
kbps modem, was providing “tech support” to family
members by first grade and, years later, programming his TI-
83+ graphing calculator to do his homework in high school. As
an investigator, he has been able to merge these interests.

READ MORE +

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11/22/23, 6:30 PM Who We Are — 221B Partners

ADAM ZOLL, SENIOR DIRECTOR

While others run from complexity, Adam races toward it. In a

career spent in corporate investigations and journalism, he
has always embraced the challenge of understanding and
communicating the deeper causes and dynamics at play in
any given situation.

READ MORE +

p: 312.806.6257 | e: [email protected] | l: LinkedIn

221B Partners
5547 North Ravenswood Avenue, Home
Suite 406
Who We Are
Chicago, Illinois 60640
What We Do
Map Us
Contact

221B Partners PLLC operates under Illinois Private Detective License No. 117-001844

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 1 DOUGLAS L. RAPPAPORT (SBN 136194)
Law Offices of Douglas L. Rappaport
2 260 California Street, Suite I 002
San Francisco, CA 94111
3 Telephone: 415-989-7900
Facsimile: 4 I 5-989-7950
4 ()Ci l 5 ZOl9
Attorney for Petitioner Cl.l:;i~KvF T~15 <.;Cur\T
5 CHRISTOFFER STANFORD THYGESEN NESTORPANELO ,
jjy ~ - oaputy C,11:rl(
6
SUPERIOR COURT OF THE STATE OF CALIFORNIA
7
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
8
CHRISTOFFER STANFORD THYGESEN, Case No. FDV-19-814465
9
Petitioner, TRIAL BRIEF
10
V.
11
KAILIN WANG,
12
Respondent.
13 I
----------------
14
1bis Trial Brief is offered pursuant to California Rule of Court 5.394.
15
I. Brief Summary of the Case
16
Background

Valentine's Day, 2018 was a day that would change Petitioner Christoffer Thygesen' s lite

forever. At twenty-five years old, he had recently graduated from Carnegie Mellon and moved from
19
the East Coast back to the San Francisco Bay Area where he began his first "real" job at a tech
20
company. He was lonely, and turned to Tinder, a dating/hook-up app. There, he connected with
21
Kailin Wang. Little did he know that Ms. Wang, who represented herself as an international tax
22
accountant in her late twenties, was in reality a thirty-six year old mentally ill serial stalker, obsessed
23
with having a baby with her victims.
24
In 2014 in New York, Ms. Wang was criminally charged after terrorizing her first victim,
25
Rory Will. According to court documents, Ms.Wang met Rory Will on Tinder-the same dating app
26
where she would later meet Petitioner--and after Mr. Will would not have unprotected intercourse
27

28

Trial Brief 1
 1 DOUGLAS L. RAPPAPORT (SBN 136194)
Law Offices of Douglas L. Rappaport
2 260 California Street, Suite 1002
San Francisco, CA 94111
3 Telephone: 415-989- 7900
Facsimile: 415-989-7950
4
Attorney for Petitioner
5 CHRISTOFFER STANFORD THYGESEN

6 SUPERIOR COURT OF THE STATE OF CALIFORNIA

7 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO

8
CHRISTOFFER STANFORD THYGESEN, Case No. FDV-19-814465
9
Petitioner, WITNESS LIST: EXHIBIT A TO
10 PETITIONER'S TRIAL BRIEF
V.
11
KAILIN WANG,
12
Respondent.
13 I

14
PETITIONER'S LIST OF POTENTIAL WITNESSES
15
The defense intends to call the following persons to testify in the trial of the above-captioned
16
matter, or their names may be mentioned in the testimony.
17
18 Immediate family members:

19 l. Christoffer Thygesen. Petitioner Christoffer Thygesen may be called to testify

20 about his interactions with Ms. Wang, his experiences parenting and caring for Baby K, the

21 impact of Ms. Wang's abuse, evidence authentication.

22 2. Allan Thygesen. Christoffer's father/ Baby K's grandfather. Mr. Allan Thygesen

23 may be called to testify about his interactions with Ms. Wang, his experiences grandparenting

24
and caring for Baby K, the impact of Ms. Wang's abuse, evidence authentication.

3. Terry Thygesen. Christoffer's mother/ Baby K's grandmother. Mrs. Terry

25
Thygesen may be called to testify about her interactions with Ms. Wang, her experiences
26
grandparenting and caring for BabyK, the impact of Ms. Wang's abuse, evidence authentication.
27
4. Elise Thygesen. Christoffer's sister/ Baby K's aunt. Ms. Elise Thygesen may be
28
called to testify about her interactions with Ms. Wang, the impact of Ms. Wang's abuse, her
-1-
 1
([email protected]).
2
28. Stacey Jones. Christoffer's mother's former colleague. Ms. Jones may be called
3
to testify about the receipt of unwanted communications - and the content delivered to her-
4
via email aliases [email protected] and [email protected].
5
29. Caroline Lucas. Christoffer's mother's former colleague. Ms. Lucas may be called
6
to testify about the receipt of unwanted communications - and the content delivered to her -
7
via email aliases [email protected] and [email protected].
8
30. David Ackerman. Christoffer's mother's former colleague. Mr. Ackerman may be
9
called to testify about the receipt of unwanted communications - and the content delivered to
10 him - via email aliases [email protected] and [email protected].
11 31. Scott Saywell. Christoffer's mother's former colleague. Mr. Saywell may be
12 called to testify about the receipt of unwanted communications - and the content delivered to
13 him - via email aliases [email protected] and [email protected].
14 32. Sherwin Chen. Christoffer's mother's former colleague. Mr. Chen may be called
15 to testify about the receipt of unwanted communications - and the content delivered to him -
16 via email aliases [email protected] and [email protected].
17

18 Investigation:

19 33. Alex Feerst. Mr. Feerst is the former Head of Legal at A Medium Corporation.
20 34. Justin Paine. Mr. Paine is the Director of Trust and Safety at Cloudflare.
21 35. Christopher Brenner. Mr. Brenner is a Director of Investigations at Hillard
22 Heintze.

23 36. Adam Zoll. Mr. Zoll is a Director of Investigations at Hillard Heintze.

24 37. Jennifer L. Mackovjak. Ms. Mackovjak is seasoned civil and criminal investigator
25 and leads Hillard Heintze's Investigations Practice.

26 38. Ellen McDonald. Ms. McDonald is a Senior Analyst at Hillard Heintze.

27 39. Erik Rasmussen. Erik Rasmussen is an expert in the field of cybersecurity. As

28 provided in Petitioner Thygesen's expert witness disclosure, Mr. Rasmussen may be called to

-5-
 1
provide: Technical background on the internet and technology at issue in this case; Explanation
2
of methods for attributing anonymous postings/messages to individuals; Explanation and analysis
3
of computer data including subscriber information, login records, and IP address records, to
4
include both IPv4 and IPv6 addresses, provided by technology companies (websites/platforms,
5
content delivery networks, internet service providers, email providers, service providers) relating
6
to the identity of the person responsible for various internet postings and internet/email contacts.
7
Explanation and analysis of subpoenaed records and web logs; geolocation tools; email addresses,
8
social media accounts, search engine optimization; anonymization services.
9
Respondent reserves the right to supplement this list and/or call other witnesses in rebuttal.
10
The above list of potential witnesses constitutes those that the defense intends to call as
11
of today's date. However, investigation continues, and as additional witnesses are discovered, the
12

13 names and addresses will be provided without de;,;;1

..a_,

14 DATED: October 15, 2019

15
Attorney for Petitioner
16
CHRISTOFFER STANFORD THYGESEN
17

18

19

20

21

22

23

24

25

26

27

28

-6-
 1

1 SUPERIOR COURT OF CALIFORNIA

2 COUNTY OF SAN FRANCISCO
3 BEFORE THE HONORABLE DANIEL FLORES, JUDGE PRESIDING
4 UNIFIED FAMILY COURT
5 DEPARTMENT 416
6 --o0o--
7
8 CHRISTOFFER STANFORD ) COURT NO. FDV-19-814465
THYGESEN, )
9 )
Petitioner, ) Pages 1 - 162
10 )
VS. ) Volume 1
11 )
KAILIN WANG, )
12 )
Respondent. )
13 )
)
14
15
16 Reporter's Transcript of Proceedings
17 Tuesday, October 18, 2022
18
19
20
21
22
23
24
25
26
27
28
 2

1 APPEARANCES OF COUNSEL:
2 For The Petitioner:
3 Law Offices of Douglas L. Rappaport,
260 California Street, Suite 1002
4 San Francisco, California 94111-4360
By: DOUGLAS LEE RAPPAPORT,
5 Attorney at Law
6 For The Petitioner:
7 Ridder, Costa & Johnstone, LLP.
440 N. Barranca Avenue, # 7750
8 Covina, California 91723
By: ERICA JOHNSTONE,
9 Attorney at Law
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
 9

1 sorry, what?
2 THE COURT: I did not ask you a question, Ms. Wang.
3 MS. WANG: Oh, okay.
4 THE COURT: We are getting a lot of feedback though.
5 MS. WANG: I don't have any other electronics on. No.
6 THE COURT: Okay. Can you leave your microphone on? No
7 feedback there.
8 MS. WANG: My microphone is on. Can you -- can you hear me
9 okay?
10 THE COURT: I can. I'm just trying to run a test to see if
11 I speak when your microphone is unmuted if that made a
12 difference. It doesn't seem to be corresponding with your
13 microphone. Okay. There is a gentleman sitting --
14 MS. WANG: Last time the --
15 THE COURT: There is a gentleman sitting at counsel table --
16 MS. WANG: I mean, if I turn off --
17 THE COURT: Ms. Wang, can you hear me?
18 MS. WANG: Let me try to turn this off and turn it right
19 back on? Okay? Let me.
20 THE COURT: Okay.
21 MS. WANG: I don't know. I -- I tried to lower the
22 microphone sound. The only thing I can think of is the
23 microphone, but Mr. Rappaport is incorrect. The Appellate Court
24 -- it was actually Justice Pollak that -- where the echo was
25 coming from last time, not me. So that's -- that's a lie.
26 THE COURT: Okay. I was waiting for you to finish doing
27 what you were doing, Ms. Wang. I have something I'm going to
28 address with someone other than you right now.
 10

1 Okay. There is a gentleman sitting --

2 MS. WANG: Okay.
3 THE COURT: -- at counsel table. You raised your hand when
4 I asked who was the person logged on as screen share. Would you
5 please identify yourself using the microphone?
6 MR. BRENNER: Hi, my name is Chris Brenner.
7 THE COURT: Thank you. Spell that, please?
8 MR. BRENNER: B-R-E-N-N-E-R.
9 THE COURT: First name?
10 MR. BRENNER: Chris -- Christopher, C-H-R-I-S-T-O-P-H-E-R.
11 THE COURT: Good morning to you. And --
12 MR. BRENNER: Good morning.
13 THE COURT: -- your role here today is?
14 MR. BRENNER: Assisting Mr. Rappaport and Ms. Johnstone with
15 technology.
16 THE COURT: Okay. Thank you.
17 And we have someone logged in. I think that's it.
18 Courtroom clerk, is that you, madam clerk?
19 THE CLERK: Yes, Your Honor.
20 THE COURT: Thank you. Appearances by counsel, please?
21 MR. RAPPAPORT: Good morning, Your Honor, Douglas Rappaport.
22 MS. JOHNSTONE: Good morning, Your Honor. Erica Johnstone.
23 THE COURT: Good morning.
24 MR. RAPPAPORT: On behalf of the protected parties who are
25 all -- who are all here in the courtroom.
26 THE COURT: Thank you. You can go ahead and name the people
27 who are in court, please, as protected parties.
28 MR. RAPPAPORT: Certainly I will. From left to right, we
 11

1 have Christoffer Thygesen, Terry Thygesen.

2 THE COURT: Good morning.
3 MR. RAPPAPORT: James -- James Thygesen.
4 THE COURT: Good morning.
5 MR. RAPPAPORT: Elise Thygesen.
6 THE COURT: Good morning.
7 MR. RAPPAPORT: Allan Thygesen.
8 THE COURT: Good morning.
9 MR. RAPPAPORT: And Emma Thygesen.
10 THE COURT: Good morning.
11 MR. RAPPAPORT: And in the back is Mr. Darrick Chase. He is
12 also counsel for Mr. Thygesen, albeit on the custody matter.
13 THE COURT: Thank you.
14 MR. RAPPAPORT: On the -- previously. I think he -- but he
15 does have a declaration should we need one here this morning.
16 That's why he is here from his previous work related to the
17 issuance of the subpoenas.
18 THE COURT: Thank you.
19 Okay. And Ms. Wang is present. Good morning.
20 MS. WANG: Good morning.
21 THE COURT: All right. Let's first address some procedural
22 things.
23 Okay. You've made a motion to continue the trial, Ms. Wang?
24 MS. WANG: Yes. I would like to make a record on some
25 points on that motion, if I may.
26 THE COURT: Thank you. I see that that motion or that
27 request has been stated a number of different ways including
28 something that's on my bench right now that appears to not have
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 EXHIBIT 9
Molly Amman, Stochastic Terrorism Expert Witness per Douglas Rappaports Declaration filed on
07/30/23 she is $500 hourly; or if on-site presence is requested a daily fee of $8,000. Molly Amman is hired by
Thygesen for the 3-Day Termination of Visitation even Supervised Evidentiary Hearing set for February 27, 29,
March 12, 2024, where Wang is forced to be Pro Se by Judge Roeca.
 II
DocuSign Envelope ID: 98E61D8C-36AF-4230-AA6C-D4A647232DD3

ELECTRONICALLY
1 DOUGLAS RAPPAPORT (136194)
LAW OFFICES OF DOUGLAS L. RAPPAPORT FILED
2 260 California Street, Suite 1002 Superior Court of California,
County of San Francisco
San Francisco, CA 94111
3 Telephone: (415) 989-7900 07/31/2023
Facsimile: (415) 989-7950 Clerk of the Court
BY: MARK ANTONIO
4 Email: [email protected] Deputy Clerk

5 Attorney for Petitioner,

CHRISTOFFER THYGESEN
6

7 SUPERIOR COURT OF THE STATE OF CALIFORNIA

8 FOR THE COUNTY OF SAN FRANCISCO
9

10
In re the Matter of: Case No.: FDV-19-814465
11
CHRISTOFFER THYGESEN DECLARATION OF DOUGLAS
12 RAPPAPORT RE PETITIONER’S
Petitioner, EXPERT TRIAL WITNESSES
13
and
14
KAILIN WANG,
15 Date: Sept 19 & 21, 2023
Respondent. Time: 1:45 p.m.
16 Dept.: 403
Judge: The Hon. Russell Roeca
17

18

19
20 I, DOUGLAS RAPPAPORT, declare:
21 1. I am the attorney of record for Petitioner in the above-entitled action. I make this
22 declaration pursuant to California Code of Civil Procedure Section 2034.260(c) and San
23 Francisco Local Rules of Court, Rule 11. 13(A).
24 Molly Amman
25 2. Qualification: Molly Amman is qualified to testify as an expert in this matter.
26 For information about Molly Amman’s qualifications, please see her Curriculum Vitae attached
27 hereto as Exhibit A.
28
1
In re the Matter of Thygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF DOUGLAS
RAPAPPORT
 II
DocuSign Envelope ID: 98E61D8C-36AF-4230-AA6C-D4A647232DD3

1 3. Area of expertise. I am informed and believe and thereon state that Molly
2 Amman is an expert in the field of behavioral threat assessment and management (BTAM). This
3 professional discipline is principally focused on preventing acts or attempted acts of planned,
4 interpersonal violence.
5 4. Substance of testimony. Ms. Amman will be called to testify about a category of
6 behavior that is unfamiliar to most but known in the threat assessment community as stochastic
7 violence.
8 5. Agreement to Testify: Ms. Amman has agreed to testify as an expert at the
9 upcoming trial scheduled to commence at 1:45 p.m. on September 19, 2023 in Department 403
10 of the San Francisco Superior Court.
11 6. Sufficient Familiarity: Ms. Amman will be sufficiently familiar with the pending
12 action to submit to a meaningful oral deposition concerning the testimony, including any opinion
13 and its basis, that she is expected to give at trial.
14 7. Fees: The hourly and daily fees of Molly Amman for providing deposition
15 testimony and for consulting with the retaining attorney are as follows: $500 hourly; or if on-site
16 presence is requested a daily fee of $8,000.

17 I declare under penalty of perjury under the laws of the State of California that the
18 foregoing is true and correct.

19
20 DATED: July 31, 2023
LAW OFFICES OF DOUGLAS RAPPAPORT
21

22

23 DOUGLAS L. RAPPAPORT
24
Attorney for Petitioner,
25 Christoffer Thygesen

26

27

28
2
In re the Matter of Thygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF DOUGLAS
RAPAPPORT
DocuSign Envelope ID: 98E61D8C-36AF-4230-AA6C-D4A647232DD3

MOLLY AMMAN, JD, CTM

3775 EP True Parkway, #262
West Des Moines, Iowa, 50265
www.mollyamman.com

BACKGROUND

Retired FBI profiler, attorney, and Certified Threat Manager Molly Amman is now engaged
in private practice, principally addressing matters such as behavioral threat assessment, threat
management, targeted violence prevention and analysis, domestic extremism, linguistic
assessment and interviewing, and corporate violence prevention programming and policy.

PROFESSIONAL EXPERIENCE

Private Consultant, West Des Moines, Iowa 2020 – Present

Expert in behavioral assessment, behavioral threat assessment and management, specializing
in workplace violence, public figure violence and threats, crisis threat assessment,
anonymous threats, stalking and extortion, domestic extremism, threat management planning,
and workplace violence policy and program development.

FBI Field Operations, West Des Moines, Iowa 2018 - 2020

Supervisory Senior Resident Agent
• Oversight of all operations pertaining to interagency threat assessment and response
matters, threat management coordination, domestic terrorism, and violent crime.
• Oversight of Joint Terrorism Task Force, Central Iowa Gang Task Force
• Chief FBI representative for western half of Iowa

FBI Behavioral Analysis Unit, Quantico, Virginia 2010 - 2018

Supervisory Special Agent
• Profiler
o Targeted violence and domestic terrorism assessment, mitigation and
prevention
o World-wide deployments to respond to completed attacks, protracted crises,
and provide training and engage in liaison with international partners
o Participated in empirical research in various threat assessment related topics
including linguistic analysis and mass attacks
• Program manager of targeted violence program to include case consultations,
training, and publications.
o Lead profiler, targeted violence program
o Submissions review committee, FBI Law Enforcement Bulletin
o Oversight of threat assessment curriculum at BAU
o FBI-wide workplace violence policy and program development team

Molly Amman, JD, CTM - 1

DocuSign Envelope ID: 98E61D8C-36AF-4230-AA6C-D4A647232DD3

FBI International Operations Division, Dakar, Senegal 2017

Acting Assistant Legal Attaché
• Assigned to the US Embassy in Dakar, Senegal, for 90 days in support of the FBI’s
missions abroad, covering an 11-country area of responsibility in West Africa
o Liaison with host nation law enforcement and intelligence agency executives
o Assistance with investigative matters pursuant to treaty obligations and host
nation needs
o Targeted violence training for host nation and other USG agencies in-country

FBI Special Events Management Unit, Quantico, Virginia 2008 - 2010

Supervisory Special Agent
• Planning and program management of FBI and interagency support to major
special events, relative to threat planning and crisis response, such as
Presidential inaugurations, major sporting championships and Olympic games
FBI Critical Incident Response Group, Quantico, Virginia 2008 – 2017
Assistant Division Counsel
• Collateral duty as division counsel; Acting Chief Division Counsel. Legal guidance
and policy matters for Tactical Program including Hostage Rescue Team and field
office SWAT assets, Counter IED Program, Special Maritime Operations program,
and extraterritorial operations.

FBI Academy Faculty, Quantico, Virginia 2006 - 2008

Supervisory Special Agent
• Faculty member at FBI Academy/adjunct faculty member at University of Virginia:
Instruction and course design: interviewing and interrogation, detection of deception,
counterterrorism, and law enforcement communication

FBI Albuquerque Field Office 2003 – 2006

Assistant Division Counsel
• Collateral duty as division counsel; Acting Chief Division Counsel 2006. Responsible
for legal guidance related to field office operations in criminal and national security
matters, as well as field office administrative matters.

FBI Field Operations 1998 - 2006

Special Agent
• Counterterrorism Division
• Albuquerque Field Office

PUBLICATIONS

Amman, M. & Meloy, J.R. (2022) Incitement to Violence and Stochastic Terrorism: Legal,
Academic, and Practical Parameters for Researchers and Investigators. Terrorism and
Political Violence; online 19 December 2022.

Molly Amman, JD, CTM - 2

DocuSign Envelope ID: 98E61D8C-36AF-4230-AA6C-D4A647232DD3

Huffman, M. & Amman, M. (2022) Violence in a Place of Healing: Weapons-Based Attacks

in Health Care Facilities. Journal of Threat Assessment and Management, online; print
forthcoming.

Amman, M., Burnette, A.G. & Crowley, B. (2022) A Review of Mass Stabbing Attacks
Between 2004 and 2017. Journal of Threat Assessment and Management, 9(2), 111–128.

Amman, M. & Meloy, J.R. (2021) Stochastic Terrorism: A Linguistic and Psychological
Analysis. Perspectives on Terrorism, 15(5).

Amman, M., Schouten, R., & Solov, R. Legal Issues in Threat Assessment. In J.R. Meloy &
J. Hoffman (Eds.), International Handbook of Threat Assessment, 2nd ed. New York, NY.
Oxford University Press.

Meloy, J.R., Amman, M., & Hoffman, J. Public Figure Stalking and Attacks. In J.R. Meloy
& J. Hoffman (Eds.), International Handbook of Threat Assessment, 2nd ed. New York, NY.
Oxford University Press.

St-Yves, M. & Amman, M. Les menaces anonymes: Évaluer le risque et démasquer l'auteur.
En L. Bibeau (Ed.), Évaluation de la menace et du risque - dans différents contextes de
violence. Éditions Yvon Blais, Thomson Reuters. 313-345.

Amman, M. (2018). Commentary: A Review of Dispensation of Dynamite. Journal of Threat

Assessment and Management, 5(4), 248–249.

Amman, M. & MacKizer, M. (2017). The Boy in the Bunker: A Crisis Threat Assessment.
Journal of Threat Assessment and Management, 4(2), 77–97.

Behavioral Analysis Unit (2017). Making Prevention a Reality: Identifying, Assessing, and
Managing the Threat of Targeted Attacks. U.S. Department of Justice

Meloy, J.R. & Amman, M. (2016). Public Figure Attacks in the U.S. 1995-2015. Behavioral
Sciences and the Law. 34: 622– 644

CERTIFICATIONS

Behavioral Profiler, FBI

Certified Threat Manager, ATAP
Attorney at Law, Iowa, USA

MEMBERSHIPS

Association of Threat Assessment Professionals

Current Chair, National Certification Program
Past Chair, Bylaws
Past Secretary, Association Board of Directors

Molly Amman, JD, CTM - 3

DocuSign Envelope ID: 98E61D8C-36AF-4230-AA6C-D4A647232DD3

Canadian Association of Threat Assessment Professionals

Iowa State Bar Association
FBI Agents Association
Federal Law Enforcement Officers Association
Society of Former Special Agents of the FBI

SELECTED CONFERENCE PRESENTATIONS AND INVITED LECTURES

Workshop, “Threat Assessment and Management Fundamentals” Canadian Association of

Threat Assessment Professionals Annual Conference, Two Day Workshop, Whistler, British
Columbia, October 16-17, 2022.

Presentation: “Stochastic Terrorism: A Legal and Psychological Analysis.” Canadian

Association of Threat Assessment Professionals Annual Conference, Whistler, British
Columbia, October 18, 2022.

Presentation: Violence in a Place of Healing: Weapons-Based Attacks in Health Care

Facilities. Association of Threat Assessment Professionals, Threat Management Conference,
Anaheim, California, August 9, 2022.

Presentation, “Core Competencies: Legal Issues in Threat Assessment,” Association of

Threat Assessment Professionals, Threat Management Conference, Anaheim, California,
August 10, 2022.

Keynote Presentation, Everyday Superheroes: Threat Assessment Basics and the Race to
Prevent Violence. Montana State University and Association of Threat Assessment
Professionals, April 27, 2022.

Presentation, The First 24 Hours: Threat Assessment Triage. Canadian Association of

Threat Assessment Professionals, virtual, November 4, 2021.

Presentation, A User’s Guide to Privacy Law: Navigating Threat Assessment Challenges.

Association of Threat Assessment Professionals, virtual, August 4, 2021.

Presentation, Authoritarian Followership and Violence. Association of Threat Assessment

Professionals Northeast Chapter, virtual, July 15, 2021.

Conference Facilitator, Navigating the Lawless Frontier: Expert Sessions on the Online
Threatscape, Two Day Conference. Canadian Association of Threat Assessment
Professionals, virtual, March 23-24, 2021.

Presentation, Conspiracy Theorism in the Internet Melting Pot. Canadian Association of

Threat Assessment Professionals, virtual, March 24, 2021.

Molly Amman, JD, CTM - 4

DocuSign Envelope ID: 98E61D8C-36AF-4230-AA6C-D4A647232DD3

Presentation, Threat Assessment in the Age of Everything: Taking Stock of 2020. Great
Plains Chapter, Association of Threat Assessment Professionals, virtual, December 8, 2020.

Presentation, “90 Days in Africa: Distinguishing Fact from Fiction in Cross Border Threat
Assessment,” African Association of Threat Assessment Professionals, virtual, August 28,
2020

Keynote Address, “Assessing the Threat of Targeted Violence,” Zone 5 Fairs and Expos
Annual Conference, Des Moines, Iowa, February 29, 2020.

Workshop, “Assessment of Anonymous Communicated Threats” Canadian Association of

Threat Assessment Professionals Annual Conference, Two Day Workshop, Niagara-on-the-
Lake, Ontario, November 13-14, 2019.

Keynote Address, “Lone Offender Assessment: Risk Factors and Warning Signs,” Iowa
Emergency Management Conference, Ankeny, Iowa, October 31, 2019.

Presentation, “Core Competencies: Legal Issues in Threat Assessment,” Association of

Threat Assessment Professionals, Threat Management Conference, Anaheim, California,
August 14, 2019

Presentation, “90 Days in Africa: Distinguishing Fact from Fiction in Cross Border Threat
Assessment,” Canadian Association of Threat Assessment Professionals Annual Conference,
Whistler, British Columbia, October 16, 2018

Presentation, “Core Competencies: Legal Issues in Threat Assessment,” Association of

Threat Assessment Professionals, Threat Management Conference, Anaheim, California,
August 15, 2018

Presentation, “The Boy in the Bunker: A Hostage Barricade Crisis Case Study,” Canadian
Association of Threat Assessment Professionals, Regional Conference, Halifax, Nova Scotia
(virtual), May 31, 2018

Keynote Address, “Making Prevention A Reality,” Big Ten Threat Assessment Conference,
Iowa City, Iowa, June 12, 2018

Presentation, “Assessing Violence Potential in Threatening Communications,” US

Department of State Regional Security Office, Private Sector Conference, Dakar, Senegal,
October 18, 2017

Presentation, “Making Prevention a Reality: A New Behavioral Analysis Guide”

Association of Threat Assessment Professionals, Threat Management Conference, Anaheim,
California, August 16, 2017

Molly Amman, JD, CTM - 5

DocuSign Envelope ID: 98E61D8C-36AF-4230-AA6C-D4A647232DD3

Presentation, “Core Competencies: Legal Issues in Threat Assessment,” Association of

Threat Assessment Professionals, Threat Management Conference, Anaheim, California,
August 16, 2017

Presentation, “The Happy Goodbye: Planning Safe and Forward-Thinking Terminations and
Expulsions,” Canadian Association of Threat Assessment Professionals Annual Conference,
Whistler, British Columbia, October 26, 2016

Presentation, “The Results of a New Study Concerning Attacks Against Public Figures
Attacks in the United States,” Canadian Association of Threat Assessment Professionals
Annual Conference, Whistler, British Columbia, October 26, 2016

Presentation, “The Happy Goodbye: Planning Safe and Forward-Thinking Terminations and
Expulsions,” Association of Threat Assessment Professionals, Great Plains Conference,
Omaha, Nebraska, October 20, 2016

Presentation, “Behavioral Threat Assessment Principles,” 2016 Domestic Terrorism

Seminar, US Department of Justice National Advocacy Center, Columbia, South Carolina,
September 28, 2016

Presentation, “Targeted Violence: Judicial Personnel Attacks,” Virginia Judicial

Conference, Norfolk, Virginia, September 20, 2016

Presentation, “The Results of a New Study Concerning Attacks Against Public Figures
Attacks in the United States,” Association of Threat Assessment Professionals, Threat
Management Conference, Anaheim, California, August 17, 2016

Presentation, “Core Competencies: Legal Issues in Threat Assessment,” Association of

Threat Assessment Professionals, Threat Management Conference, Anaheim, California,
August 18, 2016

Presentation, “Behavioral Analysis Unit Methods: Assessing Violence Concern in

Communications” Association of European Threat Assessment Professionals Annual
Conference, Ghent, Belgium, April 26, 2016

Presentation, “The Boy in the Bunker: Crisis Threat Assessment,” Canadian Association of
Threat Assessment Professionals Annual Conference, Lake Louise, Alberta, October 18,
2015

Presentation, “Keeping it Safe: Dealing with the Potentially Violent,” Richmond Bench-Bar
Conference, Richmond, Virginia, October 13, 2015

Presentation, “Targeted Violence and Healthcare Institutions,” Association of Threat

Assessment Professionals, Threat Management Conference, Anaheim, California, August 11,
2015

Molly Amman, JD, CTM - 6

DocuSign Envelope ID: 98E61D8C-36AF-4230-AA6C-D4A647232DD3

Session Address, “Threat Management and Legal Realities,” Symposium: The Power of
Prevention: Threat Management Strategies to Disrupt Targeted Shootings, Charlottesville,
Virginia, July 27, 2015

Keynote Address, “Targeted Violence and Homegrown Radical Extremist Violence,” Police
Nationale de France/Gendarmerie Nationale de France, Antiterrorism Conference, Paris,
France, June 18, 2015

Presentation, “Assessing the Potential Active Shooter,” Pentagon Force Protection Agency,
Protective Intelligence Conference, Washington, D.C., June 3, 2015

Workshop Series, Workplace Violence Assessment and Management, US Postal Inspection

Service, Orlando, Florida, January – March 2015

Presentation, “Active Crisis Threat Assessment and Management: “The Boy in the Bunker”
Hostage Crisis,” Association of Threat Assessment Professionals, Threat Management
Conference, Anaheim, California, August 15, 2014

EDUCATION
JD Drake University School of Law May 1996
Cum Laude
Editor: Drake Journal of Agriculture Law
BA University of Iowa May 1993

PRO BONO ACTIVITY

Association of Threat Assessment Professionals:
Certification program leadership. Core competencies instruction
Canadian Association of Threat Assessment Professionals:
Threat assessment and management fundamentals workshops and instruction

Molly Amman, JD, CTM - 7

 EXHIBIT 10
Two more experts see 01/09/23 Declaration of J. REID MELOY, PhD, ABPP,
FORENSIC PSYCHOLOGIST who will testify against Wang on VIOLENCE RISK & THREAT
ASSESSMENT OF KAILIN WANG, and ROBERT L. KAUFMAN, PHD, ABPP.
J. Reid Meloy works extensively with Molly Amman and has reviewed thousands of
pages of hearsay falsified material for Thygesen’s request with Judge Flores on 01/09/23 for an
Evidentiary Hearing for Termination of All Visitation even Supervised, that request was
DENIED on 02/23/23 (Order entered on 04/06/23). J. Reid Meloy was also hired by Thygesen
for the Criminal Case People v. Wang 19016407 as stated on J. Reid Meloy’s CV on his
website. https://drreidmeloy.com/bio/cv/
US. v. Buster Hernandez (2020-2021}retained by the prosecution. Testified at sentencing in federal court, Southern District of Indiana. Sentenced
to 75 years in prison.

People v. Mohamed Mohamed (2020-2022)-retained by prosecution in lone actor terrorism case.

Defendant found NGRI.

Chamblee v. Baltimore Sun et al. (2021-2022) retained by plaintiffs in civil case resulting from mass murder at the Capital-Gazette, Annapolis,
Maryland, in June, 2018. Deposed. Settled.

People v. Kailin Wang (2022· ) retained by attorneys on a civil custody case and criminal stalking case.

Thygesen plans to re-litigate similar allegations before Judge Roeca in the upcoming Termination of all
Visitation even Supervised set for 2/27, 02/29, 03/12/24.
 i https:j/drreidmeloy .com/bio/ $ c!:l *
Proposition 115 -... :@ Unzueta V. Akopy... .• Healthy u Medicai... !,; 2022 FLRC Attend... lbvnl EFF and SB Count... 0 MASTER POST OF... m Geometric Pattern ...

Dr. Reid Meloy Bio Press & Publications Books Services Presentations Training

Dr. Reid Meloy is a board-certified forensic psychologist (ABPP}and consults on criminal

and civil cases throughout the U.S. and Europe. He is a former clinical professor of
psychiatry at the University of California, San Diego, School of Medicine, and a faculty
member of the San Diego Psychoanalytic Center. He is a fellow of the American Academy of
Forensic Sciences and is past president of the American Academy of Forensic Psychology.
He has received a number of awards and honors, including the first National Achievement
Award in 1998 from the Association of Threat Assessment Professionals, the Manfred
Guttmacher Award from the American Psychiatric Association in 2021, and the
Distinguished Contribution to Forensic Psychology Award from the American Academy of
Forensic Psychology in 2022. He was the Yochelson Visiting Scholar at Yale University in
2015, and Visiting Scholar at the Psychiatric University Hospital Zurich-originally the
Burgholzli Clinic-in 2018. Dr. Meloy has authored or co-authored over two hundred fifty
papers published in peer-reviewed psychiatric and psychological journals, and has
authored, co-authored or edited thirteen books.

He has been consulting, researching and writing about personality disorder, psychopathy,
stalking, narcissism, criminality, mental disorder, and targeted violence for the past thirty
years. His first book, The PsY.chogathicMind (Aronson, 1988), was an integration of the biological and psychodynamic understanding of
psychopathy. His co-edited book with Drs. Hoffmann and Sheridan, Stalking, Threatening and Attacking Public Figures (Oxford University Press,
2008), led to a commissioned study for the National Academy of Sciences on threats toward public figures published in 2011 ( www.nap.edu ). The
first edition with Dr. Hoffmann of the International Handbook of Threat Assessment was published in 2014, and the second edition in 2021 (Oxford
University Press). Dr. Stephen White and he created the WAVR-21( www.wavr21.com ), a widely utilized structured professional judgment
instrument for targeted workplace and campus violence, now in its third edition.

Dr. Meloy has been a consultant on criminal, counterintelligence, and counterterrorism cases for the Behavioral Analysis Unit, FBI, Quantico, for the
past twenty-one years. His counterterrorism work began when he was retained as the consulting forensic psychologist by the U.S.Attorney General
in the prosecution of the defendants Mcveigh and Nichols in the Oklahoma City bombing cases. He is the originator and developer of the TRAP-18
(Terrorist Radicalization Assessment Protocol; mhs.com), a validated risk assessment instrument used by counterterrorism professionals in North
America, Europe and Australia. He was a member of the Fixated Research Group for the United Kingdom's Home Office concerning threats to the
Royal Family and British political figures, which led to the development of the Fixated Threat Assessment Center (fixatedthreat.com); and is a
consulting member of Work Trauma Services, Inc., headquartered in San Francisco, and Team Psychology and Security in Darmstadt, Germany. He
I f I inP <..n i~tP P • r nf hP I I I T rP Ai::. PC:.<.. P t PPm nt n v • tP ·ttP v -_P P Yi rk
 II
DocuSignEnvelopeID: EC14DCDF-7F33-4F3B-95E4-961E3ED6BB03

MICHAEL REEDY (161002)

McMANIS FAULKNER ELECTRONICALLY
2 a Professional Corporation FILED
50 West San Fernando Street, 10th Floor Superior Court of California,
County of San Francisco
3 San Jose, California 95113
Telephone: (408) 279-8700 01/09/2023
4 Facsimile: (408) 279-3244 Clerk of the Court
Email: [email protected] BY: TIM KYU
Deputy Clerk
5
DOUGLAS RAPPAPORT (136194)
6 LAW OFFICES OF DOUGLAS L. RAPPAPORT
260 California Street, Suite 1002
7 San Francisco, CA 94111
Telephone: (415) 989-7900
8 Facsimile: (415) 989-7950
Email: [email protected]
9 Attorneys for Petitioner,
CHRISTOFFER THYGESEN
10

11 SUPERIOR COURT OF THE STATE OF CALIFORNIA

12 FOR THE COUNTY OF SAN FRANCISCO
13

14

15 In re the Matter of: CaseNo.: FDV-19-814465

16 CHRISTOFFER THYGESEN DECLARATION OF J. REID MELOY,

PhD, ABPP, FORENSIC PSYCHOLOGIST
17 Petitioner, RE: PRELIMINARY FINDINGS;
VIOLENCE RISK & THREAT
18 and ASSESSMENT OF KAIL.IN WANG

19 KAILINWANG, Date: January 23, 2023

Time: 9:00AM
20 Respondent. Dept.: 404

21

22

23
24 Ill

25 Ill

26 Ill

27 Ill

28 Ill

In re the MatterofThygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF J. REID MELOY

 II
DocuSign Envelope ID: EC14DCDF-7F33-4F3B-95E4-961E3ED68603

I, J. Reid Meloy, do hereby declare:

2 I. You have requested from me an analysis and opinions regarding violence risk and
3 threat assessment of Ms. Kail in Wang in reference to her civil case in San Francisco Superior

4 Court. This is a declaration regarding my credentials, methodology in this particular case,

5 preliminary findings, and further needed information for me to complete such an undertaking.

6 2. I am a licensed psychologist in California since 1982, and a board-certified

7 forensic psychologist (American Board of Professional Psychology) since 1991. I have expertise

8 in criminal forensic psychology, and have been consulting, teaching, testifying, researching, and

9 preparing scientific studies and books in the following areas for the past thirty years:

10 psychopathy, stalking, targeted violence, the relationship of mental disorder to criminality, and

1I other topics at the nexus between psychology and the criminal law. I have published over 250

12 science articles in peer reviewed journals and 13 books, the first one being The Psychopathic

13 Mind (Aronson, 1988) and most recently, the International Handbook of Threat Assessment, 2nd

14 edition (Oxford University Press, 2021) which won the Manfred Guttmacher Award from the
15 American Psychiatric Association this year. I was also awarded the Distinguished Contributions

16 Award from the American Academy of Forensic Psychology this year. I am a former clinical

17 professor of psychiatry (voluntary status) at the University of California, San Diego, School of

18 Medicine, and a current faculty member of the San Diego Psychanalytic Center. For the past

19 twenty years I have been a consultant to the Behavioral Analysis Unit, FBI, Quantico.
20 3. I have reviewed a voluminous amount of data on Kailin Wang, with a particular

21 focus on the last decade of her life, and also her adolescence. The documentation will not be

22 detailed here, but consists of hundreds of documents-incl1.1ding law enforcement investigative

23 reports and trial transcripts--and thousands of pages of evidence of which you are aware

24 regarding her current and past behaviors. Following a review of this material which consists of

25 I) her productions, as well as 2) others' behaviors and opinions in rel,:l.tionshipto Ms. Wang, my
26 violence risk and threat assessment has focused upon her psychopathy (a constellation of

27 behaviors and traits that are stable and enduring, and reflect both an aggressive narcissism and a

28 callous disregard for others) and her stalking of at least three known male victims over the past
2
In re the Matter ofThygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF J. REID MELOY
 II
DocuSignEnvelopeID: EC14DCDF-7F33-4F38-95E4-961E3ED6BB03

decade. The assessment considers both her online as well as her on the ground behaviors.

2 4. I have arrived at several preliminary opinions which continue to be formulated

3 and refined as I move forward with my analysis and examination of the data.

4 5. First, Ms. Wang appears to evidence high to very high psychopathic traits. As a

5 psychopathic personality, Ms. Wang's interpersonal paradigm-the habitual manner in which

6 she interacts with others--is dominance, rather than the normal interpersonal paradigm of most
7 people which is reciprocal affection. Her desire to dominate others, whether individuals, groups,

8 or institutions-including the courts--subsumes other desires, and continuously provides

9 emotional gratification through the devaluation of others (Meloy, 1988; Garofalo et al., 2018;

10 Meloy et al., 2018). Such individuals often feel contemptuous delight toward others when their

11 manipulations and deceptions are successful, and experience pleasure through the suffering of

12 others, what is tem1ed sadism. Typically those who cross paths with a psychopathic individual,

13 whether in their personal or professional lives, will end up confused, angry, betrayed, humiliated,

14 resentful, and emotionally injured-and, in some cases, physically injured if violence is

15 involved. Psychopathic individuals leave a trail of pain and sorrow behind them. Psychopathic

16 personalities will also lie and deceive regardless of person, place, time or circumstance. As

17 Judge Flores said in his DVRO ruling against Ms. Wang on October 22, 2022: "I can't recall

18 ever being in a situation where I had to make such adverse credibility findings ever .. .I do not
19 find Ms. Wang credible" (p. 4 of transcript).

20 6. Second, it is my opinion that Ms. Wang has engaged in a continuous period of

21 stalking, both on line and on the ground, of adult males who were unwittingly victimized over the

22 last decade. There are at least three known men who were victims of both her sexual seduction

23 and her subsequent aggression; the most recent known victim was Christoffer Thygesen who

24 impregnated her in February 2018, which resulted in the birth ofa son,_ Thygesen V{ang,

25 on November 26, 2018. Two of these encounters have also resulted in stalking and harassment

26 criminal charges against Ms. Wang in California and in Utah (both victims' cases--Walker Stone

27 and Christoffer Thygesen--were consolidated in the San Francisco felony case). I see.no

28 evidence whatsoever that Ms. Wang feels any guilt or remorse for her behaviors, and ample
3
In re the MatterojThygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF J. REID MELOY
 II
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evidence that she often emotionally thrives on the chaos and torment that she can cause in others.

2 In behavioral psychology, this is referred to as intermittent positive reinforcement, and predicts

3 repetition of her behavior. A key aspect of her cyberstalking, moreover, is that through her very

4 creative and technologically sophisticated use of the internet and various websites, social media

5 platforms and other direct messaging services, she is able to translate her on line behavior into

6 dangerous on the ground behavior by others persuaded by her influence. She does this by •

7 assuming false identities and generating escalating conflict online.

8 7. Explicit threats of violence and third party sexual aggression orchestrated by Ms.

9 Wang have occurred on numerous occasions toward her two previous stalking and harassment

IO victims, Rory Wil I and Walker Stone. She also twice assaulted her father when she was an

11 adolescent at ages 15 (aggravated assault with a knife) and 18 (assault within a car). It is an

12 empirical fact that the most violent stalkers are those that have had a prior sexually intimate

13 relationship with the victim of the stalking, and frequencies range from 20-50% that violence

14 will occur during the stalking (Meloy & McEwan, 2023; Meloy et al., 201 I). Both male and

I5 female prior intimate stalkers have the same probability of violence risk (Meloy et al., 2011 ).

16 8. These preliminary opinions are based upon the historical record which is more

17 than sufficient to establish her patterns of past behavior. However, to conduct a violence r.isk

18 and threat assessment-determination of the probability of these behaviors continuing in the

19 future-and to render a formal DSM-5-TR diagnosis, a clinical and forensic evaluation of Ms.

20 Wang is needed to meet the highest standard of practice in this particular case. This evaluation

21 would consist of various tests and measures, as well as a face to face interview. The evaluation

22 would be expected to take 6-8 hours, and would be completed in one day.

23 9. Such an evaluation would allow me to render the most reliable and valid opinions

24 concerning her formal diagnosis; risk of physical violence toward others; her risk of persistence

25 of the stalking and harassing behavior, primarily on line; her risk of recurrence of the stalking and

26 harassing behavior, primarily on line; her risk of abduction of her young son from the custody of

27 his father; and the risk of third pa1ty violence instigated by Ms. Wang.

28 I declare under penalty of perjury under the laws of the State of California that the
4
in re the Matier ofThygesen v. Wang, Case No.: FDV•l9-814465; DECLARATION OF J. REID MELOY
 II
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foregoing is true and correct.

2

3 DATED: January 5, 2023

4

5 J. REID MELOY, PHD, ABPP

FELLOW, AMERICAN ACADEMY OF
6 FORENSIC SCIENCES
FELLOW, AMERICAN ACADEMY OF
7 FORENSIC PSYCHOLOGY
8

IO

11 References
12 • Garofalo, C., Neumann, C., Zeigler-Hill, V. & Meloy, J.R. (2018). Spiteful and contemptuous:
13 A new look at the emotional experiences related to psychopathy. Personality Disorders:
14 Theory, Research & Treatment. DOI: 10.1037/per0000310.

15 • Meloy, J.R. (1988). The Psychopathic Mind: Origins, Dynamics and Treatment. Aronson.

16 • Meloy, J.R., Book, A., Hasker-Field, A., Methot-Jones, T., Raters, J. (2018). Social, sexual,
17 and violent predation: Are psychopathic traits evolutionarily adaptive? Violence and Gender.
18 DOI: I 0.1089/vio.20 I 8.0012.

19 • Meloy, J.R. & Hoffmann, J., eds. (2021). International Handbook a/Threat Assessment, 2nd
20 ed. Oxford University Press.

21 • Meloy, J.R. & McEwan, T. (2023). Stalking. In: Max M. Houck (ed.) Encyclopediaof Forensic

22 Sciences, Third Edition, vol. 4, pp.611-616. Elsevier.

23 • Meloy, J.R., Mohandie, K. & Green, M. (2011). The female stalker. Behavioral Sciences and
24 the Law, DOI: 10.1002/bsl.976
25

26

27

28
5
In re the Matter ofThygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF J. REID MELOY
 ~ J. Reid Meloy, Ph.D. - Forensic Psychologist.pdf

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REID MELOY, Ph.D.

A Forensic Psychological Corporation

(office address upon request}

La Jolla, CA 92037

Cell: 858-922-1528
Email: [email protected]

Education

Acad. Cert., San Diego Psychoanalytic Institute, 2006

Ph.D., Clinical Psychology, United States International University, 1981 {Alliant International University-CSPP)

M.Div., Theology, McCormick Theological Seminary, 1975

M.S.W., Clinical Social Work, University of Illinois, 1974

B.A., History, College of Wooster, 1971

Training and Experience

June. 1995 to present Forensic Psychology Consultation Only

July, 1982- August, 1995Prlvate Practice, Forensic and Clinical Psychology

Aug., 1986 - June, 1997 Chief, Forensic Mental Health Division, San Diego County Department of Health Services (Court Services only beginning
April 15, 1992 on a part time basis); Conditional Release Program Director, San Diego County (1986-1994)

August, 1982 - July, 1986Director, Psychiatric Security Unit, San Diego County Central Detention Facility

May, 1978 - June, 1981 L.C.S.W.Private practice, psychotherapy and psychodiagnostic evaluations

Sept., 1979 - July, 1982Senior Psychiatric Social Worker, San Diego County Mental Health Department

July, 1975 -Aug., 1977Program Coordinator, Adult Day Treatment, Oak Park Family Service and Mental Health Center
 ~ J. Reid Meloy, Ph.D. - Forensic Psychologist.pdf

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U.S.v.James Wells (2013)- Retained by USAttorney. Workplace double homicide. Testified generically as expert on workplace violence, modes of
violence, targeted homicide, and multiple homicide in Federal District Court, Anchorage, on April B, 2014. Convicted. Sent back for retrial in 2017
by Ninth Circuit Court of Appeals.

Francovich v. Menmuir (2014)-civil case, retained by plaintiff. Reno, NV. Summary judgment against plaintiff.

State of California v. xxxxx (2013)-not disclosed. Retained by defense.

U.S.v. Zapirain (2014)- Retained by us Attorney in threat case against a television public figure.

Cleveland v. Taft Union High School (2014-2019)-Retained by plaintiff in school shooting, threat assessment, security issues case. 2019 verdict
found for the plaintiff, $3.8 million.

Moffitt v. USAAInsurance (2014)-retained by defense in case of intentionality of suicide. Filed report.

Montemayor v. Taymax Fitness (2014)-retained by defense in case of adequate security in double homicide in parking lot of fitness center. San
Antonio, TX. Case settled prior to testimony and report filed.

Moscoso v. San Bruno Church (2014)-County of Los Angeles. Retained by plaintiff in case of stalking. Settled. Deposed Nov., 2014.

U.S.v. Elizabeth Young {2015)- Retained by US Attorney in threat case against a corporate public figure. Report filed.

Arizona v. Michael Eckhardt (2014-2015)-Retained by criminal defense in murder case. Found guilty of involuntary manslaughter.

People v. Kori Muhammad (2017-2018)-retained by district attorney; competency to stand trial. Testified Jan. 17-18, 2018. Found competent.

Zehau v. Shacknai (2017-201BJ-retained by plaihtiff in civil case concerning responsibility for murder of Ms. Zehau. Jury found for the plaintiff.

Rosen v. Regents of University of California (2015-2020}-retained as consultant by defendant in threat assessment and management civil case.
Settled.

U.S. 11.James Wells {2018-2019)-retained in retrial of criminal case (see above). Found guilty again.

U.S.v. xxxxxxx(2019- }-consultant to the FBI/AUSAon a bombing-homicide case.

US.v. Buster Hernandez (2020-2021}-retained by the prosecution. Testified at sentencing in federal court, Southern District of Indiana. Sentenced
to 75 years in prison.

People v. Mohamed Mohamed {2020-2022)-retained by prosecution in lone actor terrorism case.

Defendant found NGRI.

Chamblee v. Baltimore Sun et al. (2021-2022) retained by plaintiffs in civil case resulting from mass murder at the Capital-Gazette, Annapolis,
Maryland, in June, 2018. Deposed. Settled.

People v. Kailin Wang (2022· ) retained by attorneys on a civil custody case and criminal stalking case.

Various ongoing undisclosed retentions by corporations, universities, and other government entities for threat assessment and management
purposes pre offense (2008-present) prior to any criminal or civil litigation post offense.
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 Robert L. Kaufman, Ph.D, HOME ABOUT SERVICES RESOURCES CONTACT
ABPP

ABOUT

Robert Kaufman, PhD, ABPP

Robert Kaufman, PhD, ABPP has been licensed in California since 1987 (License#:
PSY 9808) and has maintained a clinical and consulting practice since that time.
He earned his BA, with Honors in Psychology, at Brandeis University in Waltham,
MA and completed his PhD in Clinical Psychology at the Wright Institute in
Berkeley, CA. In 2008, Dr. Kaufman earned Board Certification in Forensic
Psychology from the American Board of Professional Psychology (ABPP). Dr.
Kaufman is a fellow of the American Board of Forensic Psychology and the
Society of Personality Assessment.

Dr. Kaufman began his practice as a clinical psychologist offering psychotherapy

for individual adults, couples, children, adolescents, and families. In addition, Dr.
Kaufman developed expertise in psychological and neuropsychological
assessment of children, teens, and adults. He has specialized in diagnosing and
recommending treatment plans for individuals with complex cognitive and/or
social and emotional problems.

Dr. Kaufman also has over 30 years of experience in forensic psychology,

including court-involved assessments, consultation to attorneys and expert
witness testimony. He has testified in both civil and criminal matters in numerous
counties in California and in Washington.

In addition to providing direct clinical services, Dr. Kaufman has taught and
supervised doctoral students in clinical and applied psychology in several Bay
Area graduate schools, including UC Berkeley, the Wright Institute and Alliant
University (formerly the California School of Professional Psychology). He is a
frequent presenter at national, international, regional and local conferences of
professional organizations such as the Association of Family and Conciliation
Courts and the Society for Personality Assessment. He has published in the field
of family law as well as in jury consultation. Dr. Kaufman is also an expert
reviewer for the State of California Board of Psychology, where he assesses
consumer complaints against psychologists and other mental health and medical
professionals.

Dedicated to assisting individuals and families of limited financial means, Dr.

Kaufman served on the Board of Directors of the Family and Children’s Law
Center, a non-profit legal center in San Rafael, CA, including three years as its
Board President. He is also a founding member of the Interdisciplinary
Settlement Conference program in the Marin County Family Court. Dr. Kaufman
also served on the Board of Directors of the Association of Family and
Conciliation Courts – California Chapter.

For more than 20 years, Dr. Kaufman applied his skills in trial and jury consulting
to a wide range of civil and criminal cases. He has participated in pre- and post-
trial research, assisted attorneys with jury selection in State and Federal Court,
consulted with attorneys on case strategy, and assisted with witness preparation.
For these years, he has served as a Senior Trial Consultant with the San Francisco
firm of Bonora Rountree, LLC; Trial Consultants and Research (formerly Bonora
D’Andrea, LLC).

Robert Kaufman, PhD, ABPP CV

COPYRIGHT © 2023 ROBERT L KAUFMAN PH.D - ALL RIGHTS RESERVED.

 II
DocuSlgnEnvelopeID: 6969E8C7-710B-4682-9B4D-E5FE7DAF7CCA

I MICHAEL REEDY (161002)

McMANIS FAULKNER
2 a Professional Corporation ELECTRONICALLY
50 West San Fernando Street, 10thFloor
3 San Jose, California 95113
FILED
Superior Court of California,
Telephone: (408) 279-8700 County of San Francisco
4 Facsimile: (408) 279-3244
Email: [email protected] 01/09/2023
Clerk of the Court
5 BY: TIM KYU
DOUGLAS RAPPAPORT (136194) Deputy Clerk
6 LAW OFFICES OF DOUGLAS L. RAPPAPORT
260 California Street, Suite I 002
7 San Francisco, CA 94111
Telephone: (415) 989-7900
8 Facsimile: (415) 989-7950
Email: [email protected]
9
Attorneys for Petitioner,
IO CHRISTOFFER THYGESEN
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
FOR THE COUNTY OF SAN FRANCISCO
13
14
15
In re the Matter of: Case No.: FDV-19-814465
16
CHRISTOFFER THYGESEN DECLARATION OF ROBERT L.
17 KAUFMAN, PHD, ABPP
Petitioner,
18
and
19 Date: January 23, 2023
KAILINWANG, Time: 9:00AM
20 Dept.: 404
Respondent.
21
22

23
24 Ill
25 Ill

26 Ill
27 Ill
28
In re the Matter ofThygesen v. Wang,Case No.: FDV-19-814465;DECLARATIONOF ROBERTL.
KAUFMAN,PHO, ABPP
 II
DocuSignEnvelopeID: 6969E8C7-710B-4682-9B4D-E5FE7DAF7CCA

1 I, Robert L. Kaufman, Ph.D., declare that the following facts are within my personal knowledge

2 and that if called as a witness, I would and could competently testify thereto.
3 Qualifications

4 1. I am a Clinical and Forensic Psychologist licensed by the State of California. I

5 have been in private practice as a licensed psychologist since 1987. In addition, I have earned

6 Board Certification in Forensic Psychology by the American Board of Forensic Psychology

7 (2008) and am a fellow of the American Board of Professional Psychology and the Society for

8 Personality Assessment. Attached hereto as Exhibit A is my current curriculum vitae.

9 2. For over thirty years, a significant part of my professional practice has been in the

10 area of family law, where I have performed over one hundred-fifty child custody evaluations,

11 served as a mediator, Parenting Coordinator, co-parenting counselor, parenting coach and

12 individual therapist. In addition, I have provided consultation to attorneys and made numerous

13 presentations regarding custody matters at national and international conferences, for

14 professional organizations, local family law groups and Family Court Services. Details of these

15 activities also appear in my curriculum vitae.

16 3. I have developed specific expertise in developing parenting plans for separated,

17 divorced, and never married families who have infants, toddlers and/or young children. In this

18 area, I have published in professional journals, have made presentations to groups of mediators,

19 bench officers and mental health professionals. I have been asked on many occasions to create

20 and develop parenting plans via mediation and evaluation venues. I have also been qualified as

21 an expert in court for these subject areas on many occasions.

22 Referral and Relevant Background

23 4. In the matterbeforethe Court,I wasaskedb_yEricaJohnstone,Esq.(of Ridder,

24 CQm & Johnstone LLP), attorney for Petitioner/Father Christoffer Stanford Thygesen, to

25 analyze issues that inform parenting plan assessments and decisions for young children,

26 especially when a parent's mental health may be at issue. The matter involves Petitioner/Father

27 Christoffer Thygesen (for clarity referred to as "Christoffer"), Respondent/Mother Kailin Wang,

28
2
In re the Matter of Thygesen v. Wang, Case No.: FDV-19-814465;DECLARATIONOF ROBERTL.
KAUFMAN, PHD, ABPP
 II
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1 and their minor son, who is four-years old (DOB: November 26, 2018). The parents were never

2 legally married and never lived together. Indeed, the parties' relationship consisted of only two

3 dates a few days apart that resulted in the conception of a child, which the Court found took
4 place under false pretenses, and constituted an act of domestic abuse by Ms. Wang under

5 California law. In November of 2018, Ms. Wang gave birth to the child in Utah, where her

6 parents lived. On March 6, 2019, the court (in San Francisco) granted sole legal and sole

7 physical custody to Christoffer after considering evidence that Ms. Wang was intentionally

8 stalking and harassing Christoffer and his family. This included threats about the minor child.

9 The following day, on March 7, 2019, the child was removed from Ms. Wang's custody. The

IO child remains in Christoffer's exclusive care. Ms. Wang has limited supervised visits with the
11 child.
12 5. There is a complex and extensive history of legal actions in this case, involving

13 multiple legal venues. Apart from the ongoing litigation regarding Ms. Wang's access to and

14 visitation with the child, the court issued and renewed Temporary Restraining Orders protecting

15 Christoffer and his family from Ms. Wang dating back to 2019. A Criminal Protective Order was

16 also issued by San Francisco Criminal Court affording similar protection to Christoffer and his

17 family, including the minor child. Ms. Wang has also faced, pied guilty to or is being prosecuted

18 for crimes in California, Utah, and New York. The courts in California and Utah have also

19 deemed Ms. Wang a vexatious litigant.

20 6. Second, San Francisco Family Court has afforded Ms. Wang limited and

21 supervised visitation with the child. The Court suspended in-person visitation after Utah law

22 enforcement reported criminal activity consistent with a possible threat of abduction, but the

23 Court later restored the in-person visitation on February 2, 2022, albeit with additional protective

24 measures, despite the court's determination that Ms. Wang continues to present heightened risk

25 of abducting the child. Since that time, Ms. Wang has supervised in-person visits with the child

26 for two hours, twice per month, at Rally in San Mateo in a Secure Room. No photos or videos

27 are allowed, and there are strict mies for beverages and food. In addition, Ms. Wang can have
28
3
In re the MatterofThygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF ROBERT L.
KAUFMAN,PHD, ABPP
 II
DocuSignEnvelope ID: 6969E8C7-710B-4682-984D-E5FE7DAF7CCA

1 supervised video sessions with the child for two hours, once per week. Visits are initiated at The

2 Family Academy (ACAFS) in Provo, Utah. No photos or video are allowed, and Ms. Wang is

3 required to use an iPad furnished by ACAFS.

4 7. Ms. Wang has filed numerous ex parte requests to change the visitation orders.

5 The current matter before the court stems from Ms. Wang's most recent Request for Orders

6 (RFO) in which she writes, "I am requesting for either termination of Supervised visitation,

7 Monitored Exchanges, and/or an increase in Supervised visitation from the bare minimum of 4

8 hours a month to 8-12 hours a month and at a facility, or facilities that can accommodate that

9 schedule whether that me [sic] partially at Rally ad [sic] another facility or private supervisors at

IO a designated safe and secure location." Ms. Wang writes that there have been "no inappropriate
11 incidents" for the entirety of the supervised visitation period, which is now more than three

12 years, and that continuing the current visitation status is unreasonable considering the absence of
13 update reviews by the court. Ms. Wang also alleges that Christoffer and his family have actively

14 interfered with her relationship with the chi1d.

15 8. In tum, Christoffer opposes Ms. Wang's RFO. He believes that given the Court's

16 findings at the recent trial and other new information (some of which will be discussed further

17 below), the risks to the child's health, safety and welfare are sufficiently great that all contact

18 between Ms. Wang and the child should be suspended until a full psychological evaluation of

19 Ms. Wang and a professional threat assessment has been conducted and considered by the Court.
20 Procedures
21 9. For this review, I was provided with scores of documents regarding both the

22 breadth and depth of the history of this matter. They include, but are not limited to pleadings,

23 court transcripts, declarations, text and email communications, incident and police reports, online

24 postings and more. A particular focus of this declaration is the recent Declaration of J Reid

25 Meloy, PhD, ABPP, Forensic Psychologist Re: Preliminary Findings: Violence Risk & Threat

26 Assessment of Kai/in Wang, dated January 5, 2023.

27 10. I have not performed an assessment in this matter and in keeping with the ethical

28
4
In re the Matter ofThygesen v. Wang,Case No.: FDV~l9M814465;DECLARATION OF ROBERT L.
KAUFMAN, PHD, ABPP
DocuSign Envelope ID: 6969E8C7-710B-4682-984D-E5FE7DAF7CCA

ROBERT L. KAUFMAN, PHO, A.B.P.P.

DIPLOMATE IN FORENSIC PSYCHOLOGY• AMERICAN BOARD OR PROFESSIONAL PSYCHOLOGY

CURRICULUM VITAE

EDUCATION AND CREDENTIALS:

2008 AMERICAN BOARD OF PROFESSIONAL PSYCHOLOGY
Board Certified in Forensic Psychology
1985 WRIGHT INSTITUTE, BERKELEY, CA
PhD in Clinical Psychology
1978 CALIFORNIA COLLEGE OF THE ARTS, OAKLAND, CA
M.F.A; Honors Distinction Award
1970 BRANDEIS UNIVERSITY, WALTHAM, MA
BA in Psychology; Cum Laude; Psychology Department Award

CURRENT EMPLOYMENT IN PSYCHOLOGY:

1987 - present PRIVATE PRACTICE, OAKLAND, CA; SAN RAFAEL, CA
Licensed OinicqJ &ycholoeist (License: PSY 9808)
• Forensic evaluations and consultation, child custody evaluations,
mediation and expert witness testimony.
• Psychological and neuropsychological assessment.
• Clinical supervision and consultation.
• Brief and long-term treatment of children, adolescents, adults, couples
and families.

200 I - present BONORA ROUNTREE, LLC, TRIAL CONSUL TING &

RESEARCH,
SAN FRANCISCO, CA (www.br-tcr.com)
Senior trial consultant
• Consultation to attorneys preparing for litigation, including pre and
post-trial research, case analysis and strategy, witness preparation and
jury selection.

2008 - present EXPERT REVIEWER FOR BOARD OF PSYCHOLOGY, STATE

OF CALIFORNIA & MEDICAL BOARD OF CALIFORNIA
• Review and evaluate ethics complaints lodged by consumers against
Licensed Psychologists
• Psychological and neuropsychological evaluations relevant to consumer
complaints to the Board of Psychology

711 D STREET; SUITE 209: SAN RAFAEL, CA 94901

TEL'. (51 0) 428- 1602 ❖ EMAIL: [email protected]
CA LICENSE: PSY 9808 ❖ WEB: WWW-RKAUfMANPHD.CQM
 EXHIBIT 11
Two experts who reviewed thousands of pages of hearsay falsified material for Thygesen over
Christmas break who appeared on behalf of Thygesen for Judge Wiley’s 5-day Termination of Visitation Even
Supervised Evidentiary Hearing that was held on 10/22/21, 11/12/21, 11/18/21, 12/20/21, and 01/05/22.
Both experts were DENIED ability to testify against Wang about how Supervised Visitation is
dangerous to the child.
Thygesen lost (See 02/02/22 Order) and Judge Wiley then increased Wang’s parent-time 250%
according to Thygesen.
Thygesen plans to re-litigate similar allegations before Judge Roeca in the upcoming Termination of all
Visitation even Supervised set for 2/27, 02/29, 03/12/24.

"Dr. Paul Elizondo is triple boarded by the American Board of

Psychiatry and Neurology (ABPN) in adult, child & adolescent,
and forensic psychiatry and currently hold a position as an
Assistant Clinical Professor (volunteer faculty) at the University
of California, San Francisco (UCSF) in the Department of
Psychiatry and Behavioral Sciences. In this role, he conducts
Paul M.
$550 hourly; or if Hired for the last day multiple weekly seminars for residents in psychiatry wherein
Elizondo Ill, 3230 Kerner Blvd. San
on-site (1/5/22) Termination of the subject of child development and the significance of the
D.O. Rafael, CA
10 presence is Visitation Even parent-child relationship are regularly discussed. On a weekly
Forensic Child P (650)283-6777
requested a daily fee Supervised Evidentiary basis, he provides psychiatric care to youth and their families
Psychiatrist [email protected]
of$ I 0,000. Hearing who reside in Marin County or are incarcerated at the Marin
County Juvenile Hall. Also on a weekly basis, he also provides
psychiatric care to youth who are currently participating in
residential treatment for between two and twelve weeks.
Through these work experiences, he has had the privilege of
witnessing hundreds of functional and dysfunctional family
dynamics and their long-term sequelae."

Mark I. Levy, MD,

DLFAPA
Dr. Mark Levy is board certified by both the ABPN and
(Medical Director), Main
National Board of Physicians and Surgeons in Adult and
Office
Forensic Psychiatry. He is an Associate Professor of
Mark Levy, $550 hourly; or if Forensic Psychiatric
Psychiatry (volunteer faculty) at UCSF and teaches in the Law
M.D. on-site Associates, LP
and Psychiatry Fellowship of the Department of Psychiatry. He
II Forensic presence is 655 Redwood Highway,
is a Distinguished Life Fellow of the American Psychiatric
Psychiatrist requested a daily fee Suite 271
Association and the Medical Director of Forensic Psychiatric Associates LP. He has
of $10,000. Mill Valley, CA 94941
practiced clinical psychiatry for 46 years, forensic psychiatry
P (415) 388-8040
since the middle 1980's and has conducted well over 500 forensic psychiatric
F (415) 634-2400
evaluations and testified in 65 State and Federal civil trials.
www.fpamed.com
[email protected]
fpamed
Paul M. Elizondo III, D.O. December 29, 2021
Forensic Child and Adolescent
Psychiatrist
Board Certified – General Ridder, Costa & Johnstone LLP
Psychiatry, Child and Adolescent Doug Rappaport and Erica Johnstone
Psychiatry, and Forensic Psychiatry
340 S. Lemon Ave. Suite 7550
3230 Kerner Blvd. San Rafael, CA Walnut, CA 91789
P (650)283-6777
[email protected]
RE: Thygesen-Wang
University Appointments

University of California, San

Dear Ms. Johnstone and Mr. Rappaport,
Francisco – Department of
Psychiatry and Behavioral Sciences We, Dr. Paul Elizondo and Dr. Mark Levy, have had the
Assistant Clinical Professor
(Volunteer) opportunity to review the copious records in the Thygesen-
Wang matter, which you made available to us on December
26, 2021. These records included legal documents, transcripts,
Mark Levy, M.D.
Forensic Psychiatrist
clinical observation notes, online media, and text
Board Certified – General Psychiatry communications. Following this detailed record review, you
and Forensic Psychiatry
asked us to express any concerns that may have regarding
655 Redwood Highway, Suite 271 Ms. Wang’s capacity as a parent.
Mill Valley, CA 94941
P (415) 388-8040
[email protected] Dr. Paul Elizondo is triple boarded by the American Board of
Psychiatry and Neurology (ABPN) in adult, child & adolescent,
University Appointments and forensic psychiatry and currently hold a position as an
University of California, San Assistant Clinical Professor (volunteer faculty) at the University
Francisco – Department of of California, San Francisco (UCSF) in the Department of
Psychiatry and Behavioral Sciences
Associate Clinical Professor
Psychiatry and Behavioral Sciences. In this role, he conducts
(Volunteer) multiple weekly seminars for residents in psychiatry wherein
the subject of child development and the significance of the
parent-child relationship are regularly discussed. On a weekly
fpamed Medical Directors basis, he provides psychiatric care to youth and their families
who reside in Marin County or are incarcerated at the Marin
Mark I. Levy, MD, DLFAPA
Medical Director County Juvenile Hall. Also on a weekly basis, he also provides
Charles Saldanha, MD, DFAPA psychiatric care to youth who are currently participating in
Assistant Medical Director
residential treatment for between two and twelve weeks.
Main Office Through these work experiences, he has had the privilege of
witnessing hundreds of functional and dysfunctional family
Forensic Psychiatric Associates, LP
655 Redwood Highway, Suite 271
dynamics and their long-term sequelae.
Mill Valley, CA 94941
P (415) 388-8040 Dr. Mark Levy is board certified by both the ABPN and
F (415) 634-2400
www.fpamed.com National Board of Physicians and Surgeons in Adult and
[email protected] Forensic Psychiatry. He is an Associate Professor of
Psychiatry (volunteer faculty) at UCSF and teaches in the Law
and Psychiatry Fellowship of the Department of Psychiatry. He
is a Distinguished Life Fellow of the American Psychiatric
Association and the Medical Director of Forensic Psychiatric
Erica Johnstone
Doug Rappaport
December 29, 2021
Page 2 of 3

Associates LP. He has practiced clinical psychiatry for 46 years, forensic psychiatry
since the middle 1980’s and has conducted well over 500 forensic psychiatric
evaluations and testified in 65 State and Federal civil trials.

Together, both Drs. Elizondo and Levy have reviewed the records in the Thygesen v.
Wang matter. Those records are listed in Exhibit “A,” attached to this report. They
include legal documents, transcripts, clinical observation notes, extensive online media
postings, and text communications. Based on our review of the available records, we
have the following concerns:

a. It is our preliminary opinion that Kailin Wang suffers from one or more
serious mental disorders that prevent her from acting rationally, meaning
that she is incapable and/or unwilling to comply with court orders and is
likely to continue to commit criminal acts endangering the health and
physical safety of the minor child whom she has consistently used as a
weapon within her criminal actions and the family law litigation.

b. To the best of our knowledge based upon our records review, a full and
complete psychiatric assessment of Ms. Wang, including robust
psychological testing, has never been completed. If ever there was a case
that required such a careful and in-depth assessment prior to permitting
her to have any access to the minor child, including in-person
visitation, it is this one.

c. Ms. Wang’s histories of violence, threats, harassment, impersonation,

defamation, altering the birth certificate for the child, applying for a ten-
year open visa to mainland China shortly after the child was removed from
her custody, and video recording the exterior of the supervised visitation
center, along with other behaviors, both legal and illegal, suggest genuine
risk factors for child abduction and injury, clearly not in the best interests
of the child.

Specifically, Ms. Wang’s repeated ideation in her social media threats about the child
being “sick” and “starving”; her use of graphic imagery of mutilated fetuses in her
numerous internet postings; her explicit threat to kill the child and herself, all while the
child was still in her custody, as well as her subsequent explicit threat, long after the
child was removed from her custody, that the child’s life was in danger even during
supervised visitations, her multiple threats involving firearms, and her threats of taking
her own life on two separate occasions, raise grave concern for Ms. Wang’s mental
stability and her capacity to utilize extreme measures and threats of violence to herself
Erica Johnstone
Doug Rappaport
December 29, 2021
Page 3 of 3

and to others in an attempt to manipulate targeted individuals, including the Court, to

gratify her personal demands, in this instance to attain the child custody arrangement
that she desires. This behavior, combined with her demonstrable disregard for Orders of
the Court, laws, and generally accepted rules of conduct that she continues to
repeatedly flaunt, suggest that she is solely interested in gratifying her own needs, be
they rational or irrational, and either does not choose to (or is incapable of choosing to)
prioritize the needs of the child above her own personal wishes. Her prior history of
threats and violence towards other individuals in addition to members of the Thygesen
family, provides even more evidence of her extremely serious and longstanding mental
disorders that render her a potential danger to the child whose best interests are being
weighed by this Court. Also of concern to us is the evidence that her parents have
knowledge of, and actively collude with, her ongoing acts of deception.

Please note that the above opinion has been offered as preliminary and is based only
on our careful review of the records made available to us. Although these records are
extensive, we understand that they are incomplete.

Please contact us with any questions.

Sincerely,

Paul M. Elizondo III, D.O.

Forensic Child and Adolescent Psychiatrist
Board Certified— General Psychiatry, Child and Adolescent Psychiatry, and Forensic
Psychiatry
Forensic Psychiatric Associates, LP

Mark I. Levy, M.D, D.L.F.A.P.A.

Forensic Psychiatrist
Board Certified— General Psychiatry and Forensic Psychiatry
Forensic Psychiatric Associates, LP
 Exhibit A

• 1_12/23/21 CA Supreme Court Petition for Review.pdf

• 1A_ Ten color copies of social media posts and direct contacts
• 2_2019-2-15 DV-100 Request for DVRO.Filed.2/15/19.pdf
• 3_2019-03-04 Supplemental Declaration.Filed.03.04.19.pdf
• 4_EXHIBIT 28 Provo City v. Kailin Wang, Case No. 011404594.pdf (Exhibit in CT’s
2/15/2019 Declaration)
• 5_EXHIBIT 30 New York Detective Anthony Cozzi’s Affidavit.pdf (Exhibit in CT’s
2/15/2019 Declaration)
• 6_EXHIBIT 31 Rory Will’s affidavit.pdf (Exhibit in CT’s 2/15/2019 Declaration)
• 7_EXHIBIT 29 People of the State of New York v. Kailin Wang criminal record Case
No. 20217 2013 Crim. Ct.pdf (Exhibit in CT’s 2/15/2019 Declaration)
• 8_EXHIBIT 32 Spanish Fork City v. Kailin Wang, Information, Citation No.
S10852813.pdf (Exhibit in CT’s 2/15/2019 Declaration)
• 9_2019-03-06 Amended DV TRO and all March 6 Orders.pdf
• 10_Transcript.03.06.19.pdf
• 11_EXHIBIT 35 Spanish fork Incident Report.pdf
• 12_2019-04-11 EXHIBIT 2 Shelter Pretrial Hearing Order from 3/18/2019 Shelter
Hearing in Utah.Filed 04.11.19.pdf
• 13_2019-03-18 EXHIBIT 1 Utah Shelter Hearing Minutes 03.18.2019.pdf
• 14_EXHIBIT 34 CPS Case Summary Report.pdf
• 15_2019-03-18 EXHIBIT 7 Ms. Wang’s March 18, 2019, filed Request for Protective
Order.pdf
• 16A_2019-04-09 Declaration of Christoffer Thygesen.Filed.04.09.19.pdf
• 16B_2019-04-05 Wang Response.Filed.04.05.19.pdf
• 17A Holysmoke 1st thread February 8
• 17B Holysmoke 2nd thread February 12
•
•

•
-
18_EXHIBIT 11 Kailin Wang’s Passport.pdf
19_EXHIBIT 10 Wang original birth certificate which lists Kailin Wang’s
country of birth as China.pdf
20_EXHIBIT 26 Kailin Wang’s June 14, 2019, Signed Supp. Exhibits to Declaration of
Kailin Wang.pdf
• 21A_Wang.Declaration of Kailin Wang.Filed.05.07.19.pdf
• 21B_Wang Memorandum of P&A Re Jurisdiction.Filed.05.07.19.pdf
• 21C_2019-05-07 Declaration of Christoffer S. Thygesen.Filed.05.07.19.pdf
• 21D_Transcript.05.08.19.pdf
• 22A_EXHIBIT 27 Judge Richard Darwin’s FOAH (from June 6, 2019 Hearing) filed
July 19, 2019.pdf
• 22B_2019-06-25 EXHIBIT 3 Court Transcript form 6.25.2019 UCCJEA Trial.pdf
• 23_2019-07-11 EXHIBIT 8 July 11, 2019 Order Denying Petitioner’s (Ms. Wang’s)
Request for Protective Order.pdf
• 24_2019.09.12.Order Modifying Supervised Visitations at Rally.Filed.pdf.
• 25_2019.10.01.Wang.Updated Declaration in Support of Temporary
Orders.Filed.Rcvd.pdf
• 27_2019.10.11.FOAH (10.3.19).Filed.pdf
• 28_EXHIBIT 33 Ppl. St. of CA v. Kailin Wang No. 19016407 Domestic Violence Felony
Complaint Arrest Warrant.pdf
• 29_2020-12-14 Filed Supplemental Memo of P&A.pdf
• 30_2021.01.07.Court.FOAH 12.16.20 Hearing.Filed.pdf
• 31A_EXHIBIT 9 Information, State of Utah v. Kailin Wang, Case No. 2111000167.pdf
• 31B_2018-3-24 Prosecution Racism email to Utah County Courts.pdf
• 31C_San Francisco Stalking Case_redacted.pdf
• 32_2021-07-19.RFO.Filed[1].pdf
• 33_2021-07-23.Supplemental Documentation in Support of Petitioner’s
Request.Filed.pdf
• 34_EXHIBIT 36 Subpoena to U.S. Dept. of State Requiring Prod. by March 22, 2021.pdf
• 35_EXHIBIT 16 First Amended Information, State of Utah v. Kailin Wang, Case No.
211100167.pdf
• 36_EXHIBIT 22 Affidavit for Search Warrant signed under penalty of perjury by Sgt.
Richard Hales June 1 2021.pdf.
• 37_EXHIBIT 24 Email dated August 13, 2019.pdf
• 38_2021-07-16.Memorandum of P&A.Filed.pdf
• 39A_EXHIBIT 20 Judge Thomas Low’s June 1, 2021 Order from May 10, 2021
Hearing.pdf
• 39B_Judge Thomas Low’s June 1, 2021 Order from May 20, 2021 Hearing.pdf
• 40_EXHIBIT 37 Judge Low 10.18.21 Order Quashing Add. Unauthor. Subpoenas.pdf
• 41A_2021-07-30 FOAH 7.29.21 Hearing.pdf
• 41B_Writ.pdf
• 41C_2021-10-18 Amended Response.pdf
• 41D_2021-09-13 Writ Decision.pdf
• 42A_2021.10.19.Wang.VOLUME 1_RORY WILL_October 2013 to 2014 (Pages 1 to
126).Rcvd.pdf
• 42B_2021.10.19.Wang.VOLUME 2_WALKER STONE_July 5, 2017 to November 20,
2017.Rcvd.pdf
• 42C_2021.10.19.Wang.VOLUME 3_CHRISTOFFER S. THYGESEN February 14, 2019
to Present.Rcvd.pdf
• 43_2021-10-22 Hearing Transcript.pdf
• 44_2021-11-12 Status Conference Transcript.pdf
• 45A_2021-11-19 - K Ex Parte RFO Re Addt’l Zoom visits.pdf
• 45B_2021-11-23 - C Memo of P&A re Ex Parte.pdf
• 45C_2021-11-24 - ORDER re Ex Parte visitation.pdf
• 46A_2021-11-08 KW RFO Custody Evaluator 4 Pages Ref on 11 18 2021 RT.pdf
• 46B_2021-12-10 - C P&A for Cust Eval.pdf
• 46C_2021-11-29 CT Memo of P&A to Lift Stay of DVRO Trial.pdf
• 47A_2021-12-07 - C Objection to Improper Communications with Court.pdf
• 47B_2021-12-16 - K Declaration… Family Court Judge Wiley
• 47C_2021-12-17 KW email to SF Family Court Judge Wiley
• 48_2021-12-14 - C Memo of P&A in Support of Motion to Quash.pdf
• 49_2021-12-16 - KW motion for Peremptory Challenge.pdf
• 50_2021-12-20 FOAH 12.20.21 Hearing .pdf
• 51_ACAFS Electronic Supervision SV Notes 12.9.20-12.8.21.pdf
 EXHIBIT 12
Thygesen’s Utah Private Investigators Chris Bertham and Patrick Adams Utah Private
Investigator. Chris Bertham has been retained continuously by Thygesen since at December
2018-Present his duties include, obtaining our child’s Utah Birth Certificate on 01/17/19 before
DNA genetic testing proved Thygesen to be the father of the child.
Chris Bertram is also hired to follow, surveil, monitors the Wang’s in Utah, appear at her
Utah hearings, and obtaining Wang’s Juvenile Court records recently on 01/09/23 from when she
was 15 years old, and publicly filing them to smear campaign her in California in violation of
WIC 827. Patrick Adams is a Utah PI who Thygesen hired to conduct unlawful pre-text method
to obtain my Mental Health records by hiring investigators who pretended to be from my Public
Defender's office attempting to obtain my records.
9/25/2020 Bertram and Associates Private Investigations

ABOUT US I TEAM ASIP

Chris D. Bertram
Lou F. Bertram Lou F. Bertram
(801) 944-7310
P.O. Box 712532 Founder of Bertram and Associates, has over 45 years of investigative
SLC, UT 84171 experience and is a retired Special Agent with the Federal Bureau of
Investigation (1968-1988). Lou started Bertram and Associates in 1989
and focused the business on private investigations, security consulting,
including security consulting services during the 2002 Winter Olympics
for a Fortune 500 Top 50 company.
Lou also taught at Salt Lake Community College as an adjunct professor
for 20 years. He has run Service Industries, an alcohol training and
liability program, since 1989. He is a court certified expert in Utah Dram
Shop law and police operations. Lou is a third generation law
enforcement officer.

Chris D. Bertram
Chris has 25 years of law enforcement and investigative experience with a major county sheriff’s office and police department. He
NAVAL retired as a Deputy Chief from the Unified Police Department of Greater Salt Lake / Salt Lake County Sheriff Office. Chris has a
,.-,1!~~'-.I.IAI~ POS'l'GRADUATI!
SCHOOL Master of Arts in Homeland Defense and Security from the Naval Postgraduate School (NPS) in Monterey, CA., and a MBA from City
University of Seattle. He is a graduate of the FBI National Academy Session 223 at Quantico, VA in 2005. In addition, he is a
graduate of the FBI Command College (2003) and Utah POST Command College (2004).
Chris has a wide range of investigative experience, law enforcement operational and tactical proficiency as well as homeland
security and intelligence knowledge. He served with several federal and local investigative task forces. He was named Utah’s Deputy
Sheriff of the Year in 1997. Chris started his work with Bertram and Associates in 1990. He also teaches as an adjunct professor and
assistant professor at both the college and university level. Chris is the fourth generation of law enforcement in his family.

www.tbertramgroup.com/team.php 1/2 4

4 AA 1000
 Bureau of Vital Records July 28, 2020
Vital Records Receipt L~- L

Request Number: 3036839 2020

JUL30 PMI: 08
Request Type: Counter
Customer Name: Chris Bertram

Description Quantity Amount

Birth Certificate I /17 / Zd/9 20.00

Total Charges 20.00

Payment Method(s): Credit

Clerk: TiffanyFitzpatrick

Bureau of Vital Records July 28, 2020

Vital Records Receipt

Request Number: 3036839

Request Type: Counter
Customer Name: Chris Bertram

Description Quantity Amount

Birth Certificate 1 20.00

Total Charges 20.00

Payment Method(s): Credit

Clerk: TiffanyFitzpatrick

3 AA 999
 II
DocuSign Envelope ID: 6915A35B-8876-4F18-A06A-8DB969C52AB3

1 DOUGLAS RAPPAPORT (136194)

LAW OFFICES OF DOUGLAS L. RAPPAPORT
2 260 California Street, Suite 1002
ELECTRONICALLY
San Francisco, CA 94111
3 Telephone: (415) 989-7900 FILED
Facsimile: (415) 989-7950 Superior Court of California,
County of San Francisco
4 Email: [email protected]
Attorneys for Petitioner, 01/20/2023
5 CHRISTOFFER THYGESEN Clerk of the Court
BY: TIM KYU
Deputy Clerk
6

7 SUPERIOR COURT OF THE STATE OF CALIFORNIA

8 FOR THE COUNTY OF SAN FRANCISCO
9

10
In re the Matter of: Case No.: FDV-19-814465
11
CHRISTOFFER THYGESEN DECLARATION OF CHRIS BERTRAM
12
Petitioner,
13
and
14
KAILIN WANG,
15
Respondent.
16

17

18

19

20 I, Chris Bertram, do hereby declare:

21 1. I am a licensed private investigator in Utah. I know personally the matters stated
22 herein. If called as a witness, I could and would competently testify thereto.
23 2. As part of my investigative work on this case, in September, 2022, I submitted a
24 GRAMA (Utah’s equivalent of a FOIA) to the Provo Police Department seeking information
25 including emergency calls made to addresses where the Wang family had previously lived,
26 including on S 990 W in Provo.
27 3. In response, the Provo Police Department produced a redacted report pertaining to
28 an emergency response on July 28, 1998 at 11:01pm, to S 990 W which resulted in Wang’s
1
In re the Matter of Thygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF CHRIS BERTRAM
 II
DocuSign Envelope ID: 6915A35B-8876-4F18-A06A-8DB969C52AB3

1 arrest for aggravated assault against her parents.

2 4. A September 13, 2022 letter from the Provo Police Department, which shows that
3 the July 28, 1998 police report was produced as responsive to my GRAMA request, is attached
4 hereto as Exhibit A.
5 5. Contrary to Ms. Wang’s allegations, this document was legitimately obtained
6 pursuant to a Utah GRAMA request.
7 I declare under penalty of perjury under the laws of the State of California that the
8 foregoing is true and correct.
9

10 DATED: January 19, 2023

11

12 CHRIS BERTRAM
13

14

15

16

17

18

19

20

21

22

23

24

25

26
27
28
2
In re the Matter of Thygesen v. Wang, Case No.: FDV-19-814465; DECLARATION OF CHRIS BERTRAM
1 DARRICK T. CHASE, ESQ. (CSB #151256)

lF fNfRl!)_JD
KA YE•MOSER•HIERBAUM •FORD LLP
2 101 California Street, Suite 2300
San Francisco, CA 94111 San Francisco County Superior Court
3 Telephone: (415) 296-8868
Facsimile: (415)495-1771
4 Email: [email protected] MAR- 412019

5 Attorneys for Petitioner CLERKOF THBCOURT

CHRISTOFFER STANFORD THYGESEN BY: --~f'cl\llV
-r~~
Pif:itt~"\'k
6
7
8
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
IN AND FOR THE COUNTY OF SAN FRANCISCO
10

11 CHRISTOFFER STANFORD THYGESEN ) Case No. FDV-19-814465

)
12 Petitioner, ) DECLARATION OF CHRISTOFFER
) SL~NFORD THYGESEN IN
13 V. ) SUlPPORT Oir THIS REQUEST FOR
) DOMESTIC VIOLENCE
) PROTECTIVE ORDERS AND
14 ) CUSTODY ORDERS
KAILINWANG
15 )
Respondent. )
16 ) Date: March 6, 2019
) Time: 8:30 a.m.
17 ) Dept: 404
)
18 )
)
19 )

20
________________ )
)

21 I. Update

22 1. This declaration supplements the declaration of Fc:bruary 15, 2019 by providing

23 additional information and updating the court on events that have taken place since then,

24 including further disturbing actions that lead me to believe my son is not healthy or safe.

25 II. Ms. Wang is Stalking Me and My Family

26 2. Since my February 15, 2019 declaration, my lawyer ha~:been able to further quantify the

27 harassment and stalking that is targeting me and my family. Exhibit Z is an index of over 100

28
1 The person she had traveled to find is the victim in the Utah criminal prosecution against Kailin.

2 IV. I Am Terrified For The Safety Of My Son

3 15. I don't know where Ms. Wang is. She has disappeared and has thus far successfully evaded

4 service of this Court's February 15, 2019 DV-110 Temporary Restraining Order (CLETS-TRO).

5 16. I don't know where my son is. I desperately fear that he is in danger, and given Ms. Wang's

6 extreme conduct toward me and others I believe that any other reasonable parent would feel the

7 same way.

8 17. I've learned that Ms. Wang has mental health issues. (2/15/2019 RDVRO, Exhibits Land I.)

9 18. The pace of the incoming harassment shows that she's compulsive.

10 19. She is not acting rationally. Publishing this unlawful content destroys my prospects, network,

11 and life, including my ability to provide for my child.

12 20. Her most disturbing posts are about dead babies.

13 21. She also posts that the baby is sick, starving, and has severe jaundice. Infants require around

14 the clock care. Ms. Wang's posts don't suggest that my son is okay. Instead they suggest that he

15 is sick, and that she is full of compulsive rage. He's not getting the care that he needs, and she

16 enjoys dangling an infant in the crosshairs of her sick stalking campaign.

17 22. I have trouble sleeping. I have trouble concentrating. My mind is consumed with what she

18 will do next, and when can I rescue my son. I need to know that my son is safe.

19 V. - Will Be Safe With Me

20 23. I will strive every day to be the best father to this little boy. I know that my son will thrive in

21 our care. When I say "our" I mean, yes, primarily me as the father, but I also I have an incredible

22 family alongside me and we, as a team, embrace this baby with unwavering love and support. He

23 will thrive; be treasured; and, he will be the light of our lives.

24 24. The evidence indicates that Ms. Wang wants to destroy me, and everyone related to me. Who

25 is more related to me than the infant in her care?

26 VI. Ms. Wang is Evading Service and Hiding Hers4~lfand-

27
25. Attempted Process Service in Utah: Ms. Wang was in Spanish Fork, Utah on February 11,
28
2019 for a pretrial conference in Spanish Fork City v. Kailin Wang, Case No. 171301350 (filed
1 November 22, 2017) on 20 counts of criminal harassment. My investigators witnessed Ms.

2 Wang's mother and Ms. Wang arrive at the Court house for her hearing. They had the baby with

3 them.

4 26. Beginning on February 15, 2019, I attempted, through the Office of the Utah County

5 Constable to serve Ms. Wang at her parents' home in Spanish City. I believed that Ms. Wang

6 was with her parents and we would be able to effect service at her parent's home.

7 27. In Mr. Chase's email to Ms. Wang on 12/27/18, he said, "I understand you are residing with

8 your parents at 2481 Fairway Drive, Spanish Fork, UT 84660. Please confirm that for me." Ms.

9 Wang's reply to Mr. Chase on 12/28/18 said, "I am currently in between 3 states, and am only in

10 Utah due to my pending case which requires my mandatory monthly appearances. And -

11 has been in between New York, Utah and California since birth. The Utah address can be used

12 as a mailing address only."

13 28. See, Exhibit J-1, document titled AFFIDAVIT OF NON-SERVICE. The affidavit lists 9

14 attempted serves with brief descriptions.

15 29. Ms. Wang's father refused to cooperate. It is not credible that her parents did not have a

16 contact number for Kailin, did not attempt to contact her, and claimed they had no idea where she

17 was. But, if they had the baby, and they had no idea when;: she was, then, again, she must have

18 left the baby with her parents.

19 30. Utah Constable Ben Stowell went in person to see Ms. Wang's criminal defense lawyer, Ed

20 Brass, at Mr. Brass' office on 2/19/2019, identified himself, that he had process to serve for Ms.

21 Wang, and requested that Mr. Brass accept service for her. Constable Stowell reports that he was

22 told by Mr. Brass' secretary that Ms. Wang had instructed the office to not accept service for

23 her. See, Exhibit K-1, AFFIDAVIT ON NON-SERVICE.

24 31. Mr. Chase emailed Mr. Brass on February 20, 2019. Mr. Chase requested Mr. Brass notify

25 Ms. Wang that there was a DV-110 Temporary Restraining Order (CLETS-TRO) to be served on

26 her, and other required documents which were itemized in the email, requested Mr. Brass ask

27 Ms. Wang to allow a meeting with the Utah Constable to effect service of the listed documents.

28 32. Mr. Chase did not receive a reply. See Exhibit L-1. I believe it is reasonable to infer that Mr.
 Wang v. Thygesen 194400718
000223 Utah County Attorney
David 0. Leavitt, Utah County Attorney 100 East Center Street, Suite 2100
Loren E. Weiss, Chief Deputy Provo, Utah 84606
Chad E. Grunander, Criminal Division Chief p: 801.851.8026
Sherry E. Ragan, Community Division Chief f: 801.851.8051
David H. Shawcroft, Civil Division Chief
Patty Johnson, Bureau of Investigations Chief

Timothy Taylor January 6, 2020

Mariane O' Bryant

David S. Sturgill

Paul Wake

Chris Vannelli
Email:
Curtis L. Larson

Randy M. Kennard

Alexander M. Ludlow
Re: Complaint against Constable Lampropoulos
Douglas W. Finch

Julia Thomas
Dear Mr. Wang,
Craig R. Johnson

Jared Perkins
Enclosed is a letter we received from Constable Lampropoulos responding to
Ryan McBride your last communication.
Christine G. Scott

Lance Bastian Please let me know if you desire to provide any further facts related to your
Kelsy Young complaint. lf so, please respond prior to January 20, 2020.
Lauren Hunt

Rhonda Gividen Sincerely,

Adam Pomeroy

Charlotte Howard

Chase T. Hansen
David H. Shawcroft
Carl Hollan
Civil Division Chief
Poponatui M. Sitake
Deputy County Attorney
Brian Miller

Barbara Finlinson

M. Cort Griffin
DS/cpb
Robert J. Moore

Paul Jones

Benjamin C. Van Noy

Anthony E. Loubet

St. Richard C. Hales

Sgt. Justin Seitzinger

Sgt. Aaron Tischner

000223
 Wang v. Thygesen 194400718
000224

March 8, 2019

David H. Shawcroft
Civil Division Chief
Utah County Attorney
100 East Center, Suite 200
Provo, UT 84606

Via Email

Dear Mr. Shawcroft,

On February 29, 2018, you sent me an email which contained a complaint received by the Utah
County Attorney’s Office from a Mr. John Wang. Listed in that complaint were several
allegations regarding myself, my associate, or my business, Unified Constable Service, Office of
the Utah County Constable. These allegations are gross mischaracterizations of events and omit
the serious underlying legal issues in this case.

I am grateful for the opportunity to respond to these grossly mischaracterized allegations.

Fcbru:irv 16, 2019
In my response, I summarize review my business and its lawful authority, provide a summary of
At
the!J:UOpm onViolence
Domestic I ebruary 16, ~Ul!J,
Temporary Constable
Restraining Lampropoulo;
Order, and Court
along with other Ueputy Constable
Orders and I rainee, !:!en
Stowell, attempted
concerning contacttowith
issues presented M<.provide
us, and \Vang aattruthful
2ll.81 Fairway Drive,
and accurate Spanish
factual Fork, of
summary Utah.
the This
attemptswas
address to serve
noted legal
as paperwork.
her potential residence. No person answered the door during the
anempt, A card was. left with Cons.table Lampropoulos' contact information on it.
Unifiedthic;;
Ourine Constable Service,
.=ittPmpt, Office to
WP ,;pnl<t•• of "i?V?r.-,.1
the UtahnPighbnr"i
County Constable
.=ihout whPthPr K;;.ilin VJ;me rP<oidP"i.=it th;:,
oddress. I he neighbor~ indi~ted that she did indeed reside at the home and provided
Unified Constable Service, Office of the Utah County Constable, serves and enforces civil and
inro11rn:1liou c1boul 111,•1 hc1ving c1d1ih.l rf::c:'=:!nlly.Tiu:! n~ighL01::. t:!Vt:!11
rE:!c::mlly ho::.l~-, bc1by
criminal court process throughout Utah County, Salt Lake County and the Greater Wasatch
shower for her.
Front. A constable “may serve any process throughout the state.” Utah Code Ann. § 17-25-1(2).

Moreover,
“To qualify the
as a neighbors
constable, aindicated
person shall thatbeKailin Wang
certified as a is a •recluse"
special functionandpeacerarely lettinthe
officer the home.
They
state.”also stated
Utah Codethat
Ann. Kailin VJang rarely
§ 17-25a-2(1) (emphasis drove and was
added). often constables
Therefore, driven by her parents
are sworn andwhen she
certified
1~r1 peace officers,
I h .. hum~. VJ.. ;tl,o certified
lf'rtrn.,.,I through
I h:-d if the
)(;.iiiUtah PeacedidOfficer
in Wr1ne Standards
,h iv..,, ,h .. wou and
Id I Training. In '-'f'hid., ;;ii
itkf' ~ii It.,,
essence,
the home. constables have police powers
Hoth lampropoul~ and arewere
ond ~towell publicwitne-sses
servants, asked
to theseby the communityby
st;:itements tothe
serve legal documents.
neighbor<.

Oftentimes this public service of serving legal papers is not easy. Difficult consequences may
om~..-
Tl1u::., Liu:! Uuifit:!J Con::.lcthlt:!1 !:>
fE:!cl:r.Orn:rl.>ly
::.U:r.i.JE:!d1::d,
b.1:.t:!Uupon infurmctlion gc1lh\::!1E:!J
follow the service of process. Most people do not enjoy being served with legal papers,
from these independent
particularly, and detached
a Domestic Violence Temporary neighbors.
Restrainingthat
Order Kailin
withWang
seriouswas living atand
underlying 2481 fairway
D~ve In Spanish
ongoing Fork. matters.
civil and criminal

Factual Summary Of Domestic Violence Temporary Restraining Order

000224
 Wang v. Thygesen 194400718
000225

February 20, 2019

places of work, out in public, and with regard to our online safety and identifications and
Earlier in theId.day~
reputations.” Stowell
at pg. 2. went to the office of Ed Brass. the attorney for Kailin, to attempt
<;iprvir..Pth;:orp. ."-itm11.
1 ;:-IIw.=i-.in...trur.tPrl th.=it .=it K.;ilin' <;ciil"Prtion, th;:- l;nv nffirA'" mrty nnt .=t<.r:Ppt
::.~rviuit
Mr. 011 h~r b~h.il(,
Thygesen and his family have good reason to feel such fear. Mr. Theisen’s sister, Emma,
received a message on February 6 via Facebook stating “Maybe you’ll get to c ur Nephew at the
Sluvv~llone
hospital c1mJ Oflk~r
day. As heGu111:·•1 ol Uu,•
is sick and S...hm1 Pulk.~
on welfare.” Id. atD~1-1c11
page lrmml
4. This c1llew1µh:d
message came lo l·onlc1d
from a M1. 'Wc1111,!.
c1l
his place
fictitious of employment
account to ~ck has
but Mr. Thygesen his reason
ossist:inoc in scr,ing
to believe KailinKail
Wangin provided
sent it. the cJrficr stated
unsuccesstul attempts, indudins kailin's attorney. Stowell requested an otticer to be present
Another message
for officer safetywent to Mr. Thygesen’s
pu rpos:es.The Constable's band mates
Offlc·eon
wasFebruary
Informed6, 2019
that from
Kamnanother
ma,, have a firearm
fictitious account, stating “Hey can u create a fund for Christoffers child who is starving
And with th,-. WAng'<; riPtPrminiPti non-r.nopPrAtinn Anet h('}<;tility, hAvine; Annth,-.r nffi~Pr and onwA,;
Welfare.”
fJIu<l~ul Id.
in <.:cl:.~ fv11,Yhn,-: li;,J .i (i1~;,i11n c1:.w,:11.

The top of another

AftcrnQon online20,
of Fcbru~ry page
2009 states “Christoffer Thygesen Forced me to Kill 18 Week old
Baby.” The document added Mr. Thygesen’s response that the statement “is false, outrageous,
vile,
Mr.and very ;'lrtl'mpti"rl
Sfnwrll frightening.fOThis is the
r.M'Vi" thr thinking
OVTRO atofth<"
a person with
Spnnlr.h extreme
~nrk anger
:1nrtand
rC"-:lrf('onr.l" -:nwlikely mental
~ vr>hldl"<:

illness.” Id. leave the home within minutes of each other. One vehicle was a gold 6MW ~UV,
s-eparetely
whkh Mr. W:me frl"quC'ntl\• tirnvl", ;"lnrl ,h" othN w:1-:., m:11rnnnI l"i,:u,; SIJV. l",ilr. ~tov,"11 i:.,w :l
Onwoman
another in online page,
the back seatMs. Wang
of the Lexusstated
alonginwith
Medium.com thatMr.“Christopher
a baby seat, Thygesen’s
Stov,ell reasonably son is
believed
sick,
thAtstarving
th!'" wnmAn WA"i KAIfIn Wane
and homeless.” Id. at ;inri
pg. 6.follnwPt! thP ou In hnpP<;of-.!'"rvlne KAlfln.

The
Mr.document contains anMifiP-:i
s,nwPII proAr::tivPly history of Ms.j11ri.,tiictinn<;,.
lnn,I Wang’s criminal record.
inr.l11rfinf. Id. Md
Provo at page 7. In
S-Andi1, Provo
thAr City v.
hP \'IM<;
Kailin Wang, c1
::.h.idov,•ing No. 011404594,
v':hid~ lhc1l hf:!Ms. Wang entered
r~.i::.011c1Lly into
!.M:!li':v~d a plea inLh~
1.:u;1loin~d abeyance forc1Disorderly
:.ul;j;,,1.:lor UVI KO, M1, Conduct
Slvw~II
r.1!hr.l'ql!l"'ntly c:.oomct<'ti I :1mpmpoulnr, l"l"qur,r,f<'ti that hr m<'i't
and was ordered to provide verification of domestic violence counseling to the court. The plea
:ll'lrl lk'I~;nriy M :.,n :.rtrlrru:,r,
th.;t
inappeared
abeyancetotook be Mr. Wang'>
place lawyer.14, 2002 and the case was dismissed a year later.
on January

InMr.
TheWanG
People inGorrectly
of the State alleges Stowell
of New Yorkhad a police
vs. Kailin sticker
Wang, No.on20217-2013
his window (N.Y. that was
County remowc!,
Crim. Ct.
Stm11PII'<; vH'llr.l~ I<; tAk~-linmP "'!'"hlr.lP wh~h h11i<;
pPr-.onAI
10/25/2013 arrest; 11/05/14 conviction by plea) Ms. Wang was charged with Aggravated
I\ pffPCf,,_ In It. ThP <;tlr.k!'"r
In qoPUlon
Harassment, Criminal Contempt, Stalking, and Harassment. The allegations involved violating an
Order of Protection which was issued in New York. A court entry from May 5, 2014 referenced a
6-month stalker program or if none then psychiatric therapy for Ms. Wang.
Lamp,opoulos an ived at the addr~ssrnorncnts afte, Stcwcll and atleff1pti!d to vl:.ually identil'y
the v,ornan in thi! vehicle. Kailin Wang was not in the vehicle, but it wa,sin:.tead M,s. Wang.
In 2017, Ms. Wang was charged with 20 counts of Electronic Communication Harassment in
Kallin's baby was ab,.-,in the v@Mde.
Spanish Fork City v. Kailin Wang, No. 171301350. The Information was later amended to include
50 counts. Each count is a class B misdemeanor. Ms. Wang is set for Entry of Plea on April 8,
2019.
Of Theasprobable
note, two vehidescause left
statement
the home, states:
one with two adults inside of it, it was reasonably
deduced th:) t lhn'.!c adull.t. wcrn ~tnyin& io~idc lhc home:?.,v:.a r'C1nindc:?f,lho W~oe,:'!: ocighborr.
On th~t
il'1dicated or about October
Kailir, would 30 - November
d,ive 20, 2017,
<:ilhc, vl!hide. Thi:.inactivity,
SpanishalQni;;
Fork, Defendant sent hundreds
with th~ report of r1eighbo,s
of Kailinofr,@siding
text messages and made
in the home and many phone calls to
the obfusc;ition by the
the Victim
W;ing'safter was told to
in providine stop
any and
contact
that her
il'1fonnation of contact was unwanted.
Kailin, c;;oo'obor-atcstheDefendant
l'l!asonableadmits.
b~licf th~t Kailin resides at the Spanish Fofk
residence. Moreover, K::,ilin'sbt-ibywas with the W::mg'swhen the incident occvrred in S:)ndy-
The document
indic-ctting that includes
they hadMr. Thygesen’s
good contact statement
with Kailin,that, “It isi.snot
which in the to
contrary best interests
every of a they
statement
helpless
m::ide of infant or any child
not knowing to be in the care of, assuming he is even with her, which I do not
herwhere::ibouts.
know a person who is exhibiting extreme rage and mental illness, in my opinion, by
cyberstalking me and my family, for the purpose of causing as much damage and pain as

000225
 Wang v. Thygesen 194400718
000241

~OLSON'S
~GREl:NHOUSE

March12,2019

Re:Qizhong(John)Wang

Mynameis RandallL Barker.I resideat 450N 850E Springville,

UT84663.
I amemployedbyOlson'sGreenhouseGardens andserveastheDirectorof HumanResources
for
Olson'sGreenhouse
UT,Olson'sof Colorado,
andProGro.Eachorganization alsohasa Human
ResourcesManager.
I havebeenemployed
by Olson'ssinceJanuary18,2016.
I wasintroduced
to Mr.Wangduringthefirstweekof myemployment.Myoriginalofficewasdirectlynextto
Mr.Wang'sofficesowe interacted
on a frequentbasis.Mr.WangandI havealsopartneredon several
projects.
I haveneverknownMr.Wangto beanythingbuta gentleman in theinteractionsI havehadwithhimand
theinteractions
thatI havewitnessedhimhavingwithotherpeoplein theorganization. If anyof Mr.Wang's
co-workershada problemwithhim,if hewastreatinga co-worker improperly,
or actingoutin an
unacceptablemanner,as theDirectorof HumanResources improper conductwouldbe reported to my
office.
Mr.Wangis a peaceable individual.
I haveneverknown,norhasit beenreportedto me,thatMr.Wanghas
evershownviolenttendencies, beenin possession
of a weapon,oractingin a threatening
natureto
anyonein ourthreedivisions.
A fewweeksago( February 20) twoindividuals,
a SalemPoliceOfficeranda Constable, cameto the
Olson'sSalemlocationat approximately 12:20pm, at thetimeI wasin myoffice.. WhileI expectedandwas
notsurprised to seetheSalempoliceofficercarryinga weaponI wasa bit surprised to seetheconstable
attiredsimilarto an officerof thelawandcarryinga sidearmwhenourreceptionist broughtthesemento
myoffice.Thedemeanor andstanceof theconstable wasa bit aggressive
andhestoodin a mannerthat
alwaysputhissidearmbetweenmeandhim.
Thepoliceofficertoldmethattheyhadcometo theoperation
thatdayto talkto Mr.Wang.Theofficersaid
Mr.Wangwasnot"introuble"theysimplyneededto talkto Mr.Wangabouta civilmatterrelatedto his
daughter.
At thatmomentl believedthatMr.Wangwasin ourassembly areatakingsomevideoof a meeting
that
washappening at thetime.I hadseenhimin thatareajusta fewminutesbeforetheofficerandconstable
arrived.I askedmyco-worker, Adrienne
Wall,to stepintotheassembly areaandaskMr.Wangto cometo

000241
 Wang v. Thygesen 194400718
000242

myoffice.Shereturned withina fewminutesto saythatthegrouphadjustdisbanded andMr.Wanghad

lefttheproperty.I offeredto calltheofficerand/orconstablewhenMr.Wangreturned. Theresponse from
theconstable wasthattheywerenotgoingto leavethepropertyuntiltheyhadtheopportunity to talkto Mr.
Wang.I foundthatresponse a bitstrangeandaggressive sincetheofficerhadsaidthatMr.Wangwasnot
in trouble.If notin troublethenwhytheurgencyto speakwithMr.Wang?Andwhytheneedto havea
policeofficeraccompany a constablefora civilmatter?Andwhymakesucha statement to a manager of
thecompany? Wearenotgoingto leaveuntil....? Theywereafterallguestsof thecompany.
Duringmycareerin HumanResources I haveinteracted
withconstables
numerous times,neverhaveI
interacted
witha constable
whois deliveringa civilsummons,
garnishment,
etc.to be attiredas a police
officeandopenlyandaggressivelycarryinga sidearm.
WhenAdriennehadleftto lookfor Mr.Wangsheranintoanotherco-worker andmentioned thatshewas
lookingfor Mr.Wangat myrequest.Thisotherco-worker calledMr.Wangto tellhimthatI waslookingfor
him.Mr.Wangreturned to theproperty
quicklyandcamelookingforme.I ranintoMr.Wangon thehallway
andtoldhimthattwo"cops"wethereto talkto himandwouldhe bewillingto go intomyofficewiththem?
Heagreedto do so butseemeda bit unsettledto havethesemenrequestingan interview.
Mr.Wang,thepoliceofficer,andtheconstable meetin myoffice.At thattimeI leftthepropertyto go to
lunchanduponreturning 45 minuteslaterobserved
thatthecarthatthepoliceofficerandconstable had
arrivedin hadlefttheproperty.
Thisnarrative/letter
represents
mytruthfulrecollection
of theeventsasdescribed.

RandallL Barker
3/12/2019
09:58

000242
 Wang v. Thygesen 194400718
000243

MelisaTodd
140West 9000 South,Suite9
Sandy,Utah 84070
801M566M
1884
[email protected]

February21, 2019

To Whomit Concerns:

On February20, 2019 at approximately3:50 p.m., attorneyJeff Riflemancame into the

officewhere I work and askedme to put myjacket on and comewith him. I heard he was on the
phonewith someonewho soundedprettypanicked. I had heardJeff ask the personon the phone,
"Are they still followingyou?" and the personreply "Yes". Jeff had his phoneon speaker,so I
heardthe back and forthbetweenthem,whileI put myjacket on and followedJeff outside. Within
a minuteof us going outsidea maroonLexus SUV pulled into the parkinglot and parked. Jeff
waived to them, so I knew this was the person he was talking to on the phone. Immediately
followingthe Lexus into the lot was a black DodgeCharger,that parked so it was blockingthe
bank drive thru area. The man jumped out of the Chargerand immediatelywent towards the
Lexus.Jeff walkedbetweenthe two and askedthe man ifhe couldhelp him. The man refusedto
tell Jeff what his name is and who he works for, he just kept statingover and over that "I don't
have to tell you my name." Jeff mentionedthe fact that that man wascarryinga gun and the man
replied, "It is open carry." From the rest of the conversationbetween this man and Jeff I
understoodthey wantedto servesomedocumentson a girl who is the daughterof the mandriving
the Lexusand the assumptionwas that this girl was in the Lexus.
Approximately2-3 minutesinto all this anotherDodgeCharger,charcoalin color,pulled
up and anothermanjumpedout going towardswhat I thoughtat the timewas the man in the Lexus.
However.he too wenttowardsJeff and got into his face. Jeff askedhis name,whichhe did give,
but becauseI was too far away to hear it, I did not catch his name. Jeff tried to get the first man
to tell him why he was harassinghis client by followinghim all the way from SpanishFork to
SandY,after he had alreadybeen to the mans work place and interrogatedhim there,but the man
would only say he had to serve papers on the daughterand wanted to know if she was in the
vehicle. Jeff asked if they were conductinga stop on his client and the man from the charcoal
Chargerstated somethingalong the lines that it was not a stop and that the Lexuswas free to go.
Jeff at this point told me to call 911, whichI proceededto do at 4:12 p.m. I heard the man from
the blackChargerstate they had alreadytalkedto SandyPolice,whichI felt was a way for himto
intimidateme into not calling 911. I gave the 911 operatorall the informationI knew, as I still
was a bit confusedas to what was going on, while trying to keep an eye on what wasgoing on
aroundme. After a bit more conversationbetweenthe two men and Jeff, the two men went to
their own vehicles,and Jeff was able to get his client,his client's wife and their grandbabyout of
the Lexusand into the "Bankof the West" building. I told the 911 operatoreverythingthat was
goingon, as it was happening,includmgthat thesetwo men appearedto be undercovercops,from
lookingat their dressto their cars, but that theywouldnot identify. Frommy personalknowledge
and collegetrainingin CriminalJustice, if a person is asked, they are to identifythat they are a
olice officer if the are in fact one. The black Char er had the " Itce" la to set up, he was
wearingwhatappearedto be "police"unifonnpants 1n the sage greenco or, e so

000243
 Wang v. Thygesen 194400718
000244

issue weapon, and other "police" gear around his belt, he also had on a plain black coat. The man
in the charcoal Charger had on a navy-blue suit jacket and pants with a white shirt and a tie that I
didn't pay too much attention to, his car did not appear to have the laptop setup, but it did have the
police lights. NEITHER car had any lights on to indicate there was an official police stop
happening at any point and time. At this time there was no indication of who these people actually
worked for, other than they were trying to serve a person with documents.
I followed Jeff and his clients into the building but stayed in the entrance way for a bit
longer, so I could finish answering the questions regarding the cars that I was being asked. I was
told to stay on the phone and to let the operator know if the men tried to enter the building, as they
were not to enter it. The first Sandy Police officer arrived, and I went upstairs to Jeffs office to
see ifl could see the officer. When the Sandy officer anived, he first talked to the two men outside,
both of whom identified themselves as working for the Utah County Constables office, showing
him badges, cards and logos on their shirts (this was confirmed by the officer when he joined us
upstairs and a visual as I was watching out the building windows). The Sandy officer came up to
Jeffs office and the two men left in their cars. After the police talked to Jeff about the matter, and
Jeff was able to obtain a case number for his client, I then assisted Jeff in calming down the client
andhjswjfe Itwas at this time, I fully understood how scared these two people were, as they had
been bein 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 a ment1one t at may et ey
should leave and go on a vacation, so they could calm down and beleft alone.

® MDcA\
tu1Li\
Melisa Todd
Affiant
DL# ......... 8034

On the 2151 day of February 2019, personally appeared before me, the undersigned notary,
Melisa Todd, the signer of the foregoing Affidavit, who duly acknowledged to me that she signed
the same voluntarily and for its stated purpose.

TERRYR. SPENCER

®
NOTARY
PUBLIC
-STATE
OFUTAH
My Comm.Exp02/01/2021
Commisslon # 692634

000244
Contact
Patrick Adams
www.linkedin.com/in/patrick- Treatment Coordinator at Salt Lake Legal Defenders
adams-52098182 (LinkedIn) Salt Lake City, Utah, United States

Experience
Salt Lake Legal Defenders
Treatment Coordinator

Page 1 of 1
Contact
Patrick Adams
www.linkedin.com/in/patrick- forensic social worker at consulting LLC
adams-452576121 (LinkedIn) Salt Lake City, Utah, United States

Experience
consulting LLC
forensic social worker

Page 1 of 1
10/3/23, 12:56 PM Gmail - Debbie This Guy from the Salt lake PD attempted to get my Mental Health Records

M Gmail

- Debbie This Guy from the Salt lake PD attempted to get my Mental Health Records

Kailin Wang <[email protected]>

To: Debbie Hill <[email protected]>,
Thu, Mar 2, 2023 at 6:08 PM

Debbie I'm sure you did not send this guy but FYI Thygesen attempted to trick my D.V. Class into disclosing my Mental
Health

2 attachments

•
Screenshot_20230302-180350.png
162K

-
Screenshot_20230302-175640.png
119K

i, I< ij !, h I

Debbie Hill <[email protected]> Thu, Mar 2, 2023 at 6:13 PM

To: Kailin Wang

You are absolutely right - I didn't. We discuss all issues over the phone - I'd never text a request for release of records.
Let's talk Monday - are you free in the afternoon? 2ish?
thanks,
Debbie
[Quoted text hidden]

[Quoted text hidden]

 I t ;1 .•di 93%I 5:56PM

EricLandon
< +18019603040
or wandering around.

> 9:52AM

0 Hi Kailin! A release of
information was emailed to you
for you to fill out. This is asking
for permission that Patrick
Adams can get updates on you
progress. The phone number
is 8019796411 and email is
[email protected]. 5:11 PM

f) :.ntermessage Q
Yes News Oh

1 2 3 4 5 6 7 8 9 0
-r" 1( ... -:;
I - < > I I
Q w E R T y u I 0 p
@ # $ % & '11 (

A s D F G H J K L
7
z X C V B N M 0

English (US)
I •
 I i ?i ..di 91%I 6:03 PM

() i google.com/sear ••
•

(§ News [;;] Images (!] Videos () Sho1

Linkedln ••
•
https://www.linkedin.com > patrick-...

Patrick Adams - forensic social

worker - consulting LLC
Salt Lake City, Utah, United States • forensic social
worker· consulting LLC
Patrick Adams. forensic social worker at consulting
LLC. consulting LLC. Salt Lake City, Utah, United
States. 9 followers ...

••
https://www.linkedin.com > patrick- ... •

Patrick Adams - Salt Lake Legal

Defenders
Salt Lake City, Utah, United States· Treatment
Coordinator· Salt Lake Legal Defenders
Patrick Adams. Treatment Coordinator at Salt Lake
Legal Defenders. Salt Lake Legal Defenders. Salt...
 EXHIBIT 13
In April 2022, I was
employed by Jensen
Hughes, Inc. ("JH"),
which is a company
hired by Ridder,
As part ofmy
Costa & Johnstone
duties at JH, I was
LLP ("RCJ"), to
TIFFANY responsible for
provide professional
BOSTROM monitoring any
services for the
(Jensen Hughs andl all Twitter
22 benefit of RCJ December 2018-Present
formerly accounts associated
(Erica Johnstone's
Hillard and with Kailin Wang
Firm for Thygesen)
Heintz) that were publicly
in the advisement of
accessible on the
their clients. Unless
internet.
otherwise stated, I
have personal
knowledge of the
facts set forth in this
declaration.

In April 2020, I was

employed by Hillard
Heintze LLC"),
which was a
company hired by As part ofmy
Ridder, Costa & duties at HH, I was
Johnstone LLP responsible for
TALIA
("'RCJ"), to provide monitoring any and
BEECHICK
professionals ervices all Twitter accounts
(Jensen Hughs
23 for the benefit of associated with December 2018-Present
formerly
RCJ in the Kailin Wang that
Hillard and
advisement of their were publicly
Heintz)
clients. Unless accessible on the
otherwise stated, I internet.
have personal
knowledge of the
facts set forth in this
declaration.
 l OOiJGLASL. RAPPJ\PORT{SBN ;3<,J94)
Law Offices of Douglas L. Rappaport
2 260 California Slrce., Suite 1002
San Fran;;)\SC.o,
CA 94111
J

4
l Tel: (415) 989-7900
l'11x:(415)981/-i950
DARRICK T. L'HASl:i{SBN 151256)
Kay(\ Mn:wt!JicrbawnFord, LLP
-r'll: Rus,;:Building
235 Montgomery Strrot, 27"' floor
San Fnmcl».-o,CA 94104
7

'
Tel: (415)202·5324

Attorneys for Petitioner

I
i

CHRISTOFFERS fANfORD r:t!YGESFN I

JO
)J IN 'OIE Sl l?ER10Jt COURT OJ'Tiff.. ST,\TE OF C'ALl}.ORNiA
I
12 IN A~D FOR nm COUNTY OF SAN FRANClSCO I
13, I
l4 '! 1-IYGESEN,
CJlfUSTOFH~RSTb.1'-!l'ORD !: CaseNo. FDV-19-814465
IS !>e:itioner, OECLARAT{ONOFTALIA 8EECHICK
ISO Ph"flTIONf.R'S MOTJON TO
16 V. ENFORC'f: rs
RESPONDEN
17 KAILINWANG, I ST.lPULA!JOh ON THE REC~R~ TO
RtoMOVE/RtDACT THE Ml SOR S
:I l{)ENTIFYINGINFORMA'CTON
FROM
rn ~pomknt HhR ONLINE POSTINGS
:
19
20
Ij Date: :';11.1y
18, 7022
Time: l;)Op.1R
Dept,,405
2l
22
______ j
23 l, Talia [kecnkk, do hereby dech\N:

24 L In April 2C20.; wai; ernplu:,ed by lliilaro llcinuc LLC (~HH), which wi:s a
25 , ~puny hired by Ridder, Cooh1& fohns\onc LLP {"ilC'J"),to provide professional 11erviccs(or

7;, the bttlelitofRCJ ir,th<:ad¥isementohheir clients, lJnk.isotllctwise~Ul!etl,I ht1¥¢pers¢nal

27 knowledge of!hc facts se: forth in this declaration.

''
 )' and_,alU~itted
IICCOWllS a • in Wang that were ublicly accessible on the internet.

3 3. On April I0, 2020, while viewing the Twitter account entitled ''Ka Hin Wang
4 @kk978678,'' I viewed a Post ("Post") with the URI. IU1ps://twitter.ct1m/kk978678/wilh_replies.

5 4. On April 10, 2020, after viewing this Post, I captured the exact image of !his Post
6 at J:3:07:S'>GMT.
7 5. On May 11, 2022, I f'(:viewe<l
page 1 ofExhihit 4 of Petitioner"s Moli(m To
8 Enfo~ Respondent's Stipulation On 'The ~l.>rd To R~move/Red1tc1
The Minor's ldc::nlifying

9 lnfonnotion From I JeeOnline Postings lodged with the Court on April 12. 2022.
10 6. Page I of Exhibit 4 is a fairand accurotc printed representation of the Post as it
11 exactly appeared on the internet on April 10,2020. at 13:07:59 GMT.
l2 I declare under penalty of perjury under the laws of the State of California that the

13 foregoingis true and correct.

14
15 Dated: 41(, Zo:12 Dye_~~-
~~ck
16
17

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24

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l Ca« No. l'DV-19-81tt6S

 I DOUGLAS L RAPPAPORT (SBN 1)6194)
Law Offices ofDuuglas I . Rappaport
2 260 Califomia Stred, Su!le 1002
Sanfl'llndsco, CA 941 ! 1
3 Tel: {415)989-790C1
Fax· (415)939-7950
4
DARRICK T. CllASE (SBN 151256)
; Kaye MoSfr HicrbaumFod, LLP
The Ru~ Build1t1g
235 ¥o~!TICJ'f Stre~t,27"' Floor
Sar: franrhco, C/\ 94 ,34
Td: {415)201-5824

Attorneys for P;:titione.r

9 CHRJSrOFFER :)TA'.'iFORDTJIYOESE\'
rn
I' IN THE Sl}Pl'.l{l(}R COURT OF THC STATE OF CI\LIFORNIA

12 IN AND FOR THE COUNTY OF S..\N FRANCISCO

"
14 CHRISTOf'FER:STANFORDTHYGESEN. ICase Nv. FfiV-l9-Sl4%5
15 f'ttition~r.
I
DECLARA710N OF TIFFANY
BOSTROM JSO PETITIONER ·s
16 MOnoN TO ENfORCh
RESPONDENT'S-STlPVL.\ TIO~ ON
17 KAlll:'>i WANG,
I THJ:,RECORDTO REMOVE/REDACT
THE MINOR'S IDENTIFYING

"
19
TNFORMATION FROM HFR ONUNE
POSTINGS

20 Date. May Ht 2022

Time: IJOp,m.
2l Dep:.: 405

I, TUfa:,:yBvs!rom,00 h~reby<k;,;:larc:
l. In Ar,ril2022, 11'-Mffllployedby Jrnsen Hughe&,Inc. (ilJH").whkh i~a
25
Ridder, Cosla & .fohn~tnneLf,P \RCT). to provid<c
t-0mp;rnyhirnd l-1:, pmti.::s~1Qr:al
servi~s fur
the b~nefit ofRCJ in the advi'l<'mentoft:l.dr clients. Cnka,; otiu:rwhn sta:ed, J hwe perro:inl

,, knov, ledge of tht facts !setfrirth in this declari!Iioo.

 2. ~Elin ofmy duties at JH. I was_re~12on~ible-for
monitoring any and all Twitter)

@ (accounts associated witlt Kailin Wang th111were E!Ubliclvaccessible on the internet]

3 3. On April 4, 2022, while viewing the Twitter account entitled "Kail in Wang
4 ~!'YkwlTI4,"I viewed a Post ("Po~") with the URI.

5 https://twittcr .c,1m/kwffl4/status/12483 799787244 58496.

6 4. On Apri I 4, 2022, after viewing this Post, I captured the exact image of this Post
7 at 17:56:01 GMT.

8 5. On May 1 I, 2022, I reviewed page 2 of Exhibit 4 of Petitioner's Motion To

9 Enforce Respondent's Stipulation On The Record To Remove/Redact The Minor's Identifying

IO Information From Her Online Postiogs lodged with the Court on April 12, 2022.
6. Page 2 of Exhibit 4 is a fair and accurate primed repr~seotation of the Post as it
12 exactly appeared on the internet on April 4, 2022, al l?:56:0 l GMT.

I3 I declare under penalty of perjury under the laws of the State.of California that the
14 foregoing is true anti corret:t.

15
16 Dated: May11,2022

17

18

19

20

21

22

23
24

25

26

27

28

2 C= ""· FOV-19../114465
 EXHIBIT 14
Private Investigator,
Matthew Dennis.
(11/18/21 RT 3:1-3,
RT 6:1-28)
Matthew Dennis is a
20 Matthew Dennis Private Investigator Security Detail December 2018-Present
(PI) hired by the
Thygesen family to
surveillance the Wang
Family at Terra Firma,
and at Rally.

''Private Investigator,
Matthew Dennis.
(11/18/21 RT 3:1-3,
RT 6:1-28)
Matthew Dennis is a
Gregory
21 Private Investigator Security Detail December 2018-Present
Johnson
(PI) hired by the
Thygesen family to
surveillance the Wang
Family at Terra Firma,
and at Rally."
SECURE OUTCOMES PROTECTION INC.
May 4, 2021

Matthew Dennis' Statement

I, Matthew Dennis, am employed as a security agent at Secure Outcomes Protection, Inc.

In the course of my employment, I was assigned to observe and secure the safety of
Christoffer Thygesen and his baby, - Wang. on September 30, 2020. As part of my
assignment on that day, I conducted observation of Terra Finna, the supervised visitation
racility where Christoffer was to drop off- for- visit with his biological
mother, Kailin Wang.

During the course of my observation from a secured position, I noted the rollowing:

1618: Kailin Wang. .John Wang, and Jan Wang arrived at Terra Finna, in BMW XS
B53-8EA UT plate.
Wang Family made 3 passes driving in the rear parking lot, filming out of the car
window on 3rd pass. It appeared that they were filming the rear of the Terra Firma
facility where the visit wa to take place.

1700: Christoffer Thygcscn delivered baby to Terra Firrna.

1920: Visitation ended. CT retrieved baby from Terra Firma, departed Hayward.

1920: Surveillance terminated.

Mathew Dennis

PO Box 980333
PHONE (209) 769-4483
West
EMAIL [email protected]
Sacramento CA
95798 WEBSITE WWW.SecureOutcomes.com
 SECURE OUTCOMES PROTECTION INC.
May 4, 2021

Gregory Johnson's Statement

I, Gregory Johnson, am employed as a security agent at Secure Outcomes

Protection, Inc.

In the course of my employment, I was assigned to observe and secure the

safety of ChristofferThygesen and his baby son, - Wang, on October 14,
2020. As part of my assignment on that day, I conducted observation of Terra
Firma, the supervised visitation facility where Christoffer was to drop off-
for-visit with his biological mother, Kail in Wang.

During the course of my observation from a secured position, I noted the

following:

1622 John Wang's Vehicle BMW X5, Utah Plates, entered the front parking lot.
The vehicle circled the parking lot to Pupuseria restaurant (aprox 200 feet) with a
cell phone in recording position. It appeared as if they were filming the Terra
Firma facility.

1628 Kailin Wang and her parents John Wang and Jan Wang enter Terra Firma
via rear door.

1657 ChristofferThygesen delivered- to Terra Firma.

1739 ChristofferThygesen retrieved-I observed John Wang,Jan Wang

and Kail in Wang depart--'ferra Firma.

~/1
//7 /~

/ Gregor ifJoh son

POBox 980333 PHONE (209) 769-4483

w. Sacramento EMAIL [email protected]
CA95798 WEBSITE WWW.SecureOutcomes.com
 •
From: Kailin Wang [email protected]
Subject: Abduction Observations in Case FDV-19-814465: Christoffer Thygesen v. Kailin Wang
Date: July 26, 2021 at 1:55 PM
To: Bertha Cuellar [email protected]

Hi Bertha,

This is Kailin Wang, I used your facility for Supervised Visitation with:

Child:
-T. Wang
Custodial Parent: Christoffer S. Thygesen

for Court Ordered visits through the San Francisco Superior Court Case No.
FDV-19-814465, on the following dates:
1. September 03,2020
2. September 30, 2020
3. September 16, 2020
4. October 14,2020
as per Terra Firma Policies Terra Firma/SV Contract

PARENT22. Prior to a scheduled visit, the Custodial Parent will park in

front and enter Terra Firma’s premises through the front door. The
Visiting Parent will park in the back and enter Terra Firma’s premises
through the back door. This also means the Custodial Parent should not
be driving anywhere in the back side where the Visiting Parent is
parked and the Visiting Parent should not be driving through the
front area where the Custodial Parent is parked. Non-compliance of this
rule will result in termination of that visit and the person responsible for the
termination will be charged for the visit. This includes any additional guests,
family or friends before and after the visit.

There has been a Criminal Investigation by Utah Investigator Richard C.

Hales, Affidavit for Search Warrant No. 2267231, Utah Criminal Case no.
211100167

-
10. In February 2021, Ms. Wang attempted to obtain personal information
and the US Passport of (Liam) Thygesen, 2-years-old. Ms. Wang
has no legal custody of the boy as ordered by a California Court. Ms. Wang
and her parents, John Wang and Jan Cheng, have been seen at Terra
Firma, a visitation center located in Hayward, CA. They were video

1.
-
recording the exterior of the visitation center, therefore, posing a
possible threat of abduction of (Liam) Thygesen from Christoffer
Thygesen, the boy's father who has full custody.

From your professional observation, did you observe during those four visits of
any signs of abduction by Kailin Wang? Did you make that statement to the

921
 any signs of abduction by Kailin Wang? Did you make that statement to the
Utah Police Richard C. Hales?
2. And did Utah Investigator Richard C. Hales contact Terra Firma about
this alleged incident above?

*Please let me know if you have any further questions.

Thank you,
--
Kailin Wang
Phone: 801-645-1060

922
 From: Bertha Cuellar [email protected]
Subject: Re: Abduction Risk
Date: July 26, 2021 at 5:47 PM
To: Kailin Wang [email protected]

No , I did not.

Get Outlook for iOS

From: Kailin Wang <[email protected]>

-----
Sent: Monday, July 26, 2021 4:36:08 PM
To: Bertha Cuellar <bcuellar@terrafirmadiversion.com>
Subject: AbducMon Risk
Hello,

This maybe more simple and straightforward.

Did you witness, obeserve any Abduction risk in the visits attended by the parties at Terra Firma?

Thanks

920
 Terra Firma/SV Contract
TERRA FIRMA COPY

16. We are mandated reporters and are required by law to report any reasonable suspicion of
child abuse or neglect. This includes physical, sexual, extreme emotional abuse or physical
neglect including the child’s direct exposure to domestic violence.

17. Neither the visiting site nor the child may be used to pass messages, make child support
payments, serve papers to the other parent or call the police. Any attempt to pass messages,
call the police or serve papers either inside or outside of the premises can result in termination
of services at Terra Firma. If there is information that needs to be exchanged concerning the
child, it can be passed only through the Supervisor and at the Supervisor’s discretion or by
court order.

18. Picture taking is not allowed. No exceptions.

19. Your cell phone is to be powered off during all supervised visits. Unless, your are playing
games, watching a movie, looking at pictures and/or listening to music. Using your cell phone
during visits for any other purposes can result in having your cell phone turned off or not
allowed to be brought in during the entire visitation time. If you absolutely have to take a call
for a specific reason, please alert the Supervisor. You will have to leave the room to take the
call.

20. VIDEOTAPING and AUDIO RECORDING is not allowed during any visits. This will result in
automatic termination of the visit. Additionally, you will be required to pay for the visit
regardless. No exceptions.

21. Supervised visitations may include going outside, walking to the park and/or any other nearby
facilities within the surrounding area. If the Visiting Parent wants to schedule a visit outside
of Terra Firma’s premises, additional fees will be applied based on location, time, and
entrance fees, etc. Terra Firma does not transport. Once an outside visit is confirmed, the
Custodial Parent will meet the Supervisor ten (10) minutes prior to the scheduled visit at the
front entrance and before the Visiting Parent arrives.

22. Prior to a scheduled visit, the Custodial Parent will park in front and enter Terra Firma’s
premises through the front door. The Visiting Parent will park in the back and enter Terra
Firma’s premises through the back door. This also means the Custodial Parent should not
be driving anywhere in the back side where the Visiting Parent is parked and the Visiting
Parent should not be driving through the front area where the Custodial Parent is parked.
Non-compliance of this rule will result in termination of that visit and the person responsible
for the termination will be charged for the visit. This includes any additional guests, family or
friends before and after the visit.
 From: John Wang
Subject: License Plate Number of the car parked at back of Terra Firma
Date: September 18, 2020 at 10:01 PM
To:

6VHT147 CA
Honda CRV
•

260
8/14/2021 Gmail - Terra Firma Thygesen's PI's in the "Rear" Entrance

Gmail Kailin Wang

Terra Firma Thygesen's PI's in the "Rear" Entrance

3 messages

Kailin Wang Wed, Aug 11, 2021 at 1:35 PM

2 attachments
9-5 Security Report 9 30 20 MD.pdf
212K
9-6 Security Report 10 14 20 GJ.pdf
33K

Wed, Aug 11, 2021 at 1:46 PM

We took the photo to find out why this car was out there every time while we arrived for the visitation (which violated the
facility policy). That is the photo I took and it only shows the car and its license plate and the background is not Terra
Firma's back building as the car parked away from the back entrance of the building. The PI is totally a lier!

Wed, Aug 11, 2021 at 1:50 PM

1/2
(3) Controlling, regulating, or monitoring the other party’s movements, communications, daily
behavior, finances, economic resources, or access to services.Since 2019 Allan Thygesen CEO of
DocuSign paid to have his Agents to Follow, Stalk, and Surveil the Wang's in another attempt to
Falsely incriminate her on bogus Criminal Charges.

https://thygesenvwang.blogspot.com/2023/06/false-kidnapping-police-reports-are.html

The Wang's are constantly afraid for their lives and documented Thygesens' abuse, his agents
following them, however when caught red-handed Thygesen instead then made a False Police
report that the Wang's were 'casing' the Supervised Visitation in order to kidnap the child, clearly
this is outrageously false.

However the Thygesens' were able to convince the authorities to issue a search warrant to search
Wang's issue Statements to the Police that Wang was seen "casing" the area around Terra Firma
located in Alameda, California in an attempt to the Kidnap the child.

SECURE OUTCOMES PROTECTION INC.

l\lay 4. 2021

l\latthew Dennis' Statc111cnt

I. Mauhew Dennis. am employed as a security agent a1Secure Ou1comcs Pro1ec1io11,

Inc.

I II the course of my cmpluymcnt, I w,1sassigned 10observe ,rnclsecure the safety of

Christoffer Thygcscu and his baby. -on September 30. 2020. As pan or my
assignment on tha1day, I conducted obscrva1ion of Terra Firma, the su1iervised visitation
focilily where Christollcr was 10drop off- for - visit with his biological
mother, Kail in Wang.

During 1hccourse of my observation rrom a secured position. I noted the following:

:mwcd al Terra Finna. in

1618: Kail in \Vang. John \Vang, and .Ian W:111g
-UTpla1c.
Wang Family made 3 passesdriving in the rear p.irking~lming oul of the car
window on 3rd pass. Ii appeared that they were filming 1hc rear of the Terra Firma
focili1y where the visi1 was 10 1ah: place.

1700: Christoffer Thygcscn dcl ivcrcd baby to Term Firrna.

1920: Visiw1io11ended. CT retrieved baby from Terra Finna, dc1)artedHayward.

I 920: Surveillance 1cnniua1ed.

Statement by Thygesen's Agent Matthew Dennis Admitting They were surveilling the Wang's in the
"rear" of Terra Firma the Non-Custodial Parent's Designating Entrance
 Thygesen then makes a False Police Report to Utah DA Investigator Richard Hales that he saw
Wang's casing Terra Firma and that this was an Abduction/Kidnapping Attempt

On 6/1/21 Utah Richard Hales Executes based on Douglas L. Rappaports' False Allegations, and
Staging of a Kidnapping, with this False information Sgt. Richard Hales Issued a Search Warrant
based on this False Information on Wang's Home, obviously nothing relevant was found, because
Thygesen and his attorneys lied.

1o. ted to obtain personal information

and the 2-years-old. Ms. Wang has
no legal custody of the boy as ordered by a California Court. Ms. Wang and her
parents, have been seen at Terra Firma, a visitation
center located in Hayward, CA. They were video recording the exterior of the
visitation center. therefore, posing a possible threat of abduction of
-from Christoffer Thygesen the boy's father who has full custody.

11. The investigation indicates some of the subpoenas issued by

Ms. Wang have been honored. Preliminary information indicates its possible

- Page 3 of Allidavil tor Search Warrant No. ::>267?31 -

Thygesen Paid Douglas Rappaport to Lie and Stage a Fake Crime and communicated False
Kidnapping allegations to Utah County District Attorney Investigator Richard Hales which resulted
in a SWAT search of Wang's home NOTHING WAS FOUND!!!!

On 7/19/21 Thygesen's attorney Douglas Rappaport further used Utah Sgt. Richard Hales as
a conduit by telling the court that an Officer a Police Sargent concluded a Possible Kidnapping
Attempt (although it was Thygesen who had Rappaport first spread the lies about the Terra Firma
Incident), in an attempt to further Terminate all Visitation between Wang and her then 3 year old
son. This is the sickening, highly unethical and fraudulent nature of Thygesen, and their attorneys
a.k.a Google Grandpa, Current DocuSign CEO.
 4 MR. RAPPAPORT: Thank you, Your Honor.
5 Contrary to Ms. Wang's statement, there

6 is something very new. Within a week of filing the

7 Ex Parte rec!uest to temporarily suspend the in-person
8 visitation, the in-person visitation in lieu of video

9 visitation. There we received a sworn statement from an

10 • iiicer of the law stating that there appear to be an
11 abduction risk. He swore that --
12 MS. WANG: Who gave him that information?
13 THE COURT: Ms. Wang, Ms. Wang, please do not
14 interrupt. I'm going to ask that you not interrupt. I

15 will give you a brief opportunity to respond.

16 MR. Rl'.PPAPORT: He swore that under penalty of
17 as a statement to a court in order to obtain a
18 Search Warrant from Ms. Wang's home and Ms. Wang's

19 computer and electronic data, it is a sworn statement in

20 which the officer stated -- inspector, actually, states

21 that it wasn't just the fact that she was seen
22 videotaping the back of Terra Firma.

Thygesen's Hired Liar Attorney Douglas Rappaport using Utah County DA Investigator Richard
Hales as a conduit for his lies.

22. Prior to a scheduled visit, the Custodial Parent wi// park in front and enter Terra Firma's
premises through the front door. The Visiting Parent will park in the back and enter Terra
Firma's premises through the bacts door This also means the Custodia Parent should not
be driving anywhere in the back side wher.e !be Visiting Parent is p_arkedand the Visiting
Parent should not be driving through the front area where tneCustodial Parent is parked.
Non-compliance of this rule will result in termination of that visit and the per.,on respnnsihlr,
for tile termination will be charged for the visit. This includes any additional guests, family or
friends before and after the visit.

Terra Firma Policies which Thygesen signed knowingly yet no only violated this by hiring agents to
surveil, stalk and harass the Wang's he additional staged a Fake Crime and Falsely reported
Kidnapping Allegations.
Thygesen deliberately omitted material
information, he withheld that the Terra Firma
Policy FORBIDS THE PARENT W. CUSTODY TO
BE WAITING IN THE DESIGNATED ENTRANCE
OF THE NON-CUSTODIAL PARENT.
Under California law, telling only part of the truth in any court filing by an attorney is the
same as telling a lie, and withholding, concealing, or omitting relevant information in
court filings is the same as telling a lie. And is considered fraud on the court, according to
the State Bar. A lawyer who tells a half-truth in court or in court filings is considered to have told
an outright lie. Under state attorney ethical standards, an attorney who withholds or conceals
material facts or information from a judge also is guilty of lying, according to the State Bar.

Thygesen continues to have us stalked, surveilled in an attempt to again have me falsely prosecuted again.

Do you see the license plate number (6VHT147) in the Green

car at Terra Firma?

In the photo in an email dated 9/18/20 below of the Green Honda license plate
number (6VHT147) that picture was taken in September 2020.
 Gmail

License Plate Number of the car parked at back of Terra Firma

3 messages

John Wang Fri, Sep 18, 2020 at 10:00 PM

To:

6VHT147 CA
Honda CRV

Now almost 3 years later that exact same car with the exact
same license plate (6VHT147) was seen surveilling us outside Rally
San Mateo on June 11, 2023 !
 The exact same car with the exact same license
number (6VHT147) was surveilling us before I arrived for my Rally
visit, and was still surveilling us after my visit.
Thygesen continues his campaign of Terror and Attempts to Fake, Manipulate new Criminal Charges.

Clearly, Thygesen feels that the Rally rules and policies do not apply to him. Thygesen has made numerous false
police reports at Rally despite him violating the law by again having his private investigators Surveil us before and after
his designated arrival and departure time, this is frightening because last time he falsely accused us of kidnapping the
child when we documented his agents following us, he is literally covering up his illegal activities with false allegations to
the police about me, can Rally document again that Thygesen has been warned.

On June 17, 2021 Rally Staff sent the following e-mail to Father:

Hello Mr. Thygesen,

This is a_T_riencllv
reminc er !hat per Rall).'g11iclelines,"Pare11tsare a.<Jie'il1101to hri11g
a1111,me
else lt>JJJil'acility_
or surroundmg areas when vis1ti11g
at Rally_."

Please let us know if you have any questions.

Thygesen on numerous occasions June 2, 2022 had a Black Jeep wait on-site at
Rally to Stalk, Surveil, and film the Wang's the Black Jeep was surveilling the Wang's
before Thygesen arrived with the child, and would wait long after Thygesen has left with the child.
See Previous False Kidnapping Allegations Thygesen has made against Wang at Terra Firma.

.T1111e
1. 1012 q,,-11er.M11
,•isit)
The Visiting Parent and Grandparents anived at their designaced a.nival ti.me witl1one big
suitcase and a cany-oo. As Staff was escorti.ng tl1em 10tl1eVisitation room. the Vi.sitingParent
showed Staff a picrurc on her phone of a black Jeep car with no license plate. The Vi.siting
Parent stated tliat the car was following them 01~their way to tbe visit and that it was parked
outside the building. The Vi.siting Parent also mentioned tl1atthey were concerned about their
safety and she also mentioned that these were private investigators hired by the Custodial Parent
and his fanni.ly.The Vi.siting P,nent added that 11rishappened before and that it had been
documented but that the Custodial Parent bed to the court. Staff informed the Visiting Parent tltal
all they could was document what she was reporting to Staff. Once tl1ey were in the visitation
room Staff checked the suitcases and tl1ey had books, toys, markers colors. and some drinks such
as yogrn1. As Staff was checking the suitcases. the Visiting Parent mentioned that they wanted
the court to know about them being followed indicating the Custodial Parent came from a
wealthy family and they had lied to court i.nprevious l!earings. TI1e Custodial Parent and-
arrived at their designated aJTi:valtime then Staff escorted - to the Visitation room.
June 2, 2022 Thygesen's PI's Surveilling in Black Jeep the Wang's Onsite at Rally Before Thygesen
arrived w/ Child
 •
. , '"-'
·"•,.. •
-
~◄
'""·i
. ,.
~~ .- . "
' ... .. . .
~

June 2, 2022 Thygesen's PI's Surveilling in Black Jeep the Wang's Onsite at Rally Before Thygesen
arrived w/ Child

On June 30, 2022 Terry Thygesen made another False Kidnapping Police Report
against the Wang's at Rally Visitation, by false stating Wang approached their
security team who again were Stalking, Surveilling, the Wangs' for no apparent
reason except to make new False Allegations against them by filming them, or to
prompt more False Kidnapping Police Reports in efforts to have Wang falsely
indicted.
 ----------

SAN MATF.O POI.ICE DEPARTMENT

Sr ·r~
-1 -.: l,Pl H1 F. 'A[ I.

\Im l.ewl

lli:2, 02
Id: l
~-----------~'in IHIIII
Te }' Th~•ge-sen l'IGAIN
e-alled 911 ,aking ALS
K- r apping A!le or 5
he 'l.!",'ang's

·\ i 10 " \,-'. 'I" 1- '(}\"• ·, C

'I. l'J":,;n C,,; . 0 \~,•1::
:_1,:s ,\ClO ~f11' •. :n TIIII~ClJ RDS.. 'r A. S-r

Kailin Wang <[email protected]>

to Shared T
@ Tue, Aug 9, 2022, 3:52 PM * +-,

Thank you, and noted, thank you for letting me know right away~ Absolutely, these issues will only be addressed before and after the visit, not during.

There was a car with a man waiting in a blac Tesla on 8/4/22 with no license plates in the front and a sticker license plate in the back.

Back on March 24, 20222, the same day the San Mateo Police showed up @ Rally, this jeeR with no front nor back license plate was surveilling us.

On June 17, 2021 Rall}_'Staff sent the following e-mail to Father·

Hello Mr. Thxgesen

([M! is ajjiendll1..£2!!1inderthatp_er Rally_guidelines "Parents are asked not to bring anyone else to the facility or surrounding area,,;when visiting at Ral/J;_•."

Please let us know i[y_ou have an]!__questions

Thank you for the update, see you Thursday Aug. 11, 2022.

Kailin Wang

KailinWang
Phone: 801-645-1060

5 Attachments • Scanned by Gmail CD

..,.._,_ ___ _......

.._,.,_,_ ........ _
ImSurveillancing No ...
Thygesen on July 16, 2023 again had his agents wait in the
same Black Jeep at Rally On-Site, this is continuous course
of conduct in violation of Cal. Fam. Code § 6320 (“monitoring
the other party's movements,”)

July 16, 2023 Thygesen again had PI's Surveilling in Black Jeep the Wang's Onsite at Rally Before
Thygesen arrived w/ Child, This is another attempt to Stage a Fake Crime
July 16, 2023 Thygesen again had PI's Surveilling in Black Jeep the Wang's Onsite at Rally Before
Thygesen arrived w/ Child, This is another attempt to Stage a Fake Crime
July 16, 2023 Thygesen again had PI's Surveilling in Black Jeep the Wang's Onsite at Rally Before
Thygesen arrived w/ Child, This is another attempt to Stage a Fake Crime
July 16, 2023 Thygesen again had PI's Surveilling in Black Jeep the Wang's Onsite at Rally Before
Thygesen arrived w/ Child, This is another attempt to Stage a Fake Crime

Thygesens' due to Allan Thygesen's $86 Million+ in salary as the

CEO of DocuSign never feels as laws, or policies of Rally, Terra
Firma should ever apply to them, they feel as if they are above
the law, that it does not apply to them that cannot be tolerated.
OVERVIEW OF OBSERVATION NOTES:
For the period of time covered by this case report, two (2) in-person visits were scheduled
to occur, and two (2) actually tookplace. The complete obsetvation notes. as documented by
Rally Staff are included in this report for review by the Court at the next sched11ledbeari11g.

Cancellations, No-shows, Late/early arrivals:

Date: Parent: Reason (if any provided):

March 24, 2022 {In-person visit)

Five (5) hours prfor 10 the visil's desif!!!_ateds1art time. a police officer an'ive<l at Rally

as.ldng]o speak to Staff aoout the vfsit. The polrce officer ex_plainedtbafthere were some

concerns maae a11dasked to talk about the plans for the visit. TJ1eSu e1visor spoke to tbe >olice

officer and be said 1.ba11heCustodial Parent's Molhefb1,1dcallea and voiced concerns abol.\l the

visit He added that the Custodial Parent's~\1ofher indicated that the Visiting Parent posted

details-on a social \nedia platform about the visit's location and also posted the schedule when

t}ieVisit.ipg Parent was attending \he visit. The Supervisor told,hiru, that Ra,lly had Jl},eirown

policies that were placed in,to ensure the safety of the Child and would be implemented if

needed ...'fhe police officer mentioned that as a precautionary measure. he would remain near the

area io case something happened during the visit, Tb~poli.ce o£ficer t.Qanketl,Staff ,wd left the

Rally.

The Visiting Parent, Grandmother, and Grandfather arrived at their designated time. The

Grandfather placed two (2) bags of his personal belongings in a room. Staff check-ed the bags

and in the bags. it contained books, toys, and some sealed beverages. Aftenvards, Staff esc.orted
 _________________________________________________________________

IN THE FOURTH DISTRICT COURT - ALL DEPARTMENT

IN AND FOR UTAH COUNTY, STATE OF UTAH

_________________________________________________

AFFIDAVIT FOR SEARCH WARRANT

STATE OF UTAH )
:ss
County of Utah )

The undersigned affiant, Sergeant RICHARD HALES of UCAO-BOI, upon an oath or

written affidavit subscribed under criminal penalty, declares:

That your affiant has reason to believe:

THAT

On the premises known as 2481 Fairway Dr.

Spanish Fork, Utah 84660, further described as The home is located on Fairway
Drive with the front facing the street. The rear facing the 16th hole of The Oaks
Golf Course. The home shares a common wall with 2485. The garage is on the
north side at a lower elevation than the front door. The numbers 2481 are above
the garage door. It is tan stucco with brown garage door and front entry door that
is partially enclosed by a covered porch/entrance.;

In the City of SPANISH FORK, County of Utah, State of Utah, there is now certain
property or evidence described as:

To seize any computer, cell phone, electronic device, paper documents or

electronic storage device capable of creating, storing, or transmitting information
related to the creation of unauthorized or fraudulent subpoena documents.

and that said property or evidence:

Was unlawfully acquired or is unlawfully possessed;

has been used or is possessed for the purpose of being used to commit or
conceal the commission of an offense; or

is evidence of illegal conduct.

- Page 1 of Affidavit for Search Warrant No. 2267231 -

 5. Ms. Wang, without consent or knowledge of Judge Low, has used the
Court’s authority to issue at least ten out of state subpoenas. Ms. Wang copied the
original Utah Court order dated June 4, 2020 in order to support the domestication
of fraudulent subpoenas through the California courts. In creating these fraudulent
subpoenas, Ms. Wang used a computer to electronically create the subpoenas,
then served the subpoenas electronically to the businesses.

6. I have obtained copies of the fraudulent subpoenas. All of the

subpoenas direct the recipient to return the requested information to Kailin Wang
either electronically by PDF at email address [email protected] or to the
physical address of 2481 Fairway Drive, Spanish Fork, UT 84660.

7. On March 12, 2021, Inspector Matt Broad of the San Mateo

County District Attorney’s Office received information from Comcast relevant
to a search warrant issued by his office. The search warrant was for related
information to IP addresses and location information related to email address
[email protected]. The certified documents from Comcast returned to the
location 2481 Fairway Drive, Spanish Fork, UT 84660. The subscriber information
was John Wang at the same address. (John Wang is Kalin Wang’s father.) The
IP addresses used to obtain and serve the subpoenas matched the subscriber
information.

8. Ms. Wang has personally communicated either by phone or email with

parties receiving the subpoenas in California. She has negotiated time extensions
by phone with at least one party using phone number (801) 645-1060. This phone
number is registered to K. Wang using T-Mobile service. Ms. Wang represented,
both by email and voice, she has the Court’s authority to issue the subpoenas. Ms.
Wang used the email address [email protected] in her correspondence.

9. Amber Evans, custodian of records for the 4th District Court, State of Utah
has verified the original order on June 4, 2020 is a valid order. The custodian of
records has confirmed there is no record of the additional subpoenas issued by
Ms. Wang other than the original two mentioned in paragraph 4.

10.

--
In February 2021, Ms. Wang attempted to obtain personal information
and the US Passport of ( Thygesen, 2-years-old. Ms. Wang has
no legal custody of the boy as ordered by a California Court. Ms. Wang and her
parents, John Wang and Jan Cheng, have been seen at Terra Firma, a visitation

visitation center, therefore, posing a possible threat of abduction of

--
center located in Hayward, CA. They were video recording the exterior of the

Thygesen from Christoffer Thygesen, the boy’s father who has full custody.
(

-
11. The investigation indicates some of the subpoenas issued by
Ms. Wang have been honored. Preliminary information indicates its possible

- Page 3 of Affidavit for Search Warrant No. 2267231 -

 EXHIBIT 15
In March of 2019
Thygesen hired Mark
Brenzinger to falsely
state that Wang made
Mark
the March 6, 2019
Brenzinger
26 "KillBaby K"post December 2018-Present
Psychologist,
and had him lie to law
PsyD
enforcement and Utah
DCFS about Wang
have Severe Mental
Disorders

.. Sheet1 Sheet2
9/7/2019 Dr. Mark Brenzinger, PsyD, Psychologist, Schaumburg, IL, 60194 | Psychology Today

City, Zip or Name

Home >Mark
IL > Brenzinger
Schaumburg
Psychologist, PsyD
Mark Brenzinger
Psychologist, PsyD
Verified by Psychology Today
Email Me (847) 603-4745

(847) 603-4745

Email Me

Midwest Behavioral Risk Management, P.C.

869 East Schaumburg Road
Suite 252
Schaumburg, Illinois 60194
(847) 603-4745

I provide Forensic and Clinical Evaluations / Consultation Services in the Chicagoland area and
Nationally. Psychological Evaluation Services: Psychosexual Risk Evaluation (Pre-Trial, Post-
Conviction / Pre-Sentence, Post-Sentence and for DCFS); Sex Offender Evaluation (State and
Federal Cases); Psychosexual Evaluation (Sexually Problematic Behaviors / Addiction); Violence
Risk and Threat Assessment (Workplace, K-12, University, and Private Individuals); Mental Health
Certification for Firearm Possession Evaluation (IL-FOID). Clients include adult and adolescent
males and females.

I also provide Fitness for Duty Evaluation (Public Safety Personnel and Corporate Employees);
Independent Medical Examination (IME); and General Evaluation (Mental Status, Cognitive
Functioning, Psychopathology, Substance Use).

I hold the following Illinois Licenses: Clinical Psychologist, Sex Offender Evaluator and
Treatment Provider. I am a Member of the Cook County SOMB; Approved Provider for
https://www.psychologytoday.com/us/therapists/mark-brenzinger-schaumburg-il/231811 1/4
 IN THE FOURTH JUDICIAL DISTRICT COURT
OF UTAH COUNTY, STATE OF UTAH

)
KAILIN WANG, )
)
Petitioner, )
)
vs. ) Case No. 194400718 PT
)
CHRISTOFFER STANFORD THYGESEN, )
)
Respondent. )
)

911 Call
Electronically Recorded on
March 6, 2019

Transcribed by: Natalie Lake, OCT

152 E. Katresha St.

Grantsville, UT 84029
Telephone: (435) 590-5575

-1-
 1 P R O C E E D I N G S

2 (Electronically recorded on March 6, 2019)

3 OPERATOR: March 6, 2019, 14:12:23.

4 911 OPERATOR: Police and fire dispatch.

5 MR. BRENZINGER: Hi. My name is Mark Brenzinger.

6 I’m calling from Chicago. I work at a private security risk

7 management firm, and we have an emergent situation in your

8 jurisdiction. I was hoping to speak with -- we’ve been working

9 with your constable in the area, and he’s been working with a

10 sergeant, and we have some information we want to share with

11 you in a fresh court order. Is there any way you can get

12 connected to a watch commander or a sergeant?

13 911 OPERATOR: For what city, sir?

14 MR. BRENZINGER: Spanish Fork’s.

15 911 OPERATOR: Let’s see. Yeah, I can go ahead and

16 get your information and then ask a sergeant to give you a call

17 back.

18 MR. BRENZINGER: Okay. The long and the short of it

19 is we have a court order coming out of California that’s

20 allowing -- it’s allowing law enforcement to go and remove a

21 child that is at risk right now and hand that child over to the

22 biological father, who is en route.

23 911 OPERATOR: Okay. Sir, can I have your phone

24 number?

25 MR. BRENZINGER: Yes. It’s 847-306-2220.

-2-
 1 911 OPERATOR: Again, what is your first and last

2 name again?

3 MR. BRENZINGER: First name Mark, M-a-r-k, last name

4 Brenzinger, B as in boy, r-e-n, z as in zebra, i-n-g-e-r.

5 911 OPERATOR: Okay. What agency did you say you’re

6 with, Mark?

7 MR. BRENZINGER: Hillard Heintze, H-i-l-l-a-r-d, H-e-

8 i-n-t-z-e. We’re based in Chicago.

9 911 OPERATOR: Okay. That’s a private investigation

10 firm, you said?

11 MR. BRENZINGER: Private investigation firm, yes,

12 ma’am.

13 911 OPERATOR: Okay. Is the 847 number a good call

14 back number for Hillard Heintze?

15 MR. BRENZINGER: It’s a good call back number for me.

16 I’ll give you a back up number of 312-229 --

17 MS. TERRY THYGESEN: 9806.

18 MR. BRENZINGER: -- 9806.

19 911 OPERATOR: Okay. Mark, could you just update for

20 me, please, the -- I’m sorry, that’s not necessary. I’ll just

21 take that out. Okay. I’m going to have a sergeant from

22 Spanish Fork give you a call back.

23 MR. BRENZINGER: Okay. Can we make this -- with all

24 due respect -- a priority? We believe our subject is mentally

25 unstable, has just got bad news, and she just posted a threat

-3-
 1 about two hours ago about a homicidal threat and a suicidal

2 threat regarding herself and this baby.

3 911 OPERATOR: Okay. What is -- what is your

4 subject’s name?

5 MR. BRENZINGER: My subject’s name is --

6 MS. TERRY THYGESEN: Kailin.

7 MR. BRENZINGER: -- Kailin. K-a-i-l-i-n, Wang, W-a-

8 n-g.

9 911 OPERATOR: Okay. Do we need to have an officer

10 respond to her address?

11 MR. BRENZINGER: Well, I think we do. I’d like to

12 give you the address to --

13 911 OPERATOR: Okay.

14 MR. BRENZINGER: The address is 2481 Fairway Drive in

15 Spanish Fork, and your officer should be prepared for anything,

16 really. This family has not been cooperative. We’ve not been

17 able to serve her for more than several weeks.

18 911 OPERATOR: Okay.

19 MR. BRENZINGER: She’s been very evasive, and her

20 parent that she lives with --

21 911 OPERATOR: And has she been --

22 MR. BRENZINGER: -- has also --

23 911 OPERATOR: Sir, excuse me, Mark, has she made

24 threats to herself?

25 MR. BRENZINGER: She has made threats to herself on

-4-
 1 social media, yes.

2 911 OPERATOR: And to the baby?

3 MR. BRENZINGER: And to the baby, as of two hours ago

4 there was a posting. She was aware there was a hearing in San

5 Francisco. She was not present, and we’re not certain how much

6 information she has --

7 911 OPERATOR: Okay.

8 MR. BRENZINGER: -- but the Court found that the baby

9 needs to be removed from --

10 911 OPERATOR: Okay. Do you have -- do you have a

11 phone number for Kailin?

12 MR. BRENZINGER: One second, let me --

13 MR. DARRICK CHASE: And just more information, the

14 order that we have is a domestic violence prevention order that

15 gets entered into the (inaudible) system, so this is the order

16 that gives full custody to my -- to Mr. Thygesen and has an

17 effecting order to law enforcement to get the baby from Kailin

18 or anybody else who --

19 911 OPERATOR: Okay. Sir, do you have a phone number

20 for her?

21 MR. BRENZINGER: We’re looking that up right now. If

22 you have an email where we could forward you these orders, that

23 would probably --

24 911 OPERATOR: The threats that she made to herself,

25 did she make any mention of how she would hurt herself or the

-5-
 1 child?

2 MR. BRENZINGER: I do not believe there was a method

3 noted in this statement, no, ma’am.

4 911 OPERATOR: Okay. Do you know if she has any

5 weapons or any access to weapons?

6 MR. BRENZINGER: I don’t know if she has weapons or

7 access.

8 911 OPERATOR: Do you know if she has any history of

9 using alcohol or drugs?

10 MR. BRENZINGER: She does have a history of using

11 alcohol. I cannot confirm on drugs.

12 MR. DARRICK CHASE: So can I give you something on

13 the temporary restraining order with respect to guns?

14 911 OPERATOR: Okay. No, I’ll have an officer call

15 you for the information about the orders, but right now I just

16 need to get the information so we can go ahead and do a welfare

17 check, and then you can speak to an officer when he calls you

18 back about the orders in particular.

19 MS. TERRY THYGESEN: I’m going to give you three

20 phone numbers. The first one is at the residence.

21 911 OPERATOR: Okay. Hold on, ma’am. Hold on,

22 please.

23 MS. TERRY THYGESEN: Sorry.

24 911 OPERATOR: Okay. Go ahead with the phone

25 numbers, ma’am.

-6-
 1 MS. TERRY THYGESEN: Okay. The first one is where we

2 believe she’s residing with her parents, and that’s -- it’s a

3 land line, we believe, and it’s 801-794-2801.

4 911 OPERATOR: Okay. Is this the parent’s house

5 address, the Fairway Drive?

6 MS. TERRY THYGESEN: Yes.

7 911 OPERATOR: Okay.

8 MS. TERRY THYGESEN: The next number is a cell phone

9 that we believe belongs to Kailin, and that number is 323-244-

10 3244.

11 911 OPERATOR: And that’s Kailin’s cell phone?

12 MS. TERRY THYGESEN: Yes. I have one more cell phone

13 number for her.

14 911 OPERATOR: Okay.

15 MS. TERRY THYGESEN: And that is 917-432-4181.

16 911 OPERATOR: Okay.

17 MS. TERRY THYGESEN: I don’t know which of the two

18 cell phones are still active, or if they both are.

19 911 OPERATOR: Do you know how old the baby is?

20 MS. TERRY THYGESEN: Three months.

21 MR. BRENZINGER: Three months.

22 911 OPERATOR: Okay. Do you know if Kailin has a

23 vehicle?

24 MS. TERRY THYGESEN: Yes. There are two vehicles and

25 a -- they belong to either her or her parents, unclear, but let

-7-
 1 me give you both of them. Hold on one second.

2 911 OPERATOR: Do you guys know the baby’s name and

what sex the baby is?

-
3

4 MR. DARRICK CHASE: Yes. Baby’s name is

I His middle name is Thygesen, T-h-y-g-e-s-e-n, last

6 name Wang. He’s a boy. His birth date is 11/26/2018.

7 911 OPERATOR: Okay.

8 MR. DARRICK CHASE: He’s a white baby. Well, as far

9 as we know.

10 911 OPERATOR: Okay. Then the vehicle information

11 for Kailin?

12 MS. TERRY THYGESEN: Give me one second. I’m opening

13 it up. Okay. It’s a -- there are two cars. One is a gold BMW

14 SUV. The license plate is Boy, 5, 3, 8, Edward, Apple.

15 911 OPERATOR: Okay.

16 MS. TERRY THYGESEN: I’ll read that back to you, Boy,

17 5, 3, 8, Edward Apple. The second car is a red Lexus SUV. The

18 license plate is David, 5, 6, 9, X-ray, Tango. We believe the

19 baby seat is usually in the red Lexus, FYI.

20 911 OPERATOR: Okay. So I have all the information

21 that I need. We’re going to send out for us to do a welfare

22 check, and then I’ve put in here a note for someone to contact

23 you by phone after they’ve made contact.

24 MS. TERRY THYGESEN: Can we do that before just to

25 give more information?

-8-
 1 911 OPERATOR: Actually, our main priority right now

2 is to make sure everything is okay, and then we’ll have someone

3 give you a call when they’re done.

4 MR. BRENZINGER: Okay. Then we can send over the

5 orders at that time as well, if that’s okay?

6 911 OPERATOR: Okay.

7 MR. DARRICK CHASE: We want to get the baby at the

8 time we do the welfare check.

9 911 OPERATOR: When the officer does call you, he’ll

10 likely be calling from a blocked or a private number, so just

11 look out for that.

12 MR. BRENZINGER: Yes, ma’am. Thank you.

13 911 OPERATOR: Okay. Thank you.

14 MS. CHASE: Thank you.

15 911 OPERATOR: Okay. Bye-bye.

16 MR. DARRICK CHASE: Bye.

17 (Conclusion of 911 call)

-9-
 REPORTER'S CERTIFICATE

STATE OF UTAH
ss.
COUNTYOF TOOELE

I, Natalie Lake, a Notary Public in and for the State of Utah,

do hereby certify:

That this proceeding was transcribed under my direction from

the transmitter records made of these meetings.

That I have been authorized by Beverly Lowe to prepare said

transcript, as an independent contractor working under her court
reporter's license, appropriately authorized under Utah statutes.

That this transcript is full, true, correct, and contains all

of the evidence and all matters to which the same related which
were audible through said recording.

I further certify that I am not interested in the

outcome thereof.

That certain parties were not identified in the record,

and therefore, the name associated with the statement may not
be the correct name as to the speaker.

WITNESS MY HANDAND SEAL this 11 th day of May 2020.

My commission expires:
January 9, 2024

\ 5

Natalie Lake
NOTARYPUBLIC
Residing in Tooele County

Beverc:&(R

NatalieLake
NolaryPublic,s1a:eof Utah
Comm,ssion # 709897
My~ EJ;l<!&.\
.Ja,ua,y9 202i
08/26/19 Utah Valley Dispatch 6475
08:58 CALL DETAIL REPORT Page; 1
Call Number: C6050525

Nature: WELF CHEC 6

Reported: 14:13:17 03/06/19
Rcvd By: Tauaefa K DD How Rcvd: T
0cc Btwn: 14:12:27 03/06/19 and 14:12:27 03/06/19
Type: l
Priority: 3

Address: 2481 S FAIRWAY DR

City:

Alarm:

COMPLAINANT/CONTACT
Complainant: HILLARD HEINTZE, Name#: 1206993
Race: Sex: DOB: **/**/**
Address: 30 S Wacker Dr, Chicago
Home Phone: {312)229-9806 Work Phone: (312)869-8500

Contact: mark brenzinger

Address:
Phone: (847) 306-2220

RADIO LOG

Dispatcher Time/Date Unit Code Zone Agne Description

Willden L 14:19:29 03/06/19 6J34 ENRT SFPD SFPD incid#=l9SF01599 Enroute to

a Call call=7201
Willden L 14:19:41 03/06/19 6J22 ENRT SFPD SFPD incid#=l9SF01599 Enroute to
a Call call=7201
Smith D (S 14:22:36 03/06/19 6J22 DLIN SFPD SFPD MDC: name=WANG, KAILIN
dob=Ol/20/1983 sex=F
dl~l67959889 state=UT
Willden L 14:27:22 03/06/19 6J22 ARRV SFPD SFPD call=7201
Willden L 14:29:36 03/06/19 6J34 ARRV SFPD SFPD call=7201
Smith D (S 14:32:18 03/06/19 6J22 VHIN SFPD SFPD MDC: pl=B538EA st=UT
lptyp=PC
Smith D (S 14:32:19 03/06/19 6J22 VHRE SFPD SFPD MDC: pl=B538EA st=UT
lptyp=PC
Willden L 15:09:19 03/06/19 6J22 TS SFPD SFPD 3313 E HAWKDR, SF; pl=,
call=7201
Willden L 15:09:20 03/06/19 6J22 CMPL SFPD SFPD incid#=l9SF01599 Reassigned
to call 8141, completed call
7201
Willden L 15:09:41 03/06/19 6J34 CMPL SFPD SFPD incid#=l9SF01599 Reassigned
to call 8141, completed call
7201
Willden L 15:29:35 03/06/19 6J34 ARRV SFPD SFPD incid#=l9SF01599 Arrived on
Sc,::ne call=7 201
Willden L 15:40:59 03/06/19 6J34 4 SFPD SFPD incid#=l9SF01599 suspend
ca11=7201
08/26/19 Utah Valley Dispatch 6475
08:58 CALL DETAIL REPORT Page: 2
Willden L 15:45:47 03/06/19 6J34 CMPL SFPD SFPD incid#=l9SF01599 Reassigned
to call 8781, completed call
7201
Willden L 16:11:53 03/06/19 6J34 ARRV SFPD SFPD incid#=l9SF01599 Arrived on
Sci~ne call=7201
Solie E (S 17:36:57 03/06/19 6J34 NMIN SFPD SFPD MDC: name=WANG, KAIL IN
Solie E (S 17:36:58 03/06/19 6J34 DLIN SFPD SFPD MDC: name=WANG, KAILIN
Solie E (S 17:37:18 03/06/19 6J34 OLIN SFPD SfPD MDC: name=WANG, KAILIN
dob=Ol/20/1983 sex=F
dla.a167959889 state=UT
Solie E (S 17:37:19 03/06/19 6J34 NMIN SFPD SFPD MDC: name=WANG, KAILIN
dob=Ol/20/1983 sex=F
dl==l67959889 state=UT
Solie E (S 17:37:50 03/06/19 6J34 NMIN SFPD SFPD MDC: name=THYGESEN,
CHRISTOFFER
Solie E (S 17:37:51 03/06/19 6J34 OLIN SFPD SFPD MDC: name=THYGESEN,
CHRISTOFFER
Willden L 18:12:16 03/06/19 6J34 CMPL SFPD SFPD
COMMENTS
--------
subject re kailin wang / mental problems/ has made threats to herself and to
baby as of two hours ago/ rp is calling from out of state/ has orders for
custody to be given to father/ no method mentioned/ hx of ale I unk drugs
14:19:03 03/06/2019 - Tauaefa K DD
unk weapons
14:19:52 03/06/2019 - Tauaefa K DD
poss #801 794 2801 parents house/ 323 244 3244 kailins cell/ 917 432 4181 cell
14:20:01 03/06/2019 - Tauaefa K DD
baby is 3 months old
14:20:50 03/06/2019 - Tauaefa K DD
babys name is -
14:21:07 03/06/2019 - Tauaefa K DD
rp reg 1021 after contact
14:21:42 03/06/2019 - Tauaefa K DD
poss veh gold suv b538ea / red lexus suv d569xt
14 : 3 9 : 5 6 0 3 / 0 6 / 2 019 - Fr a z i er J DD - Fr om : So 1 i e E ( SI: )
c4
14:50:37 03/06/2019 - Willden L DD - From: Solie E (SF)
code 4
15:01:23 03/06/2019 - Willden L DD - From: Solie E (SF)
code 4
UNIT HISTORY

Unit Time/Date Code

------
6J22
-------------------
14:19:41 03/06/19 ENRT
6J22 14:22:36 03/06/19 OLIN
6J22 14:27:22 03/06/19 ARRV
6J22 14:32:18 03/06/19 VHIN
6J22 14:32:19 03/06/19 VHRE
6J22 15:09:19 03/06/19 TS
6J22 15:09:20 03/06/19 CMPL
6J34 14:19:29 03/06/19 ENRT
6J34 14:29:36 03/06/19 ARRV