Professional Documents
Culture Documents
Thygesen's 26 Known Attorneys, Experts, Private Investigators vs. Pro Se Wang - Redacted
Thygesen's 26 Known Attorneys, Experts, Private Investigators vs. Pro Se Wang - Redacted
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
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.
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.
Thygesen's Utah
Attorneys
Beau J. Olsen
15 $325/ Hr. Family Law Olsen & Olsen 3/3/19 Utah Bar: 10/18/2014
Utah Bar: 15213
Thygesen's
Private
Investigators
Chris Bertram
Utah Private
17 Utah Private $250/hr. December 2018-Present
Investigator
Investigator
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."
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 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
-- --
-- -
9/18/23, 2:49 AM Top Rated San Francisco, CA Criminal Defense Attorney | Douglas Rappaport | Super Lawyers
Douglas L. Rappaport
Top rated Criminal Defense attorney in San Francisco, California
Visit website
Special Licenses/Certifications:
• State Bar of California Certified Criminal Law Expert
Honors/Awards:
• Top 100 Trial Lawyers , National Trial Lawyers, 2012
Selections
15 YEARS
SUPER LAWYERS
Super Lawyers: 2009 - 2023
https://profiles.superlawyers.com/california/san-francisco/lawyer/douglas-l-rappaport/2f00921a-3eb0-466e-80c9-8fe78c124b54.html 2/5
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: mreedy@mcmanislaw.com 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: admin@sfcrimlaw.com
9
Attorneys for Petitioner,
10 CHRISTOFFER THYGESEN
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
FOR THE COUNTY OF SAN FRANCISCO
13
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
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
8 3. I am familiar with the work performed to date relating to Petitioner's DVRO request, and
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
17 6. The following are summaries of the work completed to date which directly relate to the
23 • Preparation for the trial originally scheduled for October 22, 2019, including
24 drafting Motions in Limine, preparation and coordination of 39 potential
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
Via FedEx
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
admin@sfcrimlaw.com
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.
DOUGLAS L. RAPPAPORT
Doug,
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:
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:
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
17
18
19
20
21
22
23
24
25
26
27
28
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
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
8 Nevertheless, the victim Christoffer Thygesen does not wish undermine Defendant Wang’s
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
15 The victim, Mr. Christoffer Thygesen, has both a constitutional and statutory right to a
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
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
13 No. FDV-19-814465
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.
4 DEPARTMENT 404
5 ---oOo---
7
8 CHRISTOFFER STANFORD THYGESEN, )
)
9 PETITIONER, )
)COURT NO. FDV-19-814465
10 vs. )
)
11 KAILIN WANG, )
RESPONDENT. )
12 ____________________________________ )
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
28
23 Christopher.
10 at risk until the court has heard the evidence and assessed,
13 Rally.
14 THE COURT: That argument was made the last time we were
22 (Proceedings concluded.)
23
24
25
26
27
28
FL-150
PETITIONER:CHRISTOFFER STANFORD THYGESEN CASE NUtllllER·
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
{
~
Date: December 10, 2021
MICHEL.ENE INSALACO ► /
(TYPE OR ~INT NAME)
L.. (SIGNATURE O• OEClARANTJ
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
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)
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.
=========================
KAILIN WANG
Appellant,
v.
CHRISTOFFER STANFORD THYGESEN
Respondent
=========================
----------------------------------------------------------------
---------------------------------------------------------------
Michelene Insalaco (SBN 161711)
Janet Simmonds (SBN 245506)
Sucherman • Insalaco LLP
101 Mission Street, Suite 1640
San Francisco CA 94105
(415) 357-5050
MI@Sucherman-Insalaco.com
Counsel for Respondent
Christoffer Stanford Thygesen
DECLARATION OF MICHELENE INSALACO
Task MI JS YL TE Total
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
//
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.
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.
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
erica@rcjlawgroup.com
(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: mreedy@mcmanislaw.com 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: admin@sfcrimlaw.com
9
Attorneys for Petitioner,
10 CHRISTOFFER THYGESEN
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
FOR THE COUNTY OF SAN FRANCISCO
13
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
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
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:
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
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 (~]
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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2. Did you know Christopher Thygesen is the _,_.,.,...._
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DocuSign Envelope ID: F39B7326-C697-4996-A378-AB60F267168D
Browser engine: Mozilla/5.0 (Windows NT 10.0; Win64; x64) AppleWebKit/537.36 (KHTML, like
Gecko) Chrome/118.0.5993.54 Safari/537.36
PDF length: 2
User: 221partners
26
27
28 REPORTED BY: VICKI GROSS, CSR
CERTIFICATE NO. 5525
22
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.
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 erica@rcjlawgroup.com
Fax: (415) 358-4975
May 5, 2019
Karl Kronenberger
Kronenberger Rosenfeld, LLP
150 Post Street
San Francisco, CA 94108
Dear Karl,
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.
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.
• 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
-
-
- -
-
- -
I
-
-- --
- -
I -
I -
I -
- -
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
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.
News Images Videos Books Shopping Maps Flights Finance All filters Tools SafeSearch
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
Patch
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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: dchase@kayemoser.com
5
Attorneys for Petitioner
6 CHRISTOFFER STANFORD THYGESEN
7
8
9 IN THE SUPERJOR COURT OF THE STATE OF CALIFORNIA
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
22 2. I am representing Mr. Thygesen in this matter, and have been since on or about December 13,
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.
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
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 dchasc@kaycmoscr.com
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:
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):
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. ~ •
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 .…
News Images Videos Books Shopping Maps Flights Finance All filters Tools SafeSearch
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
Patch
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http://pepperseeds.eu › http: › caltocompnemunfark.cf
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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: dchase@kayemoser.com
5
Attorneysfor Petitioner
6 CHRISTOFFER STANFORD THYGESEN
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,
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
Q
0
marincountyconfidential @marindatanow · Feb 1
1/
This is sad and alarming.
From anyone
People you follow •
0
Location
B
On January 21, 2023 an elected official in Novato, Darrick Chase,
apparently died of a "penetrating shotgun wound to chest", in the garage of
his residence.
Anywhere
Near you •
0
The death was not reported by the local "paper of record"; logged only
recently by Coroner. Advanced search
Live on X
Brick Suit
• is speaking
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
mitigation for impacts to the creek from
Party Updates, & Why
Trump should go
-=-===------)
Independent
0 3 n 15 0 24 6K
#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
What’s happening
Board Candidate Interview Questionnaire Term expires: December 2024
2023 Cheryl Furst
Term expires: December 2024
Please drop off your application at the CSD • Mercy Angelopulos NHL · LIVE
office. Term expires: December 2024
Canadiens at Coyotes
Applications will be reviewed by the Board Public Meetings
Nobody wanted to step into the box against Randy Johnson... but which
hitters did he have the toughest time against during his 22-year career? Politics · Trending
Messages
Hezbollah
@BenVerlander
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11/2/23, 8:59 PM darrick chase (from:marindatanow) - Search / X
170K posts
6il
Who to follow
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0
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. ••
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Theconstitutionalist
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17 59 541 31K
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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,
marinij.com
1 5 4 609
Messages
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 mreedy@mcmanislaw.com
Phone 408.279.8700
Focus
Family Law, Litigation, Appellate
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.
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
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 ...................................
.._ ____ --+-,
_,__._,._,,
....
Date: 8 / 3 1 / 2 0 2 2
Michael Reedy ►
(TYPE OR PRl~T NAMEJ
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: mreedy@mcmanislaw.com 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: admin@sfcrimlaw.com
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
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: mreedy@mcmanislaw.com 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: admin@sfcrimlaw.com
9
Attorneys for Petitioner,
IO CHRISTOFFER THYGESEN
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
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
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
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
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
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
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
,, ............
,.... ,.....,
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
PARTIES
Petitioner - CHRISTOFFER THYGESEN
Represented by: BEAU OLSEN
Represented by: MITCHELL OLSEN
Represented by: MARTIN OLSEN
Represented by: BRYANT MCCONKIE
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
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
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
MITCHELL J. OLSEN JR. being first duly sworn, deposes and says:
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
7. That I have been practicing law for approximately 12 years, and my hourly rate is
8. That on April 29, 2022, the court awarded Respondent his attorney fees and costs
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
client, preparing for court hearings, court hearings, phone calls, emails, and preparing the
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
15. That this declaration is not inclusive of all my time, and is merely focused on
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
22. That based on hearings and hearing prep alone since Petitioner was declared a
23. That this amount is reasonable based upon the above mentioned factors and the
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
28. That I declare under criminal penalty under Utah Code §78B-18a-106 and the laws
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
kaywg2372@gmail.com
Petitioner, CHRISTOFFER THYGESEN, complains and for cause of action and alleges
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
4. That the Court and state of Utah enforce the Amended Temporary Restraining
5. That the Court schedule a hearing on the first day possible after service.
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
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.
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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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.
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
Action”)
5. By Mother filing for child support services and paternity, she verified to the court
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
beau@olsenfamilylaw.net
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
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
A final order was entered in this case on May 7, 2018. Since that date, this case has been
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
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.
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
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.
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 O@gmail.com
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
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:
END OF ORDER
••ENTERED ON mE DATE AND AS JNDJCATED
BYTHE SEAL or TIIE COURTAT TOP OF PAGE 1°
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
1Kaywg2372@gmail.com
PARTIES
Petitioner - CHRISTOFFER THYGESEN
Represented by: BEAU OLSEN
Represented by: MITCHELL OLSEN
Represented by: MARTIN OLSEN
Represented by: BRYANT MCCONKIE
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
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
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
Beau@olsenfamilylaw.net
Petitioner, CHRISTOFFER THYGESEN, complains and for cause of action and alleges
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
4. That the Court and state of Utah enforce the Amended Temporary Restraining
5. That the Court schedule a hearing on the first day possible after service.
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
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.
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
!" #""
$%&!'"! ()
"'"* +",(-))
$. /'0"+1!2$'3'!4 +"
2!"#
88!#. (;
#+"30!!4
<0<"! '0"+
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.
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
Action”)
5. By Mother filing for child support services and paternity, she verified to the court
2
IN THE FOURTH JUDICIAL DISTRICT COURT
--oo0oo--
____________________________________
)
KAILIN WANG, )
)
Plaintiff, )
) Case No. 194400718
VS. )
)
CHRISTOFFER STANFORD THYGESEN, )
)
Defendant. ) TRANSCRIPT OF:
____________________________________) TEMPORARY ORDERS
2 age.
5 about a 12-hour drive. We're not sure how that really plays
11 case.
8 Your Honor, we addressed the email that she sent towards the
15 is relevant.
19 to an inconvenient forum.
20 Your Honor, the only thing that you have left in the
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
“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
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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.
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.
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: donald.dubain@sfgov.org
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: dchase@kayemoser.com
5
Attorneys for Petitioner
6 CHRISTOFFER STANFORD THYGESEN
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,
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
25 Civil ProcedureSection2034.260c.
28 an expert in this matter. For information about Erik Rasmussen's qualifications, please see his
5 Technical background on the internet and technology at issue in this case; Explanation 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,
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
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
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3 foregoing is true and correct, and that this declaration was executed on October 3, 2019 in San
4 Francisco, California.
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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:
20 about his interactions with Ms. Wang, his experiences parenting and caring for Baby K, the
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
(eggfu45@gmail.com).
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 courtorder6678@gmail.com and servebyemails@gmail.com.
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 courtorder6678@gmail.com and servebyemails@gmail.com.
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 courtorder6678@gmail.com and servebyemails@gmail.com.
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 courtorder6678@gmail.com and servebyemails@gmail.com.
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 courtorder6678@gmail.com and servebyemails@gmail.com.
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.
22 Heintze.
24 37. Jennifer L. Mackovjak. Ms. Mackovjak is seasoned civil and criminal investigator
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
15
Attorney for Petitioner
16
CHRISTOFFER STANFORD THYGESEN
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-6-
IN THE FOURTH JUDICIAL DISTRICT COURT
--oo0oo--
____________________________________
)
KAILIN WANG, )
)
Plaintiff, )
) Case No. 194400718
VS. )
)
CHRISTOFFER STANFORD THYGESEN, )
)
Defendant. ) TRANSCRIPT OF:
____________________________________) TEMPORARY ORDERS
2 age.
5 about a 12-hour drive. We're not sure how that really plays
11 case.
8 Your Honor, we addressed the email that she sent towards the
15 is relevant.
19 to an inconvenient forum.
20 Your Honor, the only thing that you have left in the
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
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:
• John Doe v. Serbian Orthodox Diocese of Western America, Superior Court for the State
FILED DATE: 2/15/2023 10:04 PM 2019CH00990
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.
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.
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.
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: donald.dubain@sfgov.org
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: dchase@kayemoser.com
5
Attorneys for Petitioner
6 CHRISTOFFER STANFORD THYGESEN
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,
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.
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
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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
WHO WE ARE
OUR EXPERIENCE
https://www.221bpartners.com/who-we-are 1/5
11/22/23, 6:30 PM Who We Are — 221B Partners
READ MORE +
READ MORE +
https://www.221bpartners.com/who-we-are 2/5
11/22/23, 6:30 PM Who We Are — 221B Partners
READ MORE +
READ MORE +
https://www.221bpartners.com/who-we-are 3/5
11/22/23, 6:30 PM Who We Are — 221B Partners
READ MORE +
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
https://www.221bpartners.com/who-we-are 5/5
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
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:
20 about his interactions with Ms. Wang, his experiences parenting and caring for Baby K, the
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.
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.
24 37. Jennifer L. Mackovjak. Ms. Mackovjak is seasoned civil and criminal investigator
25 and leads Hillard Heintze's Investigations Practice.
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
15
Attorney for Petitioner
16
CHRISTOFFER STANFORD THYGESEN
17
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-6-
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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
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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
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LICENSE
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: admin@sfcrimlaw.com Deputy Clerk
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
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
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.
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. & 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
MEMBERSHIPS
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.
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, 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.
Keynote Address, “Lone Offender Assessment: Risk Factors and Warning Signs,” Iowa
Emergency Management Conference, Ankeny, Iowa, October 31, 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, “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, “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, “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, “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
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
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
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 *
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Dr. Reid Meloy Bio Press & Publications Books Services Presentations Training
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
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14
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5 preliminary findings, and further needed information for me to complete such an undertaking.
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
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
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DocuSignEnvelopeID: EC14DCDF-7F33-4F38-95E4-961E3ED6BB03
decade. The assessment considers both her online as well as her on the ground behaviors.
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
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,
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,
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).
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
DocuSign Envelope ID: EC14DCDF-7F33-4F3B-9SE4-961E3E06BB03
evidence that she often emotionally thrives on the chaos and torment that she can cause in others.
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 •
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
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
DocuSign Envelope ID: EC14DCDF-7F33-4F3B-95E4-961E3ED6B803
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
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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Cell: 858-922-1528
Email: reidmeloy@gmail.com
Education
Ph.D., Clinical Psychology, United States International University, 1981 {Alliant International University-CSPP)
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.
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.
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.
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.
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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ABOUT
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.
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.
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).
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
5 have been in private practice as a licensed psychologist since 1987. In addition, I have earned
7 (2008) and am a fellow of the American Board of Professional Psychology and the Society for
10 area of family law, where I have performed over one hundred-fifty child custody evaluations,
12 individual therapist. In addition, I have provided consultation to attorneys and made numerous
14 professional organizations, local family law groups and Family Court Services. Details of these
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
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
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
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
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
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
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
CURRICULUM VITAE
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.
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
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.
Sincerely,
•
-
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
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
Clerk: TiffanyFitzpatrick
Clerk: TiffanyFitzpatrick
3 AA 999
II
DocuSign Envelope ID: 6915A35B-8876-4F18-A06A-8DB969C52AB3
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
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: dchase@kayemoser.com MAR- 412019
20
________________ )
)
21 I. Update
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.
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.
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,
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
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.
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
24 24. The evidence indicates that Ms. Wang wants to destroy me, and everyone related to me. Who
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
13 28. See, Exhibit J-1, document titled AFFIDAVIT OF NON-SERVICE. The affidavit lists 9
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
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
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
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
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
Anthony E. Loubet
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
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.
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
000224
Wang v. Thygesen 194400718
000225
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.
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
000241
Wang v. Thygesen 194400718
000242
RandallL Barker
3/12/2019
09:58
000242
Wang v. Thygesen 194400718
000243
MelisaTodd
140West 9000 South,Suite9
Sandy,Utah 84070
801M566M
1884
melisa@spencerandcollier.com
February21, 2019
To Whomit Concerns:
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
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
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]
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
padams1972@yahoo.com. 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 ••
•
Linkedln ••
•
https://www.linkedin.com > patrick-...
••
https://www.linkedin.com > patrick- ... •
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
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
''
)' 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
18
19
20
21
22
23
24
25
26
27
28
"
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
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
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
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.
1920: Visitation ended. CT retrieved baby from Terra Firma, departed Hayward.
Mathew Dennis
PO Box 980333
PHONE (209) 769-4483
West
EMAIL Admin@SecureOutcomes.com
Sacramento CA
95798 WEBSITE WWW.SecureOutcomes.com
SECURE OUTCOMES PROTECTION INC.
May 4, 2021
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.
~/1
//7 /~
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
-
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?
Thank you,
--
Kailin Wang
Phone: 801-645-1060
922
From: Bertha Cuellar bcuellar@terrafirmadiversion.com
Subject: Re: Abduction Risk
Date: July 26, 2021 at 5:47 PM
To: Kailin Wang kaywg2372@gmail.com
No , I did not.
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.
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
2 attachments
9-5 Security Report 9 30 20 MD.pdf
212K
9-6 Security Report 10 14 20 GJ.pdf
33K
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!
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.
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.
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
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.
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
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:
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_."
.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.
----------
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
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.
([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;_•."
Thank you for the update, see you Thursday Aug. 11, 2022.
Kailin Wang
KailinWang
Phone: 801-645-1060
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
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
_________________________________________________________________
_________________________________________________
STATE OF UTAH )
:ss
County of Utah )
THAT
In the City of SPANISH FORK, County of Utah, State of Utah, there is now certain
property or evidence described as:
has been used or is possessed for the purpose of being used to commit or
conceal the commission of an offense; or
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
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
.. Sheet1 Sheet2
9/7/2019 Dr. Mark Brenzinger, PsyD, Psychologist, Schaumburg, IL, 60194 | Psychology Today
Home >Mark
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Schaumburg
Psychologist, PsyD
Mark Brenzinger
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Email Me (847) 603-4745
(847) 603-4745
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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
-1-
1 P R O C E E D I N G S
9 with your constable in the area, and he’s been working with a
11 you in a fresh court order. Is there any way you can get
16 get your information and then ask a sergeant to give you a call
17 back.
21 child that is at risk right now and hand that child over to the
24 number?
-2-
1 911 OPERATOR: Again, what is your first and last
2 name again?
6 with, Mark?
12 ma’am.
20 me, please, the -- I’m sorry, that’s not necessary. I’ll just
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
4 subject’s name?
8 n-g.
16 really. This family has not been cooperative. We’ve not been
24 threats to herself?
-4-
1 social media, yes.
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
20 for her?
22 you have an email where we could forward you these orders, that
23 would probably --
25 did she make any mention of how she would hurt herself or the
-5-
1 child?
7 access.
15 you for the information about the orders, but right now I just
17 check, and then you can speak to an officer when he calls you
22 please.
25 numbers, ma’am.
-6-
1 MS. TERRY THYGESEN: Okay. The first one is where we
10 3244.
23 vehicle?
-7-
1 me give you both of them. Hold on one second.
-
3
9 as we know.
11 for Kailin?
13 it up. Okay. It’s a -- there are two cars. One is a gold BMW
22 check, and then I’ve put in here a note for someone to contact
-8-
1 911 OPERATOR: Actually, our main priority right now
-9-
REPORTER'S CERTIFICATE
STATE OF UTAH
ss.
COUNTYOF TOOELE
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
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
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