FBI Denver April 10, 2011 8000 East 36th Avenue Denver, CO 80238 (303) 629-7171 Re: Kevin P. Maguire (3-5-54) Elisabeth M. Maguire (8-28-96) Catherine R. Maguire (5-1-98) Kyle P. Maguire (4-11-00)

To whom it may concern, I request the FBI initiate an investigation regarding the violation of the civil rights of my children and myself by the State of Colorado, of many years duration; obstruction of justice and collusion/conspiracy to obstruct justice; witness tampering; witness intimidation; collusion/conspiracy to commit witness tampering; falsification of records, alteration of records by Colorado State agency; the refusal of State agencies to acknowledge and intervene to stop the emotional/psychological abuse of my children; failure of Colorado State agencies and licensed mental health practitioners to report child abuse. The above actions involve the State of Colorado, Court-appointed individuals, and private individuals. Although my focus here regards events in Colorado, this case spans three states (MI, AK, CO) beginning in 2001. Colorado begins in June 2003. I have a very large amount of documentation, as well as video interviews, which provides sufficient evidence to prove these. I believe the information also demonstrates actions against my children and me as a hate crime. Attached is an expert report, written by R. Christopher Barden Ph.D, J.D., who was the prosecution’s expert witness for the State of Colorado in the case of a girl’s death due to inappropriate therapy. Within his report on my case he writes “I suggest that the FBI be contacted to investigate what

may well turn out to be a case of corruption (e.g. obstruction of justice) in the local abuse

investigation system.”

Also attached is an evaluation report done as part of Colorado’s investigation of me. I request to speak with and present information to the FBI. I may be contacted at any time. Sincerely, Kevin P. Maguire D.O. Box 140487 Anchorage, AK 99514-0487 907-748-5200 (tel) 907-375-2967 (fax) doc4diabetes@yahoo.com

My family and I (wife-Lisa, Elizabeth-4, Catherine-2 ½, Kyle-6 mos) moved from Anchorage, Alaska to Huntington Woods, Michigan, so I could start a radiology residency program, and moved into a house in October 2000. Lisa had many relatives in the area, and our family had frequent contact with them. In March 2001, following a party we had for some other doctors were I worked, my daughter Elizabeth said that Allie (eight-year-old boy at the party) had touched her. Over the course of the following week, she repeatedly named an adult male cousin of Lisa's (“Mr. Denise” – Shawn Cotter) , and gave details of being touched by this man at the home of Lisa's aunt. We called the police, and filed a police report on March 16, 2001( ). Elizabeth underwent a forensic interview on March 22 (__no video or audio recorded). She named "Mr. Denise" and Allie. On March 23, the police came to our house and took items from the girls’ bedroom and the crime lab van also came to do an evaluation. Elizabeth directly told the police Lieut. that the man had "a tattoo where he pees" (see ). On March 26, Elizabeth began seeing the social worker/therapist recommended by the prosecutor. On April 6, 2001. Lisa called the police to the house, and lied to them that the therapist had suggested questioning our daughter Elizabeth at home. During this "questioning" Lisa told the police that Elizabeth said “Kevin” and “Allie” touched her. The police contacted social services, who came to the house on April 11 (my son's first birthday). When I got home, Lisa told me that social services said I had to leave the house or they would take our kids away. The following day, Lisa secretly withdrew $9,914.12 cash from our joint account(below IRS "radar"). I came home every night, we had dinner with the kids, put them to bed, and talked. I went to the hotel to sleep. Weekends we did things all together. I was totally in the dark that Lisa had been making false allegations against me, and attributing these to Elizabeth and Catherine. When I asked social services why this was taking so long, told me they were just investigating all allegations. On May 1, 2001 Lisa secretly withdrew $9,999.00 and $9,950.00 cash, and $5,075.00 in Traveler’s checks. She took the kids to a hotel, and told me they were afraid of the house. On May 3, 2001 Lisa absconded with our kids to Alaska, which I only discovered when I called that night and she said she was already on the plane. On May 9, 2001 Michigan social services closed the case, and informed Lisa in Alaska. They didn’t inform me. Michigan expanded: I accepted a radiology residency and we moved our family (me, my wife Lisa, Elisabeth 4, Catherine 2 ½, Kyle 6 mo.) from Anchorage, Alaska to Huntington Woods, Michigan, and settled into our house in Oct. 2000. We often visited with Lisa’s relatives (she was born in

Michigan). On March 10, 2001 after a party for some hospital friends, Elisabeth (4 ½) said that the 8 y/o boy (Allie) at our house that night had touched her at the party. Over the next few days she said that it was a man she called ‘Mr. Denise” (SC - a cousin of Lisa’s). We contacted police and filed a report. On March 22, 2001 an interview was done by a social worker at Care House (no video or audio recorded) in which Elisabeth named him again, and that he touched her at our house. She also mentioned “Allie” – the boy from the party at our house. It was decided that because Elisabeth did not mention the relative’s house, only ours, that the case would be transferred from Farmington Hills (where the report was filed) to our local police dept. (Huntington Woods). The following day (March 23) the police came to our house and took items from the girls’ bedroom for crime lab evaluation. Elisabeth told a police Lt. that the man had a “tattoo where he pees” (see police note March 23 - ) (see SC felony arrest record noting a ‘tattoo right hip’ - ). Our daughters underwent a forensic physical exam, no evidence of abuse seen. Lisa took notes with our kids while I was at work. Shortly, our younger daughter Catherine (34 months) chimed in with her sister, adding various names unknown to us as well as saying that the young (2-4 y/o) children of Lisa’s relatives had also touched her. We took Elisabeth to the social worker/therapist recommended by the prosecutor. On Mar 27, 2001, just 5 days after Elisabeth’s interview, a staff member at Care House told the investigating officer that Elisabeth would undergo “intensive counseling in order to see if she will name the person responsible for the assault", and that it "might be as much as six months or more before Elizabeth is ready to be re-interviewed." She told the investigating officer that the case was basically on hold until then. Remarkably, he investigating officer wrote that “It is recommended that no suspects be interviewed until one is actually named by the young victim.” (See police note March 27, 2001) On April 6, 2001 (Fri) When I got home from work our kids were not there. Lisa told me that the therapist had recommended that Lisa question Elizabeth at home, by asking her who she did not want to come to Kyle’s birthday party (therapist notes confirm this to be a lie) (See police note April 6, 2001) Lisa told me Elisabeth said “Kevin”, then “Allie” (boy at our party) She told me the therapist had recommended that Lisa take Elisabeth to her cousin’s house that night, since sometimes kids will name someone close to them as a way to “test the water” and then make a disclosure. Lisa also told me the therapist recommended I take a lie detector. I thought this was strange but I trusted my wife, so I called HWPD and spoke to Lt. Armold, who said they didn’t do them, and to call the State Police. I called them and was told it needed to be scheduled. April 11, 2001 Social services came to the house while I was at work. Lisa told her things are fine, she is worried about the kids. Social worker made false comments in her notes that my daughters made disclosures to the therapist. (Investigation by the State of Michigan proved that the therapist never made any such claims - ) In fact, the only allegations ever made, or claimed to have been “heard” from my daughters, was from Lisa. When I got home Lisa told me that the social worker said I had to leave the house because of what Elisabeth said on Friday (6th), or they would take the kids. We finished dinner, sang happy birthday to Kyle (he is 1) put our kids to bed, talked for a while, and I went to a hotel.

April 12, 2001 The very next day, Lisa secretly began the first of 3 withdrawals from our account, in amounts of @ $9,999.00. (Below IRS radar of $10,000)

I came home each night, we had dinner, played with our kids, put them to bed, talk, and I went to the hotel to sleep. April 15, 2001 Easter Sunday. We go to Mass, then Sunday Bruch at a local hotel. April 16, 2001 Lisa converted the first $9,914.12 withdrawn money into Western Union

checks of $1,000.00, and deposited them in a Comerica bank account (unknown owner).

April 25, 2001 Lisa secretly bought plane tickets to Alaska for herself and our kids. May 1, 2001 Lisa took our kids to a hotel. Told me our kids were afraid of the house. Also, Lisa made 3 more secret withdrawals from our account $9,999.00 and $ 9,950.00 cash, and $5,075.00 in Traveler’s checks. May 3, 2001 Lisa absconded with our kids to Alaska. I didn’t find out until I called that night and she was already on the plane. She told me not to follow her or I’d be sorry. May 9, 2001 Unknown to me, case is closed in Michigan; Lisa is informed but I am not. My inquiries to social services about the investigation were met with non-responses that they could not speak directly about the case. A long time later I would discover that in late April 2001 Mr. Denise – the man my daughter identified – was suddenly dropped as a suspect and I was then listed by Care House as a suspect (following Lisa’s fabricated allegations and false statements to the police). A year later, in June 2002, after a year of separation from me, “recovered memory therapy” in Alaska, Elisabeth was brought back to Michigan and interviewed again at Care House – now she said dad touched her. (Again there was no video or audio recording made. When I requested copies of the original handwritten observers notes, I was told they had been lost or destroyed and that all that they kept on file was the typed after-interview summaries) In 2002 I learned that Lisa had attempted to manufacture evidence, having taken evidence from our house and did not give it the police. I did not get most of this information until well after the fact. I remain convinced that the “investigation” was mishandled, or worse. The allegations against me were fabricated by Lisa, manipulated by Lisa, and that she planned her actions. The man my daughter identified (Shawn Cotter) was apparently never interviewed: despite Elisabeth’s CareHouse interview, our police report and statements to police, the tattoo identified by Elisabeth, his arrest report, or his presence at multiple family functions. (He also has a sealed juvenile criminal record in Michigan). Lisa lied directly to the police by fabricating comments made by the therapist; the social worked made false comments of disclosure attributed to the therapist; and the therapist

conducted an investigation, not therapy. I don’t know if anything happened to my daughters, although I still suspect Lisa’s adult cousin – Mr. Denise (Shawn Cotter) ALASKA – May 2001 – June 2003 Lisa arrived in Alaska with our kids May 4. We spoke on the phone, she told me not to come to Alaska or “you’ll be sorry”. She sent me e-mails that she "absolutely believes the girls". After a couple of weeks, she cut off all contact. Back in Michigan, I didn't hear anything from the social services department. There was sexual abuse in Lisa's family when she was a child (two of her brothers were sexually abused by a high school teacher). I thought that this had caused her to psychologically snap in some fashion, and decided to give her some time while social services conducted their investigation. Also, we are Catholic and I had every intention of saving our marriage and our family from what I saw as an attack by an overzealous system. On May 7, 2001 Lisa spoke with the police Lt. in Michigan. She told him she was in Alaska with our children. She told him that our kids were “in fear of their father, and that she had decided to leave town and go back to her family.” "She further stated that she was afraid that he would come to Alaska. Writer advised her that if there is a real fear there, then she should start immediately on a PPO there preventing contact. Writer advised her to start all necessary legal procedures immediately if she was indeed in fear for her and her children's safety." (see ) Lisa did not. She waited until July 11, 2001 (after closure of the Michigan investigation)

June 14, 2001 (unknown to me) Michigan social services finalized the closure of the case. Five days later, on June 19, 2001, Lisa hired a therapist for our children. At the initial interview, the therapist wrote that Lisa told her our children had been sexually abused. The therapist quoted Lisa as telling her, "Positive it was Kevin, maybe other as well but certain of him." (This is the first time this statement by Lisa is seen anywhere) After being in Alaska for 10 weeks, refusing to come home with our kids with, and with the investigation finally closed in Michigan, Lisa filed for a restraining order in Kenai, Alaska on July 11, 2001. She wrote on her statement of request: “On March 15, 2001 my daughter

Elisabeth told me that her father (respondent) had be sexually molesting her and her sister over time from October 2001to present." She also wrote: "he then threatened to make me ‘fish food’ if I suspected the abuser was him." I was served on July 22, 2001, although my attorney did not make it to the hearing on July 30, 2001. Under questioning from the magistrate, Lisa repeated her written statements. Without anyone there to counter her statements, a six-month order was granted. Lisa's written and oral statements to the court were perjury. Up to this point Lisa never made such allegations, and her statement that she had been threatened by me comes out of thin air. Of specific note is her written and sworn testimony "On March 15, 2001……". The police report was filed March 16, 2001, and none of her restraining order allegations are mentioned. Nor are her allegations included in anything in Michigan, such as notes of social services, the police, or in her voluntary statement provided to Michigan police on March 23, 2001. (I was stunned that the Judge, in asking Lisa questions at the hearing, didn’t ask why she waited 10 weeks before filing for a restraining order! Why not file in Michigan if any of it were true?!) At no point after arriving in Alaska did Lisa make any report to Alaska social services. It was the Court that referred to Social Services to review the case (after the long-term order was granted). Alaska Social services concluded: “Due to this case being investigated in Michigan the Division of Family and Youth Services will not initiate another investigation here.” December 1, 2004 A hearing was held in Larimer County Court on a motion for my mother to be able to visit her grandchildren. ChildSafe therapist Valerie Macri-Lind testified that she recommended that my mother not be permitted to see her own grandchildren. Ms. Macri-Lind said there would be risk of deleterious psychological effects on my children. Had reservations about what my mother might say to her grandchildren with regard to "the children's reality", and that any mention of me or the allegations would be disruptive to ChildSafe's activity with my children. However, glaringly absent from Ms. Macri-Lind's testimony is any mention of her knowledge that my daughter Catherine disclosed in the forensic interview of October 29, 2004 that Lisa Pendleton (mother) had coached her to make false allegations of abuse! This is clearly relevant (and directly contrary) to her stated position of psychological risk to my children. Had the Court had been made aware of Catherine's statements in the forensic interview, it is almost certain the Court would have recognized the inappropriate, even absurd exclusion of a paternal family member in view of mother’s confirmed implantation of false memories of abuse in our children. Ms. Macri-Lind withheld from the Court clear proof that what she termed "the children's reality" was a lie, manufactured and implanted in their minds by their mother.

It is impossible to think that this was anything other than obstruction of justice and perjury by omission. At the time of the hearing, Ms. Macri-Lind had been with ChildSafe for 18 years, and regularly testified in Larimer County Court. Intentionally withholding vital information from the Court, Ms. Macri-Lind and ChildSafe continued with their "abuse therapy" for another 18 months, knowing they were following an inappropriate and even harmful course for my children. Despite Catherine's disclosure of coaching, ChildSafe not only continued their individual "abuse therapy" of my children, but placed both my daughters in group therapy for girls who had made allegations of sexual abuse. Elizabeth was placed in this group immediately after the Department of Human Services found ChildSafe's allegations against me as not credible (Aug 23, 2004). Catherine was placed in this group in September 2005, a month after her individual therapy stopped, and 11 months after her October 2004 disclosure of coaching by mother. At least three ChildSafe therapists were involved with my children (including Lori Lund, who witnessed Catherine's disclosure of being coached), and all shared information with each other, with Ms. Macri-Lind as clinical director. Their actions constitute obstruction of justice, conspiracy to obstruct justice, conspiracy to violate ethical and professional standards, violation of ethical and professional conduct standards, failure to report ethical and professional violations of each other, witness tampering, conspiracy to commit witness tampering, conspiracy to commit child abuse, and emotional child abuse of my children. Lisa Pendleton (mother) cooperated with, and contributed to, all aspects of ChildSafe's therapy on our children. She coached our children to make false allegations of abuse against me. She knowingly committed obstruction of justice, conspiracy to obstruct justice, conspiracy to violate ethical and professional standards, witness tampering, conspiracy to commit witness tampering, conspiracy to commit child abuse, and emotional child abuse of our children. She also threatened a local therapist, resulting in the filing of the police report against her (witness intimidation). Following a police investigation in Alaska, her case was referred to the district attorney for perjury and unsworn falsification. Secondly, at this point ChildSafe was well into its second year of "abuse therapy" with all three of my children. Ms. Macri-Lind testified that contact between my children and my mother would interfere with ChildSafe's therapy of my children. ChildSafe's therapy summaries do not record that Lori Lund referred Catherine for a forensic interview, nor do they record ChildSafe's knowledge that Catherine made a disclosure of coaching by her mother. ChildSafe continued the same line of "abuse therapy" on my children, even enrolling Elisabeth in group therapy “for girls who have sexual abuse histories”. Elisabeth was placed in this group in early fall 2004, "due to her repeated disclosures of sexual abuse by her biological father and an investigation by the Larimer County Department of Human Services which substantiated these allegations." (Macri-Lind therapy summary of Elisabeth-April 14,

2005 ) However, the State Department of Human Services had overturned the report filed by ChildSafe regarding Elisabeth in August 2004, one month before she was placed in group therapy. ( ) Thus, ChildSafe knowingly and inappropriately placed Elisabeth in group therapy, and continued her in this group until May 2005, despite the intervening coaching disclosure by Catherine in October 2004. ChildSafe then continued their “abuse therapy” on all three of my children despite the overturn of their own report to Human Services, and the October 29, 2004 disclosure by Catherine that Lisa’s coached her to make false allegations. In doing so, ChildSafe conducted a cover-up campaign of their inappropriate and harmful therapy on my children. ChildSafe had full knowledge of the hazards they were creating by their actions, and displayed a reckless disregard of possible consequences and indifference to the health, safety and rights of my children. In her sworn testimony on December 1, 2004 Ms. Macri-Lind intentionally withheld from the Court the disclosure that Lisa had coached Catherine. Ms. Macri-Lind then went on to recommend that my entire family be cut off from contact with my children so that ChildSafe could continue therapy on my kids! Macri-Lind knowingly misled the Court in order prevent removal of my kids from their “therapy” and prevent examination of ChildSafe’s actions. Dec 23, 2004 Social services note of call from Lisa to K. Harden voicemail. Lisa details

conversation with Linda Simmons Jan 31, 2005 Colorado Court order that I have “all the rights to records and

communication that a non-residential parent has for his children” Feb 5, 2005 ChildSafe sends summaries only. Nowhere in the notes is any mention of

the October 29, 2004 interview with Catherine in which she acknowledged that her mother had been coaching her. It is specifically absent in the notes of Lori Lund, who initially made the referral of Catherine to social services, and witnessed the interview of Catherine on October 29, 2004.

February 9, 2005 Linda Simmons, the ChildSafe therapist conducting the initial attempt at

reunification, wrote a letter to me that she was terminating contact between my children and me, because I did not follow her recommendations to "admit" to the reality of my children regarding the abuse allegations. By her own writing and confirmation in testimony from Valerie Macri-Lind at ChildSafe, Ms. Simmons communicated frequently and regularly with ChildSafe and could not have been unaware of Catherine's comments made during the October 29, 2004 interview. Thus, it is clear that Ms. Simmons in attempting to have me “acknowledge their reality",

April 25, 2005 My motion to stop Ms. Simmons involvement and just move ahead to

spend time with my kids – vanishes. I called the Court, left messages for the clerk. Nothing happened.

May 17, 2005 Judge denies my motion to get records of my kids from ChildSafe. June 25, 2005 I file a complaint against Larimer Dept. of Human Services. Oct 2005 I have to file for bankruptcy. Oct 30, 2005 I file a motion for parenting time.

Nov 10, 2005 I received a letter from Human Services (Ginny Riley) stating that the case

is totally closed, and that the department will “consider the credibility of the reporting party if other allegations are made”

Dec 14, 2005 Magistrate Schapanski excused 3 ChildSafe therapists from deposition. I

found this very disturbing since a year earlier at the Dec. 1, 2004 hearing, Valerie Macri-Lind, one of the therapists I had hoped to depose, testified in court. Now she gets excused from being deposed? To me it seemed clear that the Magistrate was protecting the therapists from exposure for what they had been doing to my kids. Or worse, he is protecting the system of abuses and civil rights violations from exposure. So much for being allowed my rights as a non-residential parent. (Order Jan 31, 2005)

Dec 28, 2005 ChildSafe summaries, dated Nov 18 and Dec 5, arrive. They were

postmarked December 20, 2005, well after the scheduled date (Dec 15)

of the hearing and deposition. Intentionally delaying their records until

after the hearing, ChildSafe withheld from the Court (and from me) the

fact that they witnessed the interview and statements made by Catherine

in the October 29, 2004 LCCAC interview.

This is fraud and obstruction upon the Court.

Upon reading the ChildSafe summaries (after the hearing), it was

discovered that ChildSafe made no record of their witnessing the

interview of Catherine and her “mom told me” statements.

Also missing from the summaries was the fact that in Sept. 2005

ChildSafe placed my daughter Catherine in group therapy for girls 7-9

“who have made allegations of sexual abuse” – despite their knowledge

of Catherine’s my-mom-told-me statements in Oct 29, 2004 interview -

This was done to “program” Catherine so that she would forget her

confirmation that her mother had coached her to make false allegations

of abuse, and that continued exposure to an “abuse therapy”

environment (individual and group) would enhance her suggestibility to

take on mother’s alienation campaign and push Catherine further toward

This is OBSTRUCTION OF JUSTICE upon the Court for intentionally

withholding evidence. ChildSafe did not want the Court to see that they

had continued Catherine in individual “abuse” therapy, and additionally

in September 2005 witnessed included any mention of Catherine’s

interview in their therapy notes.

Further that they had committed a felony for failing to report emotional

abuse. As did Det. Voleski, Katharina Harden, Jennifer Middleton

(LCCAC), Lori Lund and the “ChildSafe treatment team” for failing report

the emotional abuse or Catherine’s disclosure of being coached.

Although Catherine had disclosed that she was coached by her mother to make false abuse allegations, ChildSafe did not change their “abuse” therapy of Catherine (or Elisabeth). Placing Catherine in group therapy (2005) ONE YEAR AFTER her “my mom told me” disclosure was witness tampering. It was ChildSafe’s effort to cover-up their emotional abuse of my daughter by instilling more of the same “abuse” therapy, causing reinforcement and implantation of a false memory. In this regard they were acting in collusion/conspiracy with Lisa Pendleton to “program” my children. Notes from other therapists (Dr. Govan, Ms. McBride, Ms. Smith) confirm Lisa Pendleton’s efforts to disrupt the reunification process, direct intimidation of our children, and severe parental alienation and implanted memories in my children.

ChildSafe was required by law to report what they saw in the interview. Also, they continued their “abuse therapy” on all three of my kids for another year. A specific process bears detailed consideration. ChildSafe therapists knew of (and witnessed) Catherine’s video statement that her mother had told her to make false allegations against me. ChildSafe did not report it. Nor did ChildSafe alter or reconsider the therapy of all 3 of my kids. Elisabeth at this time was in ChildSafe group therapy for girls who had made sexual abuse allegations, and continued in that group until May 2005

The continual refusal of the Court to allow me full records of my children from ChildSafe, refusal to allow me to conduct depositions of the ChildSafe therapists involved with my children, the repeated failure of the Court to respond to my motions to address the instability of their mother; the Human Services Dept. relationship with the therapists in information exchange; the fact that LCCAC, Human services, the FCPD, State licensing boards and DORA investigators, even the office of the Governor refusal to investigate cause me to consider that collusion or perhaps even conspiracy existed in this circumstance with ChildSafe. There were significant sums of money involved, and ChildSafe was billing for my children’s therapy and group therapy for over 2 years. I at one time asked the State to investigate whether ChildSafe had received Victims

Assistance funds for therapy of my children. I had discovered that ChildSafe does receive substantial federal/state money for its abuse therapy and programs. Keeping my children in their programs is financially advantageous for them. And the continual

Therapists, CDHS workers, LCCAC interviewers, and the police are mandated reporters

of suspected child abuse. Yet none of them reported that my daughter Catherine had

disclosed that her mother had been coaching her to make false statements. This activity is covered and defined within both Colorado definitions of emotional and psychological abuse, and within the Centers for Disease Control child maltreatment surveillance definitions. Failure to report child abuse or suspicion of child abuse is a criminal offense in Colorado. Additionally, with several of these therapists, a human services social worker, and a police detective all witnessed Catherine's disclosure that her mother coached her to make false abuse allegations, and none took any action or made any separate report to investigate the mother. I believe this constitutes a conspiracy to obstruct justice, and more importantly constitutes child abuse in itself. Further therapy, both individual and group, was intentionally and needlessly conducted on both my daughters CDC CHILD MALTREATMENT –

http://www.cdc.gov/ViolencePrevention/pub/CMP-Surveillance.html

Dept of Human services knowingly and repeated interfered with and damaged the parent-child bond and relationship between my young children and me. The actions of Dept Human Services constitute failure to report or respond to emotional and psychological child abuse as defined in by Colorado law, and Centers for Disease Control (CDC) Child Maltreatment Definitions. Specifically regarding Ms. Macri-Lind: in her testimony of December 1, 2004 she testified that visits between my children and my mother would not be advisable because of her concern that my mother might say something that might not validate my children's “reality”. She also testified that contact between my mother and my children might pose some psychological risk because of a “family resemblance" between my mother and me, and went on to testify that the only people that she would advise to limit my children’s contact with is me and my family. (Transcript excerpt of Dec 1, 2004 p) A: "Ms. Maguire and Dr. Maguire's family members who the children don't know. Q: So basically anyone related to Dr. Maguire A: Correct. Ms. Macri-Lind was aware of the interview of my daughter Catherine on October 29, and aware that Catherine said that her mother had coached her to make false allegations. This is confirmed in her own notes indicating that she had frequent contact with other child safe therapists, and

specifically with Ms. Lund, the child safe therapist who had been present at Catherine's October 29, 2004 interview. This is obstruction of justice. Ms. Macri-Lind, Ms. Lund, Ms. Middleton (LCCAC interviewer), Ms. Simmons, and Detective K. Voleski are ALL mandated reporters. They are required to report suspicion of child abuse. Failure to report such suspicion is a criminal offense in Colorado. Additionally, if knowledge of the Oct 29, 2004 interview and disclosure of Catherine’s coaching by her mother was made known, it would have allowed the Court full knowledge of the information and actions of Mother and prevented another 2 years of false allegation-chasing and needless therapy by ChildSafe in pursuing a false line of accusation. Keeping knowledge of both the interview and the disclosure of Mother’s action a secret from the Court, was intentional fraud upon the Court, failure to give me the information entitled (I had joint legal custody) Social services. Despite the ChildSafe and Lisa allowed the therapy to become abusive and directly aid in the alienation which was later so terrible as to evince emotional harm to our children. (see “I hate Kevin” letter, and Elisabeth’s letters 2006-07) This went far beyond misrepresentation. Failure to disclose their knowledge of Catherine’s comment allowed them to keep my daughter in therapy circumstances which reinforced mother’s coaching, cover their tracks for their abusive and inappropriate therapy, and help mother to continue her psychological abuse, brainwashing and alienation. Together these constitute a conspiracy to commit child abuse, willful failure to disclose a statement of emotional or psychological abuse by a child, and fraud upon the Court for withholding information which would have given up to date and complete information for proper evaluation of the children’s circumstances. Deflecting the “grandmother may make statements counter to the children’s reality? Catherine already made that statement! Catherine’s statement exposed the lie and harm being perpetrated by her mother and ChildSafe, and ChildSafe needed to cover it up. Mother was cooperative in bringing our children to ChildSafe for further harmful therapy. Social services, LCCAC and the police were all too willing to cooperate by keeping silent. Conspiracy to obstruct justice: Present at Catherine's October 29, 2004 interview were Katharina Harden, social services; Detective Kathy Voleski of the Fort Collins Police Department; Lori Lund, Catherine's therapist at ChildSafe (Ms. Lund made the social services report of Oct 11, 2009 which led to this interview); and the LCCAC interviewer Jennifer Middleton. Confirmation that they witnessed Catherine's statement that her mother had coached her is documented in Katharina Harden’s social services notes of the interview, noting the presence of herself, Lori Lund, and Detective Voleski at Catherine's interview.(social services note - On November 16, 2004, following a visit with my children, as I walked into the parking lot I was met by Katharina Harden and Detective Voleski. Ms. Harden said she wanted the three of us to go somewhere to talk about the case right now, saying that she wanted asked me a few questions. I said the case went back many years and that this would probably be better done my attorney's office. I gave them his address and phone number and said that we could arrange to speak at his office. (CD of the police recording available) Later we agreed to meet on November 18 in my attorney's office.

After visiting with my kids on November 18, 2004 my attorney and I met with Ms. Harden and a different Fort Collins policewoman. Ms. Harden spent just short of two hours asking questions about Michigan, and only a few minutes speaking about Colorado. I told her that the case had been in Michigan and Alaska now in Colorado, and that the allegations Lisa Pendleton and ChildSafe had made last year (Aug 2003) had been overturned by the State Department of Human Services. Ms. Harden said that she didn't care, that she was going to continue with another investigation. (social services note) According to her notes, Ms. Harden went to the home of Lisa Pendleton on November 22, 2004 and "updated" her on the meeting that she and the police detective had with me in my attorney in his office. “Home visit yesterday to update mother about interview yesterday with father.” Ms. Harding also made a reference to “pending criminal cases." Her use of the word "updated" implies that Ms. Harden had previous conversations with Lisa Pendleton, and discussed what appears to be an ongoing social services investigation. Larimer County Department of Human Services, Fort Collins Police Department, ChildSafe therapists, Larimer County Child advocacy Center (LCCAC) and Lisa Pendleton, have conspired to conceal and undermine any attention or further investigation into the actions allegations and responses of the above parties as regards my children and myself. The statements of my daughter Catherine, repeatedly identifying her mother as coaching her, is perhaps the most obvious and egregious example of Lisa Pendleton's ongoing campaign against our children, not only go unreported or investigated, but the agencies and individuals involved, including On June 27, 2005, I filed a complaint against the Larimer County Department of Human Services with the Colorado State Department of Human Services. I requested an investigation into their actions dating back to August 2003, which had been inflicting/permitting emotional and psychological abuse on my children, and also for apparent collusion in refusing to investigate that my daughter Catherine that she was coached by her mother to make false abuse allegations. For over a year I wrote to multiple departments and dozens of individuals within the Department of Human Services, State and local government. What responses I did receive were dismissive and did not answer my questions. Glaringly absent was any mention of my daughter Catherine's October 29, 2004 forensic interview and her statements within that interview. On March 10, 2006 the Larimer County attorney wrote to me "There will not [be] any further investigation conducted nor will there be further correspondence with you about this investigation." I had also requested to present my complaint to a Citizen Review Panel, per Colorado law (section 19 – 3 – 211, CRS). I was repeatedly denied. From May and September 2006 I wrote to the Governor. The final letter concluded: The Office of the Governor is unable to dedicate any further resources to assist you with this matter. (September 27, 2006)

I wrote to Gov. Bill Ritter, December 25, 2008, but I received no response. ChildSafe, social services, LCCAC and Lisa Pendleton have acted individually and collusively to maintain a stream of allegations and baseless safety concerns in order to keep my children and I effect an underlying pattern of efforts to elicit an “admission” from me, to continue my children in therapy for “abuse” which has been disproven and even confirmed as coached by their mother, The organizations, agencies, and individuals identified above have intentionally and maliciously engaged in a continual stream of allegations, recovered memories, inappropriate “abuse” therapy, failure to document therapy used, refusal to release records, obstruction of justice, conspiracy to obstruct justice, failure to report emotional/psychological abuse, coercion to elicit an “admission” and failure to document statements from my children which would have exposed the unnecessary therapy enacted on my children. What is apparent from this pattern is that many have profited, especially the various therapists. Maintaining the façade allowed ChildSafe to collect tens of thousands of dollars in payments for “therapy” on my children – needless and harmful therapy. Other therapists, ostensibly involved to break the pattern of alienation, also garnered tens of thousands of dollars in fees. Collectively and individually, this amounts to nothing less than child exploitation. The evidence presented here is representative. They have knowingly acted to directly cause and to abet child abuse of my children, refused to take action to stop the child abuse, failed to properly investigate the abuse, altered records, made false reports, withheld records to which I was entitled, and acted with coercion and in collusion with private individuals/organizations to deflect attention and to cover up their part in the abuse of my children and the violation of our civil rights. I have grave concerns about the manner in which the investigation of the possible abuse of my children was conducted in Michigan. Some specific points stand out. First: Our daughter Elizabeth identified and described Mr. Denise (Shawn Cotter) multiple times to both Lisa and me. She disclosed "a friend of aunt Denise" at her forensic interview at Care House (no video done) Elizabeth directly told the police Lt. that the man had "a tattoo where he pees". An arrest record of Shawn Cotter identifies a tattoo on his right hip. Second: Despite the above evidence, just five days after the forensic interview Care House told the police that Elizabeth would have to undergo as much as six months of extensive counseling in an effort to have her “name her attacker”.

Also, despite the above evidence, the police wrote “It is recommended that no suspects be interviewed until one is actually named by the young victim". Third: Despite the initially detailed disclosures of Elizabeth, there was apparently no effort made to conduct any investigation whatsoever of Shawn Cotter, or of Lisa's aunt's house. The transfer of the case from Farmington Hills to Huntington Woods seems to have deflected all interest from investigating Elizabeth's initial disclosures. Fourth: It seems clear that both the police and Care House inappropriately left the investigation function in the hands of the therapist recommended by Care House. This is even more disturbing in that Elizabeth had already given multiple disclosures naming Shawn Cotter (Mr. Denise). Thus leaving the therapist with the task of eliciting a name from Elizabeth, rather than concentrating solely on her professional role, that of assessing the need for and providing psychological or emotional therapy. Fifth: Regarding the April 6, 2001, questioning session at home conducted by Lisa, there was no effort made to confirm that this questioning session was conducted at the request of the therapist (it was not requested or approved by the therapist). It is later noted that no action could be taken in the case because of the repeated questioning conducted by Lisa. Sixth: Regarding the effect upon our children of having to undergo