OSC Response- Clean Copy

February 5, 2023

To the Court and Judge Prus:


While not a United States citizen, I have lived here for almost fifteen years. I am originally from Dublin in the Republic of Ireland, where my parents and siblings still reside. Notably I have not visited Ireland for three and a half years, largely due to these proceedings and the Plaintiff’s refusal to allow me to take our child with me to meet his extended family and foster many positive and nurturing relationships. 

I would like to present to the Court some of the Plaintiff’s history, the many negative findings on the Plaintiff from the forensic report, and address issues concerning the Plaintiff’s testimony during the forensic evaluation. 

I kindly ask the Court to review this response with the sole objective of achieving what is in the best interest of our child


Both Kellen and I have sustained many abuses by the Plaintiff. We continue to endure a dire living situation, such as me sleeping on a mattress, inappropriate heating and A/C, having to pay for our laundry facilities, and scrutinization for using lights or household appliances. Attempts to negotiate these substandard conditions are met with aggression from the Plaintiff. Additionally, Kellen is under constant scrutiny and monitoring from his father. His autonomy is compromised when he is subjected to excessive and petty chastising. For example, he is forced to pick up grains of rice or crumbs when they come off his plate, and disproportionately scolded when losing a Lego piece. These issues amplify my resolve to safeguard against any future harm to our child. It is self-evident that this environment is damaging to Kellen’s well-being.

There have also been numerous issues with the Plaintiff’s responsibility to pay health insurance. I have three outstanding bills that have not yet been paid despite the Plaintiff’s assurances that I was covered under two healthcare providers for the month of April (See Exhibit Health Insurance). I have sold my personal belongings and enter into considerable personal debt. I have done so in the knowledge that wealth should not be a deciding factor in the safety of our child.

I am subjected to antagonistic comments and actions. For example, on March 26, 2021, when I was preparing food for Kellen, I asked the Plaintiff not to remove my items from the drying rack. The Plaintiff removed the drying rack from the counter, explaining that he ‘can end the problem’ by taking it away. Kellen replied, ‘leave Mama alone’. The Plaintiff then re-entered the kitchen and instructed me not to use any other kitchen items – ice cube trays, pots, pans, etc. Kellen became upset and started crying. I comforted him by taking him away from the situation. The Plaintiff followed and pulled Kellen to which I asked him to stop. In a similar encounter, on January 29, 2021, during a discussion regarding the dog’s bowl, the Plaintiff responded to my request not to throw it on the floor, “I don’t care what you are asking me, get out of my house.”

In just a few weeks following our marriage, there was a significant change in the interpersonal dynamics. The Plaintiff became very controlling and continually threatened me with divorce as a means of intimidating and isolating me. I engaged as little as possible with the Plaintiff, and only when pertaining to Kellen. This was because these encounters served the Plaintiff with an opportunity to be abusive, combative, and argumentative, often in front of Kellen. He is a perceptive child, so I am always mindful of Kellen when the Plaintiff and I interact. 

This experience has taught me that in order to successfully parent Kellen and provide for him, I need a more flexible working arrangement. This will allow me to overcome the Plaintiff’s many attempts at minimizing my career opportunities and using certain vulnerabilities against me. For example, the Plaintiff failing to attend my green card interview, lacking access to my immediate family for support, and the obliteration of my finances to successfully start anew. I am fully cognizant of the responsibility I have in moving forward with my own life. I have secured a job and a home for Kellen and me with immediate effect. I plan to reestablish my LLC.

I would like to contrast that with the limited offers to include me in joint experiences the Plaintiff has with Kellen. He continually excludes me from speaking to Kellen in the home, which is confusing to a small and impressionable child. Also, for the past two Christmases, both the Plaintiff and his mother have purchased and decorated a Christmas tree with Kellen. They have waited until I left the home to commence this tradition. The Plaintiff is fully aware of how much I love the holiday and its traditions. Deliberately excluding me from this shared experience with our child has been immensely painful. Kellen has never watched TV at home. The Plaintiff refused to allow a TV to be set up in the living room and I have sold the one I once had in the master bedroom. Sometimes I would go into the kitchen early to prepare breakfast for Kellen and me. We tend to either read or watch an episode of a show on my iPhone. The Plaintiff accuses me of buying candy, toys and giving him my phone or iPad to entertain him in the morning. The Plaintiff does the exact same thing and in fact initiated these actions. (See Exhibit Plaintiff and Kellen in bedroom with iPad and iPhone). Appropriate climate control continues to be an issue in the residence. The living room and kitchen remain cold with inadequate heating or air conditioning. As a mark of being a competent father, he spends more time with Kellen in the morning. However, what was enticing to our small child was the Plaintiff’s substantially warmer room. The rest of the house was often below sixty degrees in temperature. Additionally, the Plaintiff has a comfortable king-size bed and access to many children’s shows on the Plaintiff’s iPad, which could go on for an hour or two. (See Exhibit Plaintiff with Kellen iPad ). Since the return of the forensic evaluation, the Plaintiff’s narrative has changed to suit his new agenda. He now claims he doesn’t have ‘access’ to Kellen in the morning. Prior to the March and April hearings, there were constant outbursts regarding kitchen utensils almost every single day. The Plaintiff spoke of a $3-5 hard plastic spatula being burned, and a wooden spoon, having a burned marking on it. Even if I had accidentally done this, which I am not convinced I did, it would be in keeping with the necessary process of making a meal, rather than a malicious attack against the Plaintiff, as he appears to be characterizing it. On a further occasion, after discussions with my lawyer over an ongoing attempt to get the Plaintiff to secure and pay for health insurance each month, the Plaintiff became upset. In a fit of rage, he walked straight into the kitchen and removed a large, sharp knife from the counter as I was preparing a meal. The Plaintiff then proceeded to remove all the knives from the magnetic holder on the wall behind me and claimed I’d been damaging his things. The Plaintiff brought all the knives to his bedroom, which I suspect was an attempt to intimidate and frighten me, where they remain still. (See Exhibit Knives). 

While claiming alienation, the Plaintiff exercises double standards by expecting me to leave the house any evening that he spends time with Kellen. This also happens in the daytime when the Plaintiff often stays at home. Not only is this unreasonable, but this tactic also prevents Kellen from engaging with me in a natural way when we are both present. When I am in the house, his controlling impulses mean he will constantly keep Kellen from me by locking himself in the room with Kellen, preventing us from saying goodnight. Kellen once responded, “Dada, open the door, Momma is my friend”. It is in fact the Plaintiff who is alienating me from our son by doing this. As a result of these proceedings, I am experiencing genuine alienation from my family (as is Kellen), as well as from employment opportunities. This limits my financial security and my ability to attain independence to remove myself and Kellen from this controlling dynamic. I am eager to return to the very successful life I had created while working and living in New York prior to meeting the Plaintiff. Mealtimes and food are another way that the Plaintiff exercises attempts at division, control, and manipulation. He has been known to give our child multiple ice-creams on the same day and regularly decides to give our child ice pops as I was preparing dinner. This leaves our child with little appetite and delays his bedtime routine. I often try to include the Plaintiff in dinner plans, as Kellen often asks for us to all eat together when we are in the home (See Exhibit Eating Together). This is not reciprocated by the Plaintiff. On a handful of occasions, the Plaintiff made dinner for Kellen and himself, and I would be eating a different meal. The Plaintiff often insists that Kellen, eats, usually by way of threats or coercion or putting food up to his mouth or telling him the number of bites he needs to consume before he is allowed to be finished. 

The Plaintiff bought very few toys in the first couple of years of Kellen’s life. He has now bombarded Kellen with an abundance of Lego building kits. Though, Kellen is not really given full access to them and is not allowed to break them as he plays. If Kellen drops a piece, the Plaintiff will confiscate them from him. On the contrary, I do my utmost not to flaunt our agreed-upon handoffs. I make every effort to return on time to care for Kellen. When I have been delayed due to traffic, train delays or long lines at the grocery store, I usually reach out to notify the Plaintiff. Conversely, the Plaintiff has been deeply disrespectful of my time, returning an hour or more late following his many golf outings with no apology or explanation. On one particular evening the Plaintiff was scheduled to care for Kellen, the Plaintiff stepped out with his phone and laptop open to ‘take a work call’. He returned close to midnight smelling of alcohol and calling me names as he walked past me to his bedroom. Turning off the lights has also become a compulsive trait for the Plaintiff over the last year. The Plaintiff, out of spite, has turned the lights off in the living room while I sat on the couch working on my computer. He would also turn off the lights outside my closet while I search for clothes to wear. Other antagonistic behavior includes picking up my dog’s hair from the floor and throwing it in or on my laundry bag. He has used my hand towel to wipe the floor and put it back filthy on the rail for me to continue to use (See Exhibit Dirty Towel).

Since receiving and reading the Plaintiff’s filing, I have experienced enormous mental pain and anguish over its content. Consequently, I have lost close to ten pounds in just a few weeks (149lbs to 139lbs) (See Exhibit Doctor Visits), I have struggled to focus on the training at my new employment and the little sleep I get is broken each and every night. I have never, in my entire life, experienced such a sustained and deeply stressful situation, environment and character. The toll on my health is no doubt significant and I wish for it to end post haste and ask that the court please intervene to enable this.

The Plaintiff’s claim that it is in his best interest to have exclusive use of the property is a further example of him prioritizing his own needs. It shows little desire to do what is genuinely best for Kellen. The sole objective of the Plaintiff is to secure his assets and maintain his financial net worth. He has not disclosed a single piece of financial documentation in three years besides his tax returns (See Financial Net Worth). I did not refuse to follow the court’s direction as suggested by the Plaintiff. The transition to move out was not feasible at the time, given the financial parameters and disparity. Consequently, the orders were vacated by Judge Prus. This is a matter of record, making the Plaintiff’s claim easily falsifiable.

On April 12, 2018, following an incident, the Plaintiff was charged with ‘Assault in the Third Degree’ and ‘Endangering the Welfare of a Child’. This was our 3-and-a-half-month-old child. Ideally, since then, Kellen and I should not have been living with the Plaintiff. I have wanted to leave the marital residence since this time. There have been various matters restricting my ability to do this, largely revolving around the Plaintiff’s behavior and unwillingness to accommodate even basic requests to facilitate this. These include establishing childcare so I could work, and the sabotage of my immigration status. The Plaintiff has also shown an unwillingness to come to any meaningful or fair settlement, so that Kellen and I can establish a new home environment. 

I have also made many efforts to settle in an attempt to extricate Kellen and I from the toxic living environment created by the Plaintiff. The first attempt to try to discuss a settlement was with the Plaintiff’s first lawyer, criminal defense lawyer Anthony Bramante, which ended abruptly when I asked for some assurances that our child would be safe when the Plaintiff is caring for our child. Following this, they walked out of the room. When the Plaintiff retained a second lawyer, mediation lawyer Sabra Sasson, the Plaintiff postured, was combative and abusive to both my lawyer and I. Etched into my mind was his statement, “I’d rather burn the money than give her a penny.” Following the forensic evaluation and early 2021 court hearings, the Plaintiff made a new settlement offer. This was even lower than what was offered in 2019 and included a lump sum of $10,000 which does not even cover my accumulated debt, legal fees and any funds to re-establish a new home. I cannot understand his continued inability to consider the needs of our child. My custody demands were fair and reasonable, given the Plaintiff’s history and continuous negative and problematic behavior. 

  The Plaintiff barely provides shelter. I have slept on a mattress for close to two years in our child’s room. Although he does pay for the utilities, he would be paying comparable costs with or without my presence. He has failed to provide AC or heating for our child in the cold winter months and sweltering heat. I have paid for all mine and Kellen’s food. The Plaintiff makes random food purchases, usually enough to cover the next meal or two while he cares for Kellen, or more often than not, take-out. In the past almost two years, the Plaintiff has not paid for any of our child’s primary needs, such as clothes or shoes. There have been a few exceptions where minor items were purchased by the Plaintiff. 

The money the Plaintiff provided was for my lawyer’s initial retainer, sporadic child support payments (predominantly during the time I was custodial parent during ACS and family court proceedings), and when the Plaintiff traveled back and forth to California. I would like to make note, that while I did receive some monthly child support payments, I was already in deep credit card debt. This was perpetuated by the financial abuse sustained in the marriage prior to the Plaintiff’s arrest. I estimate I received $100 on five occasions. 

With respect to health insurance, this has been an ongoing issue since the Plaintiff lost his job in April 2020. Judge Prus ordered the Plaintiff to secure the insurance forthwith in September 2020. There was a delay of an additional five months to secure it. Since then, the Plaintiff has failed to pay the premium on time each month. Both Kellen and I also have outstanding bills due to the Plaintiff’s non-payment (See Exhibit Health Insurance Bills Lisa and Kellen), with Kellen’s Pediatrician’s office reaching out twice because of failed payments. 

When I was employed for a short duration in August 2020, the Plaintiff made it tremendously burdensome by having me care for Kellen most mornings prior to my leaving and when I returned home each evening, sometimes close to 7pm. While I had been at work, our child was not fed dinner, bathed or in any way prepped for bed, despite the Plaintiff being out of work. I did it all except for the two or three meals the Plaintiff made, and the one time the Plaintiff bathed Kellen. Then, on those weekends, I cleaned the house, laundered the clothes and bought groceries for the week ahead. 


I have consistently attempted to provide the financial stability essential for Kellen’s wellbeing. For over two years, I have purchased almost all of Kellen’s clothes, coats, shoes, boots, haircuts, toys, food, play outings and excursions as well as his basic needs (See Exhibit Spending Since Cut Off September 2019). Conversely, when I have asked the Plaintiff to contribute to any of these items, on countless occasions I am ignored. In May 2021, I provided a toddler bed for Kellen. Earlier this year when Kellen’s stroller broke (See Exhibit Broke Stroller), and the Plaintiff refused to replace it, I resorted to accepting a second hand one as I did not have the means to purchase a new one. He has recently bought a new car, $600 headset and guitar (See Exhibit Car, New Headset and Guitar). Additionally, the Plaintiff refuses to maintain consistent health insurance which Judge Prus has been made aware of. 

 Many of the Plaintiff’s points show a complete disregard for truth and fact. I was a regulatory reporting analyst, and I left my job to set up my own business. I submitted an entire application to immigration, including a comprehensive business plan on X (See Exhibit Immigration Cover Letter and Business Plan). The Plaintiff is fully aware of this entire process. For him to claim otherwise is preposterous. I moved in with the Plaintiff to his apartment with his agreement, as the Plaintiff’s apartment was both larger and cheaper than mine. With respect to subletting my apartment, it was discussed as a possibility for the last two to three months of my lease. However, subletting was not permitted by building management and would result in penalization if found to be doing so. I underestimated the time needed to repaint the apartment and paid an additional two to three days rent in order to secure my deposit. I do not recall the Plaintiff making any repairs. I have always tried to work and earn money.

The Plaintiff is aware of my dire financial situation. Any money I have accumulated has predominantly been spent on food, clothing, toiletries, travel and anything Kellen needs on a weekly basis, amounting to almost X in X months, which I would like partially credited for by the Plaintiff. Regarding my spending, I have almost every receipt since the Plaintiff cut me off financially as per (See Exhibit Spending Since Cut Off September 2019). With respect to the rentals the Plaintiff speaks of, I question if any of them are fit for a small child or are in keeping with the living situation he has known since birth.

The Plaintiff fails to mention that though we were married, and now pregnant, I still did not have a work permit. This was granted in August 2017 when I was now four to five months pregnant. I applied for countless jobs, interviewing for temporary work, but did not gain much traction possibly due to being visibly pregnant. Besides, I was first promised that I would never have to work, and that I could be a stay-at-home Mom if that is what I wanted. Then, when I did not work, I was called a ‘gold-digger’ or a ‘deadbeat’. When I suggested taking odd jobs to sustain myself, I was threatened with reports to immigration. Consequently, I was the constant housekeeper, cook, dog walker and mother to our child. I maintained all these roles while the Plaintiff traveled extensively throughout the world, accumulating wealth and elevating his socioeconomic standing and career prospects. I ask that these many abuses also be taken into consideration when settling on equitable distribution of finances. 

During the summer of 2019, when the Plaintiff moved back to New York full-time, I decided that I would like to return to work, or revisit my business idea, but the Plaintiff simply refused to pay for any childcare, even part-time and as a result we lost two wonderful nannies. It was at that time that I remained stuck in this dilemma and without family for a time, while the Plaintiff lived a bi-coastal lifestyle, earned a huge salary and bonus all while I predominantly raised our child for the first year and a half to two years of his life. 

I am keen to accept any form of employment to improve my personal situation and find a way to move out of my current living arrangement. I accepted a sales role with MetLife in June 2020. It was a commission-based role and I needed to obtain my license before starting the position. Towards the end of my studies with MetLife, I was offered a salaried position with Neuro-Insight, which I gratefully accepted. This was because it was a more secure and stable opportunity. I started the role in August. I did not leave this role due to any difficulty in being away from Kellen. 

I would like the Plaintiff to show me evidence of thee technology purchases he claims I have made. My wireless headphones are replacements from Bose – the original of which was purchased by the Plaintiff. Another set of headphones I now possess were left out as a donation on our street, which work perfectly after I replaced a cable. Any devices I use were not new purchases or new replacements, but instead kindly donated to me by a friend. Conversely, it is the Plaintiff who is indulging in grandiose purchases, while I plunge deeper into debt due in order to provide for my child and me. Since these proceedings started, the Plaintiff has purchased to name a few, a new Volvo XC60 car, $500+ headsets and a new guitar (See Exhibit Volvo XC60 car, $500+ headsets and a new guitar). Again, I believe the Plaintiff is misquoting Dr. Moscovitz as I do not recall telling Dr. Moscovitz that I had sufficient funds to support myself, but rather sufficient funds to sustain my present living situation.


The forensic evaluation was necessitated because of the many serious concerns I have regarding Kellen’s safety and psychological well-being. More specifically, when in the care of the Plaintiff when I am no longer in the marital home. I made no attempt to stall proceedings, which were delayed by covid and largely by the Plaintiff’s spending almost six-months to respond to my submitted evidence. 

During the forensic evaluation, the Plaintiff alluded to Kellen having light scratches on his arm possibly because he had fallen from the stroller, however the Plaintiff mistakenly dated this incident, and he was in fact caring for Kellen on the day in question. The final report contains pages of negative findings for the Plaintiff, which validates many of my concerns and the abuses I sustained. 

There are many documented instances of alcoholic abuse by the Plaintiff. The Plaintiff has assaulted me and verbally abused me while intoxicated. The Plaintiff has two prior DUIs, one with assault. The Plaintiff has driven while under the influence of alcohol the entire time I have known him, including during my pregnancy and also with our small child in the car (See Exhibit Drinking and Driving Justification Text). The Plaintiff has admitted to me that he is an alcoholic. Yet, despite this, has not engaged in any treatment or recovery program. 

Also, the report does not recommend a true equal 50/50 split for custody. Instead, it states that “Assuming sufficient resources are available for Ms. Roelants to find a suitable living situation for her and Kellen, it is recommended that the defendant be awarded physical custody, with the father having significant parenting time (40-50%), including overnight stays apportioned in such a way to minimize Kellen’s transitions.” While a 40% temporary custody arrangement is preferable, I still am not comfortable rising to this level of parenting time for the Plaintiff from the outset due to his abusive nature.


I vehemently deny claims by the Plaintiff that I have tried to alienate Kellen from his father. Nothing could be further from the truth. I understand fully the importance and affirmative impact in maintaining a positive connection with his father. In the past 3 years, I have gone above and beyond to try to include him in countless outings, events, concerts, holidays, and classes with Kellen and me. When the Plaintiff lived and travelled extensively to and from California for an entire year, I consistently ensured there was contact both morning and night via FaceTime, except for when there was timing conflict. I have even surprised the Plaintiff with Kellen at JFK airport upon his arrival from California, to which his response was that I only ‘did it for a ride home’. 

For the Plaintiff to suggest that I am inconsistent with nap and sleep times is simply egregious. It is extremely difficult for me to keep Kellen on a consistent schedule when the Plaintiff does not maintain the same schedule. The Plaintiff happily lets Kellen take a three-hour nap; I believe this is to serve the Plaintiff so that he can have additional personal time to work out or to be on his laptop, etc. During Kellen’s three-year check-up, Dr. Danis Copenhaver (Pediatrician) suggested that some children stop napping at two years old, and that Kellen naps for just one hour and is then woken up to maintain a good sleep pattern for nighttime. I have asked the Plaintiff to honor this advice many times, but he simply refuses. If Kellen is let sleep for a longer period, it disrupts his bedtime routine.

The Plaintiff physically removed me from the master bedroom soon after his return to the marital residence after the family court matter ended on April 10, 2019. I resorted to sleeping on the sofa for a time until I could secure a mattress. I had no choice but to sleep in the basement, however, when the Plaintiff vindictively removed the camera from our child’s room, I had no visibility or audio of our child should he wake at night.  I have tended to our son every night of Kellen’s life and due to the Plaintiff’s actions, I had to sleep on the sofa in the living room. Soon after this event, the Plaintiff physically removed all the AC controls from the walls having sole control, and since then Kellen and I have endured horrendous hot and cold living conditions. I continuously move the mattress into Kellen’s room at night and remove it each morning in order to maintain Kellen’s space for the entire day. This myriad of behaviors from the Plaintiff around my sleeping in the residence, only serves to humiliate, embarrass and shame me even further, notably in front of his guests and family, notwithstanding having me sleep like a parting guest. With respect to showering Kellen, I’m not allowed in the Plaintiff’s bedroom and so I cannot bathe my child regularly in the bathtub which is in the bathroom in the master bedroom. 

The Plaintiff is so sensitive and aggrieved by everything I do. I cannot do anything nice for our child without the Plaintiff feeling alienated. I’m not permitted to remain in the residence during the Plaintiff’s time with Kellen and this speaks to his need to dominate exclusively his time with Kellen.I have not been allowed by the Plaintiff to have our child Christened (though both raised as Catholic), to obtain an Irish passport and for Kellen to be allowed to travel to Ireland with me to meet his family and enjoy his rich culture and heritage. 

Plaintiff’s citations such as poorly loading a dishwasher, leaving lights on, fridge and freezer doors being left open, and finding puddles on the floor, are trivial in nature. Especially when taking into account the abusive and coercive nature of the Plaintiff and how a young child is forced to witnesses this behavior despite my best attempts to shield him from it. The Plaintiff characterizes these as an attempt to antagonize him, when in fact they are often my attempts at maintaining a warm, clean, and bright environment, and a positive home for our child. 

The Plaintiff speaks of inattentiveness and safety, and yet, on X, 2018 at Xam, the Plaintiff came home drunk, left the stove on high, which burned off the boil, while the Plaintiff was passed out on the sofa. Fortunately, I came into the kitchen to prepare a bottle to feed our child (See Exhibit Gas Stove and Pots). Also, contrary to Plaintiff’s assertions, I have in no way abused the Plaintiff, be it emotional, mental, financial, or otherwise. The Plaintiff is in no position, nor is he qualified to speak about, my mental or emotional health. It has, however, been fully explored by Dr. Moscovitz which demonstrated the Plaintiff’s claims have no factual grounding.

I moved in with the Plaintiff in 2014. Life together was fun in the beginning, with some support and comforts. The Plaintiff paid the rent and some dinners and on occasion a gift. I covered almost all the groceries for us both, and I paid for all other aspects of my life at that time as I had the means to do so, and I continue to do this. However, at every opportunity, be it with friends, family or sometimes colleagues of his, he would mention that he was paying rent and would bring it up at some point in the conversation. It was an opportunity to shame and demean me in front of people, something I had never experienced before as I have always been independent. In hindsight, I now realize that he was putting me in a position where I became more financially dependent upon him and that it was a mistake giving him the financially control, thus empowering him to control and abuse me as time progressed. 

During my pregnancy, the Plaintiff from the outset wanted to abort the baby, telling me that the best thing that can happen is that the baby dies (and subsequently after his birth, that it is best for Kellen if I die). The Plaintiff then refused to pay for prenatal classes, berated me because of a particular stroller, and begrudged even minor purchases. I borrowed maternity clothes, baby clothes, and a co-sleeper for our child. I also had to resort to sourcing free prenatal classes, canceling doctor appointments, and walking to places due to no access to money even after selling many of my furniture, artwork and personal belongings. In the final weeks of my pregnancy, when the nesting instinct was most powerful, I was never afforded the opportunity to prepare or decorate a nursery. The Plaintiff then compounded my worries and refused to attend the childbirth. When Kellen was born, I was horrifically verbally abused, notably on January 11, 2018, with the Plaintiff telling me to ‘kill myself’ and continued right up until I was assaulted on April 12, 2018, ended up in the Emergency Room where the Police met me because I thought my ribs had been fractured due to the force of the hit by the Plaintiff. What is significantly unsafe and highly questionable behavior by the Plaintiff, is leaving Kellen alone in his car while he dropped off laundry on X., or leaving our child outside a pizza restaurant, alone in his stroller on X. Additionally, I have copious records of Kellen not in his crib until after 10:30pm, 11.30pm or 12:30am, which usually means he wakes extremely late and thus, knocks off his nap time for the following day again (See Exhibit Bed Empty at Nighttime). On April 3, 2021, the Plaintiff took Kellen from the house at 7.45pm. At this point, our child had not had any snack or meal following his nap. The Plaintiff returned home at 10:10pm, by which time I was already in bed. The Plaintiff then started running a bath for Kellen and himself. Kellen didn’t get into bed until after 11pm (See Exhibit Leaving House, Returning Home, Kellen Going To Bed Wet Hair).

Most recently, on Friday April 23, and Saturday April 24, 2021, the Plaintiff demonstrated a level of neglect and abuse that is significant when Kellen was unwell with a fever. Kellen woke up just after 2 am, he looked and sounded visibly unwell, and he had a high fever and told me he had a sore throat.. I went into the Plaintiff’s room to inform him of Kellen’s condition and to ask about medication. He barely budged. I gave Kellen some Tylenol. I nursed Kellen for an hour and tried to cool him down, but his fever didn’t dissipate. I went back to the Plaintiff to discuss Kellen’s symptoms and to tell him that his fever was not going away. He didn’t seem bothered. The symptoms seemed to resemble Covid symptoms in a small child as he also developed a cough. I then called the emergency number for Kellen’s pediatrician at South Slope Pediatrics at 4:30 am. They called back about 20 minutes later and gave me some guidance. I stayed awake with Kellen until 5:45 am, patting his brow with a damp cloth, comforting him, singing to him. What bothered me most was the Plaintiff’s lack of concern for Kellen. 

Later that morning, I received a text message from Greg containing false accusations against me (See Exhibit Text Message). This, as well as the many false accusations made against me is another form of abuse by way of trying to discredit my character and behavior. He said the entire place was reeking of alcohol! And I was too! I walked out the door and although I expected accusations to start to come, I was shocked by the audacity of his blatant lies since I haven’t consumed alcohol since 2019. I decided to be proactive and secure a blood test (See Exhibit Blood Test). 

I have taken Kellen to every single medical and dental appointment to date. During Kellen’s three-year checkup, Dr. Copenhaver stated that sugar is fine and that even four cookies a day is considered acceptable. Dr. Copenhaver also stated that diabetes in children is not attributed to food but more to genetics. Kellen also had his first dental check-up on X and his teeth are in great condition. But yet again, the Plaintiff found a way to exploit an unfavorable comment about Kellen’s teeth. The dentist suggested we should work towards reducing and ultimately removing Kellen’s pacifier as the direction of his teeth may skew further the longer it remains. However, since then and because we are still under the guise of the court, the Plaintiff practically sits at home trying to record any and all incidents of pacifier use, to convey that I may be somehow neglectful or harmful to Kellen in order to paint me in an unfavorable light. (See Exhibit Kellen’s Teeth). In fact, the Plaintiff furnishes Kellen with it more often than I, as per his own text message to me (See Exhibit Text Message). 

The Plaintiff and I discussed the possibility of leaving New York when the covid outbreak started in order to keep Kellen safe and reduce our chance of contracting the virus. The plaintiff stated that he would take Kellen whether I went or not and so I had no choice but to agree. However, going to Vermont on March 16, 2020, and being isolated there without access to a car, no working phone, not one grocery store in walking distance that sold food (even though the Plaintiff said there was) and an intermittent WIFI signal, compounded further my already dire living situation with the Plaintiff. All the while the Plaintiff was looking at potential properties in the locality. He worsened by telling me not to eat any of the food that he purchased, was now essentially keeping Kellen and me hostage by way of not allowing us to return to New York after the first month and involved me contacting my lawyer to ask for help. 

Kellen is now demonstrating aggressive tendencies and is lashing out at me and others. The Plaintiff has taught Kellen to run and hit in ‘play fighting’ to apparently mitigate bullies, however as a three-year-old he is now using these tactics to release some pent-up angst and aggression to those around him.

The Plaintiff intended on taking this position in San Francisco and took the opportunity to work with a previous client he admired. The Plaintiff knew that in order to receive his three-year KAD (Key Account Director) bonus payout, he needed to stay with Oracle for another year so the opportunity in San Francisco was ideal. None of this aspect of the move and new role was discussed with me. I feel that he abandoned me as a new mother, but notably our child, for money and advancing career prospects. The Plaintiff filed for divorce to stifle, discombobulate me and sabotage my immigration status in order to coerce me into lifting the order of protection and threaten me with him gaining full custody of our child.

I ask that you deny this order that has been submitted to the court on the basis that much of what the Plaintiff claims is either unfounded or are behaviors he himself is displaying. Additionally, I do not want this order to be used as a legal cudgel, through which to abuse me further, should there be issues with respect to the Plaintiff’s parenting in the future. Besides, much of what the Plaintiff states that I do are genuine mistakes or had misgivings. They tend to emerge as the Plaintiff claiming that they are the norm. It is an impossible situation and something that our child also has had to navigate. It is my contention that this motion could have been avoided had the Plaintiff been willing to find a more amicable and fair solution to us living separately, especially given his extensive earnings to date. 

Frankly, given even the most experienced Parent Coordinator, I do not foresee that I will be in any way able to coparent, legally or otherwise with the Plaintiff, given his deep oppositional stance on all that I wish and hope for Kellen. Accordingly, I have made considerable efforts to move forward from this marriage, gain employment and independence secured a new home for Kellen and me (See Exhibit New Home). Besides, some of our possessions are already in place for ease of transition and to lessen any confusion for Kellen. Therefore, I ask that I be allowed to leave with Kellen in the day or two following this hearing so that he can experience his new normal with his mother. 

I ask that I be granted sole legal and physical custody, with the Plaintiff allowed visitation. I also ask that visitation for the Plaintiff to include alternate weekends commencing Friday pm to Sunday pm, with one midweek dinner every week. Given the disparity in economic standing, I ask that that the child support payment of $1,500 as wells the lump sum payment offer of $10,000 be increased to $3,000 and $20,000 respectively, in order to cover the many costs in setting up a new residence (See Exhibit Budget), the cost of child-care when needed, as well as any incidentals that need to be covered before accumulating my own savings and surplus monies. I ask that the Plaintiff use Soberlink for at least six months. I ask that I be granted the right to choose the School of Good Hope for Kellen’s year of Pre-K. I also request that the Plaintiff sign the removal of his 50% ownership in my LLC.

It is vital that our child learns to interact with children his own age, to learn new skills and enjoy playing with his peers. He has been offered a free Summer Program in the school which is located halfway between our properties. This school also can provide PreK education from September; however the Plaintiff has denied the application for this school despite its exemplary reviews.



Lisa Roelants

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