Ray Casares
American Tradesmen LLC
American Tradesmen Publishing
Ray Casares (Owner)
JIW Local 1 Chicago #1366886
708-954-7920
Date: __________
[ENTER NAME]
[ENTER ADDRESS]
RE: VIOLATIONS OF THE INDIANA PARENTING GUIDELINES
Respectfully,
Complainant avers that the Respondent severally violated the Indiana Parenting Guidelines in the
following manner:
December 11, 2021
Angelica informed Ray of her intention to have Camila’s and Alessa’s ears pierced. Ray opposed
Angelica’s decision upon which Angelica refused to address the issue again. Angelica proceeded
to have the girls’ ears pierced. This was contrary to paragraph 7 of the Court Order, which
required the parties to maintain healthy communication on all issues. Further, Section 1(A) of the
Indiana Parenting Time Guidelines, 2022, provides in pertinent part that “[a]ll communications
concerning a child shall be conducted between the parents.” It was Ray’s assertion that at least,
they should have discussed about the matter first. Ray also asserted that Camila must have first
known how to clean herself better and wait for gold earrings. As a result of Angelica’s action,
Camila got an infection on both of her ears.
January 3, 2022
Angelica expressed her intention to claim one of the children as dependent on her tax return.
This was contrary to the Court Order that expressly stated that Ray claims the children since
Angelica does not help with school. Paragraph 15 of the Court Order expressly states that the
father shall be entitled to claim the minor children as dependents every year for tax purposes. At
no time was this provision modified by the Court.
The children also informed Ray that Angelica wanted them to watch her have a baby. This is
contrary to Part A(7) of the Indiana Parenting Time Guidelines which provides that a child’s
basic needs which need to be protected include the need “[t]o be physically safe and adequately
supervised when in the care of each parent and to have a stable, consistent and responsible child
care arrangement when not supervised by a parent.” When Ray tried to discuss the foregoing
with Angelica, she started attacking Ray and alleging that Ray has an Opioid addiction, which
makes him an unfavorable parent for the children. Angelica further alleged that Ray is only
jealous towards her because she is young and Ray can no longer have children. Accordingly, Ray
suggested the parties go through mediation. It is averment that the children should not watch
Angelica giving birth since it may scare them if anything goes wrong. Besides, it is in the
children’s best interests, to have them first learn about having a family, getting married, then
having children.
February 28, 2022
The children’s school sent a letter stating that eleven times, Angelica has been picking the
children from school outside the school hours, which was late. The school further stated that it
reminded Angelica of the required time, but Angelica still picked the children late. As a result,
the school charged a late pick up fee amounting to $175.
When Ray raised the issue with Angelica, she denied and alleged that she had never been late so
many times. She further alleged that she had only been late once.
Accordingly, Ray offered to pick up the girls daily at 3:30pm since he gets off work at 3pm.
Therefore, there is no need for the children to wait for Angelica until 6pm. This also made the
children very tired since they are dropped off at 7am. However, Angelica still, against the best
interests of the children, denied Ray’s request.
March 1, 2022
Ray made several attempts to have Angelina submit to mediation and telehealth, so that the
glaring issues should be addressed amicably. This was despite Dorian, from New Vista, severally
expressing her availability to meet the parties for mediation. However, Angelina brushed off
Ray’s concern and averred that she could schedule when the parties could attend mediation,
when there are actual issues in dispute affecting the girls. Besides, when the parties agreed to a
meeting schedule, Angelica cancelled the meetings. Angelica’s actions were in breach of Section
1(E) of Indiana Parenting Time Guidelines 2022, which provides that “[w]hen a disagreement
occurs regarding parenting time and the requirements of these Guidelines, both parents shall
make every effort to discuss options, including mediation, in an attempt to resolve the dispute
before going to court” (emphasis added).
May 8, 2022
Angelica insisted on keeping the children overnight contrary to the guidelines. When Ray
requested to get the girls at 6pm, Angelica responded that she had plans. Ray went further to
inform her that the children wanted him to pick them up at 3:30pm upon which Angelica argued
that children lack as sense of time.
Angelica further stated that she would no longer work with Ray, and that it was “non-
negotiable”. She alleged that Ray was foolish and that it was the last time she gave up her time
for the children to be with him. She went further to state that she would never give up her time
for the children to attend any function with Ray, whether it is a family function, or a kid’s party.
Ray ended up filing a police report.
The foregoing Angelica’s conduct was in violation of both the Court Order and the Indiana
Parenting Time Guidelines. Notably, paragraph 4 of the Court Order admonished Angelica from
such behavior, which was contrary to the best interests of the minor children. Further, paragraph
7 of the Order expressed the court’s hope that the parties maintained a healthy communication on
all issues regarding the best interests of the children. Paragraph 10 also directed the parties to
apply the guidelines of the Indiana Parenting Time Guidelines.
Section 1(C) of the Indiana Parenting Time Guidelines provides in pertinent part that:
Parents should recognize there will be occasions when modification of the
existing parenting schedule will be necessary. Parents should exercise
reasonable judgment in their dealings with each other and with their child.
Parents should be flexible in scheduling parenting time and should consider the
benefits to the child of frequent, meaningful and regular contact with each
parent and the schedules of the child and each parent (emphasis added).
The said provision further states regarding make-up time that: “[w]henever there is a need to
adjust the established parenting schedules because of events outside the normal family routine or
the control of the parent requiring the adjustment, the parent who becomes aware of the
circumstance shall notify the other parent as far in advance as possible.”
May 9, 2022
Angelica remained adamant and denied Ray’s request to pick the children.
June 1, 2022
Ray picked the children from school at 3pm since they had to attend graduation, which Ray
wished they did not miss. Ray had promised, and intended to return the children by 6pm.
However, when Angelica heard that Ray had picked the children, she protested and alleged that
it does not matter whether the children had a graduation, or not, she was entitled to pick them
that day. The Court Order, in paragraph 10, stated that the Indiana Parenting Time Guidelines
should operate in interpreting all parenting time and actions. Section 1(C) of the Indiana
Parenting Time Guidelines 2022 provides in pertinent part that:
Parents should recognize there will be occasions when modification of the
existing parenting schedule will be necessary. Parents should exercise
reasonable judgment in their dealings with each other and with their child.
Parents should be flexible in scheduling parenting time and should consider
the benefits to the child of frequent, meaningful and regular contact with each
parent and the schedules of the child and each parent (emphasis added).
July 22, 2022
The children informed Ray that they sometimes had sleep overs at Angelica’s boyfriend’s house.
Upon further probing, Ray was informed that they (the children) sometimes slept on the sofa or
with Leo in bed. Leo is Angelica’s boyfriend’s ten-year old son. This was against the CPS
guidelines that requires no more than two children to share a bedroom and that each child must
have separate bed with clean beddings. Further, children of opposite genders, who are above the
age of five, must not share a bedroom. Ray raised this pertinent concern with Angelica and
requested mediation on the same. However, Angelica denied mediation. Angelica alleged that
Ray was only jealous that she had found someone better than him. She further accused Ray of
stalking her boyfriend on social media, yet Ray only wanted to have the best interests of the
children protected.
I am looking forward to your consideration of this matter,
Sincerely,
_____________
Ray Casares
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