1. Ann Wright lies. Her consistent pattern from October 11, 1994, forward has been to lie at every opportunity, as a means of gaining advantage in this divorce. The attached Exhibits A and B document this pattern of deceit going back two years. Exhibit A is a letter to Dr. Marlene Joy, our custody evaluator, documenting a series of lies Ann had told to her. Exhibit B is a document I prepared in January of 1996 documenting lies Ann had told to me, to Dr. Joy and in court filings. In the affidavits and court filings submitted since the divorce trial on March 28, 1995, Ann has continued and enlarged upon this pattern of deception, to the point that her lies are brazen and completely incredible. Ann is desperate to deprive me of contact with both of my children by any means possible, and she has quite literally destroyed her character while abusing the judicial system.

2. So as not to seem to be exaggerating, take note of this nested lie:

In her affidavit dated September 23, 1996, Ann says with respect to my World Wide Web page:

Greg also responded in writing to Dr. Joy regarding my concerns by letting her know that "I have said nothing that is not completely undisputed, non-controversial and known in detail to both children. [....] Someday, my children may read what I have written, and, frankly, I hope they do."

If they do, they will learn about a style of mind I admire intensely, and, in the essays about them in particular, they will revisit a history that I surmise is right now being steadily erased. Cameron at four and Thumper are intended in due course to lend them a cache of splendor when they may need it most. I hope my children will be with me when they are teenagers. But if they are not, I have already established the means by which I will be with them.

3. As an example of the deceptive misuse of ellipses, in the same affidavit, Ann quotes me as saying:

You forbade Meredith access to the ultimate playground of the mind (the Internet) until you could censor her access to information. [....] This would have flow-control advantages, resulting in both direct power and the ability to spin information in any desired way, since there is no possibility of independent verification. In any case, this must stop with respect to Meredith (and with respect to Cameron when he is in Seattle).

At the skating rink you falsely accused me of telling Meredith the truth about her psychological fatherhood, then vowed that if I ever did tell her that truth, I would never see her again. The vow itself is consistent with the actions you've taken in court and by moving away, but the issue I want to discuss is information control. Threatening punishment for speech is the root of the censorious impulse. You could argue that you felt that your accusation was an extreme case, but the fact is that since then you have asked me to forbid Ken Hooper from sending mail to my daughter, when he has never sent mail to my daughter, and when the mail of his that I sent to Meredith was about nothing but math. You forbade Meredith access to the ultimate playground of the mind until you could censor her access to information. I don't know why you do this stuff, and there's a lot more of it--the attempt to have me jailed for a web page you've never even seen, the outrage that I've spoken to Christy Hedges, etc. I have an inkling that you're trying to isolate the people in your life so that no one of them may have a separate relationship with any other. This would have flow-control advantages, resulting in both direct power and the ability to spin information in any desired way, since there is no possibility of independent verification.

In any case, this must stop with respect to Meredith (and with respect to Cameron when he is in Seattle). First, I am responsible for my actions. Obviously, I am going to protect the children from the gruesome details of our divorce, and I think I've done a good job of that so far. Any other details of my life and our relationships with my family and my friends--such as Ken Hooper or Judy Sawyer--are not your concern. I have never behaved irresponsibly as a parent, but, even if I had, this would not justify forbidding the children the full use of their own minds. Second, my relationship with my children is not secondary to yours nor dependent on it. We have a right to the privacy of our intimacy irrespective of how important you might think it to be to violate that right. In expression of this second point, I must insist that the children's mail, email and phone calls will not be monitored by you or Steve.

I don't know why you do this stuff, and there's a lot more of it--the attempt to have me jailed for a web page you've never even seen, the outrage that I've spoken to Christy Hedges, etc. I have an inkling that you're trying to isolate the people in your life so that no one of them may have a separate relationship with any other.

5. With respect to the above, Cameron's teacher, Denyse Norby, never mentioned to me any scheduled cooking example which Ann was to present, but she has asked me to prevail upon Ann not to disrupt school by remaining in Cameron's classroom for hours on end.

6. With respect to Items 8 through 13 in that affidavit, truth is the defense against a charge of libel. There is nothing untrue on my web page, and no one has ever argued to the contrary. Ann quotes words she regards as inflammatory, but she does not dispute their veracity. The quotation from Dr. Joy is deceptive, as one might guess. Ann's version reads:

that both parents refrain from making disparaging remarks about the other parent/step-parent....

THAT each parent refrain from making disparaging remarks about the other parent/step-parent or arguing with each other in front of Cameron.

7. With respect to Item 14, Ann claims that I am frantically busy yet she volunteers to place Meredith with me for 25% of her time. Moreover, even though Ann claims that I have no time for my children, she complains in Item 7 that I took my son to the zoo on a Friday morning. The facts are these: I work very hard, but my work is structured in such a way that I am always available for my children. Over half my billing is done in the pre-dawn hours, while Cameron is asleep. If I am especially busy, I continue working after he has gone to sleep; I am preparing this document at 10 pm. The billing I do during the day is discretionary and low-pressure. Moreover, Cameron is in school from 8 am to 3 pm. I spend time at Cameron's school, both morning and afternoon, every day. My bicycle is modified with a tandem-like attachment so that Cameron and I can ride together. We either ride the bike or go swimming together--or both--every day. I have a child seat on my bicycle, also, so both children can ride when Meredith is here. I think it is beyond contest that a man who is willing to haul an extra 90--wriggling--pounds is a dedicated father.

The claims in Item 14 are gross and obscene. Meredith had a bike with training wheels that went with her to Seattle when Ann moved her away. This Summer, I bought Meredith another bike, this one without training wheels. In the 17 days she was here this Summer, I worked with her three times a day to learn to ride that bike. At the end of that time, she was on the threshold of proficiency, and Ann promised me that the training wheels would come off the old bike immediately, so that Meredith wouldn't lose any ground. More than a week later, the training wheels were still on the bike, and Meredith rode on her bike precisely once from August 29 to October 4, 1996. Ann is so busy posturing as a good mother and defaming me as a bad father that she can't devote 15 minutes a day to her daughter's health and independence.

Cameron attends a full-time Montessori school--for which Ann contributes not one cent of tuition. He plays with his friends every day. Cameron's best friend, Jasmine Baker, is frequently in our home when Ann phones here; Cameron and Jasmine are depicted in fiction in Exhibit G. We have been members of the Phoenix Zoo for three years and we visit the zoo every other weekend. We hike in the desert every other weekend. The children and I have toured Arizona fairly thoroughly--Globe, Payson, Flagstaff, Jerome, Prescott, Sedona, Wickenburg, Gila Bend, Tucson and Tombstone, among others. We visit museums, attend street fairs, scout out playgrounds and attend sporting events. I have a huge, colorful kite in the trunk of my car at all times, just in case there's wind for it. The simple fact is that I am by all measures an ideal father, and this is why Ann goes to such enormous lengths to defame me.

8. In Item 15 Ann tells a new set of financial lies to contradict her two earlier sets of self-contradicting financial lies. It turns out that Ann has enough money to do anything on the face of the earth except live where her son lives. Similarly, she has time enough to do anything in the world with the children except take the training wheels off Meredith's bike and help her to ride it.

9. Item 16 is also deceptive. Cameron did not become "distressed that Meri was leaving", he became distressed that he couldn't go with us. Cameron loves his mother, but he does not relish visitation with her. Visits are preceded by bad behavior, from a pout to a tantrum, and he is always glad to return. Ann has learned not to come to my house in the middle of a visit, because Cameron won't want to go away with her. On September 19, I was presented with the awful chore of selling Cameron on remaining with his mother when he wanted to come with me, with or without Meredith. Ann misquotes me, hardly a surprise, but it doesn't matter. The essence of the matter was that I was candy-coating the bitter pill of visitation for a little boy who had to swallow it, like it or not. Thus, Ann is complaining that I rose to the defense of her legal rights against Cameron's will and my better judgment. As with everything else in this affidavit, Ann complains that I have done the right thing.

10. With respect to Item 17, I have refused to engage Ann except on paper because this is the only way I have even the chance of defending myself from her consistent pattern of lies. The wisdom of this policy is surely demonstrated here and in Exhibits A and B. As to Cameron's health insurance, he has been insured by Golden Rule for nearly three years. Ann knows this, since she arranged for the policy. Ann pays not one cent of child support. She contributes nothing toward Cameron's $480 per month tuition. She pays none of his expenses, purchases none of his clothing, pays nothing toward his health insurance, absorbs none of his uninsured medical expenses and contributes nothing toward our outstanding community debts. She has not so much as subscribed to a magazine to be delivered to Cameron's home in his name. She offers me not her money, not even her husband's money, but the largesse of the phenomenally generous Microsoft Corporation. Arguably this is something, although it would have little if any effect on my health insurance premium. But as I say in the matter she omits to quote, "I do not accept things I have not earned".

Ann quotes me as saying:

I will not avail myself of any insurance you have arranged.

7.c. I will not avail myself of any insurance you have arranged. I am willing to permit it while Cameron is there, simply to cut down on the crosstalk. But I do not accept things I have not earned. In an case, I do continue to require you to inform me in advance of any medical or dental treatment Cameron is to receive in Washington. Also as a matter of policy, I explicitly forbid any appointments with psychologists, psychiatrists, priests/ministers/rabbis/etc. or any other sort of psychological or spiritual counselors. If you feel that Cameron requires any of these sorts of services, and if you wish to be present, I will arrange for them in Arizona on dates when you are scheduled to be here and we will attend them together. I don't mean to be offensive, and I am sure my caution is perfectly understandable, give our history.

11. Ann's September 11, 1995, affidavit is similarly mendacious. In Item 3, she aggrandizes herself for not inhibiting contacts when, in fact, she has consistently presented obstacles to contact. I saw Meredith almost as much as I was scheduled to because I erected a barrier of obstinance, reinforced weekly, that Ann dared not cross; Ann's attorney attests to this on lines 2 and 3 of page 18 of the trial transcript. I had and continue to have enormous difficulties getting Ann to permit the children to talk to me on the telephone, and Ann has refused to schedule a regular time for me to talk to Meredith. Ann is consistently late in delivering the children, and, since her move to Washington, has scheduled Meredith's returns to Washington at ludicrously early hours of the morning. All of this is trivial except as it demonstrates a consistent pattern of frustrating contact by petty means.

12. Also in Item 3, Ann speaks of Cameron having developed a "chronic health problem". What she doesn't say is that this problem--fecal matter retention--manifests itself only in her home. Simply put, Cameron resists moving his bowels in his mother's company. When he returns from visitation, his bowel movements are inordinately large and frequent, and he takes several days to return to his normal schedule. One can speculate endlessly about the causes of this phenomenon: as will be discussed below, Ann is inappropriately intrusive with both children, and this could be Cameron's way of enforcing his sovereignty; as the sheer volume of legal filings makes plain, Ann is obsessed with this divorce, and her internal disquiet could be spilling over onto Cameron; or, more simply, he could simply be uncomfortable in his mother's presence.

13. In Item 6 of that affidavit, Ann quotes Meredith as allegedly having said, "Why did the judge decide that Cameron and I shouldn't live together? Doesn't he know that that's the worst thing you could do to a kid?" If this incident actually happened, Ann had the opportunity to tell Meredith the truth, that Judge Dairman did not decide that Meredith and Cameron should live apart, Ann did. Ann robbed Meredith of her actual psychological father as a means, she planned, of coercing Dr. Joy and Judge Dairman into giving her custody of Cameron. The children were effectively split on May 10, 1995, when Judge Barry Schneider denied my paternal rights to my daughter--without my having the opportunity to say a thing about it--and conferred them upon Steve Wright, essentially a stranger to Meredith. Ann told Dr. Joy in the Summer of 1995 that she would split the children if necessary, and she refused to say she wouldn't in Judge Dairman's courtroom on March 28, 1996. Ann split these children, and in order to lie to the court in Item 6, she portrays herself lying to Meredith by omitting to tell the truth when that was called for.

14. In Item 7, Ann claims that she devised the schedule that Dr. Joy has recommended and, to my understanding, the court has ordered. This is untrue. The schedule was developed by Dr. Joy in consultation with Ann and I, and it is vastly different from the proposals Ann and I had developed in advance of our meeting. It bears noting, however, that I voluntarily assented to an access schedule that is far in excess of Maricopa County guidelines for out of state access. So very far from seeking to frustrate contact between Ann and Cameron, I have voluntarily agreed to have Cameron spend 25% of his time with his mother. As discussed above, I have been scrupulous in observing this schedule.

15. The bulk of Item 8 is simply hysterical. For example, the school asked me if I would consent to coming for the parent-teacher conference at the same time as Ann, so as to conserve appointment slots. Ann objected to this, so we had to use two separate appointments. Contrary to the claim I did not "expand" visitation, on April 1, 1996, I told Ann that I was doubling her Wednesday time with Cameron and extending her weekend time by more than 10%. I did this unilaterally, without having to be asked, and I did it at a time when Meredith was being entirely withheld from me. Ann goes on to claim that I have withheld Cameron by not putting him with her when he is scheduled to be with me. This is true. By contrast, Ann has consistently withheld the children in time they were scheduled to be with me. The amounts of time involved are trivial in the light of actual frustrations of contact, but the fact remains that I have held to the letter and the spirit of our agreement, while Ann has consistently violated both. The text "Greg did pick up the children" is amusing. Ann forbade me to meet my children at the airport and only called me to ask me to pick them up when her planned transportation fell through and they were already more than an hour late. The point of all this is obvious: Ann has no basis at all for claiming that I have frustrated or impeded contact. I am completely in compliance with our court-mandated agreement, and there are sanctions built into that agreement should I fail to comply with it. Ann is herself technically in violation of it, but it had not occurred to me to generate hundreds pages of legal filings over merely technical violations.

16. Also with respect to Item 8, the television is turned off when Ann phones. Cameron frequently does not want to talk to his mother, a consequence she promotes by promising--although often failing--to phone daily. I make him turn off the TV or computer and I lean all over him to talk to his mother, which puts me in a role I don't relish. Ann cites her phone call on the night of the Superman movie, but she doesn't mention that she called more than a dozen times in less than an hour. She attributes a motive to Cameron's subsequent tantrum, a tantrum that actually resulted from his being up past his bedtime. The worst of all of this is that I had called her in advance and specifically asked her to phone early that night, so she would not interrupt Cameron. Instead she practiced the kind of telephone harassment that has characterized her behavior in this divorce. My mistake was making Cameron follow through on his promise to call her back when he needed to get to bed.

17. It is my belief that Ann is psychologically violating both of these children. In her eyes this may be a manifestation of love, but it looks to me like an expression of fanatical need that is, at a minimum, an obligation that no child can or should be expected to bear, and, at worst, a consistent pattern of intrusiveness. As discussed above, Ann seeks to censor everyone with whom she comes into contact. It is obvious that Meredith's phone calls to me are monitored, with the result that Meredith murmurs almost unintelligibly. As discussed in Exhibits H and I, Ann (and possibly Steve Wright) seem to be trying to maneuver both children into upholding the vision of their new family they seek to present to the world. These are subtle things, but they are subtly destructive of the confidence and independence of two very remarkable children. There are worse fates, I'm sure, than growing up with a woman who entreats you to repeat to her her meaningless lies as a means of buttressing her own belief in them. But there are better fates, too. To move Cameron from the better to the worse seems to me to be the very opposite of justice.

18. I don't like trafficking in trivia, but I have feared throughout this divorce that, by not matching Ann spitball-for-spitball, I risk having the spitballs stick to me. This is absurd and insane and degrading, but the fact remains that Ann has asked both the Court of Appeals and the Superior Court to take Cameron away from me when I have never been afforded the opportunity to speak in my own behalf. I have been asked one hostile question in 21 months of proceedings. The last time I answered a friendly question was February 14, 1995. It's conceivable--though improbable--that my son could be taken from me just as my daughter was, without my having any chance to defend either him or myself.

So: first, Cameron is far better off with me than he would be with his mother. He loves living with me, and he is prospering as he had not done during the pendency of the Temporary Orders. It is tragic that Ann has split him from his sister, but this is a rend that cannot now be mended, and Meredith is clearly doing worse now than she was during the Temporary Orders, which span of time in turn was worse than the time before Ann abducted the children. Cameron is doing better than he was before the divorce, Meredith is doing worse, and to put Cameron with Ann cannot possibly be regarded as being in his best interest.

Second, the children have blurted out a great deal of information about how Ann runs her home, none of which was surprising to me. I have never pumped them for information, nor have I zealously recorded such as they have inadvertently imparted. But I noted it with some amusement, in light of all the absurd charges Ann has made against me. Ann is lazy and slovenly, so it was no surprise to me when Meredith reported that she frequently wears dirty clothes at her mother's house. One of her key complaints about life in my home is that I require her to bathe daily. She reported to me that, on a weekend trip with Steve Wright, they drank "tons" of Dr. Pepper and never brushed their teeth. I could go on forever.

What's interesting about this is that it is not interesting. It is trivial. I don't like Ann, and I think she is far worse as a parent than she was when she was living up to my standards--or pretending to. But as disquieting as these trivial details might be to me, they are not reasons to deny Ann visitation with Cameron. In exactly the same respect, even if Ann's ludicrous claims were true--and I have demonstrated that they are not--this would not be a reason to remove Cameron from his father, his home, his school, his friends and his total environment and send him off--"immediately"--to live in Seattle. Ann is harping hysterically about invented trivia because she has nothing of importance to complain about.

19. Ann abandoned Cameron. She said she would and she did. It is a manifestation of the lingering gender bias in our culture that we are shocked that a woman would do what men do all the time--move away on their children. Steve Wright did this with his real daughter, Amelia, and we don't give it a second thought. But when men move away on their children, they don't usually have the gall to expect to take the children with them. Ann seeks to invert the gender bias, to say that because she is a woman, she should be afforded a privilege that would be denied to any man, to move away and take the children. As a matter of general policy, this would have awful consequences in a culture that is already being destroyed by an epidemic of fatherlessness. In this particular circumstance, it would be hideously unjust. Cameron would be robbed of his father. I would be robbed of both of my children. And Ann would be robbed of the opportunity--perhaps her last opportunity--to discover that she cannot lie her way to goodness.

20. Since many of Ann claims in her Proposed Findings of Fact depend on material shown here to be either entirely false or egregiously misrepresented, it is demonstrated that the Proposed Findings of Fact is itself largely mendacious.