People involved in this case for various reasons

Judith Moss, BS; MA

Program Director

CASA of the 36th Judicial Circuit

644 Charles Street

Poplar Bluff, MO 63901

Tele: 573-776-7830 ext. 13

Fax: 573-776-6130

E-mail: casa36@thecrc.org

Angelina Champion (CASA of the 36th Judicial Circuit) filed report on July 24, 2017 in Juvenile court

*Blue links are hot linked to a document

Court order from July 24, 2017 says girls should visit with Charles Haynes and Bernice Haynes - but someone made a clerical error when preparing the court order - the court order should have stated as “therapeutically recommended” - this per Roxann Ward and Theresa Wharley Children’s Division case managers for Mikaela and Sara Haynes juvenile cases...who were in the July 24, 2017 behind closed doors negotiations - the GAL Jennifer Williams did not stand up to protect the girls and say no visits until pending criminal case is over - she just let JO Attorney Dean Million rip the counselor (Scott Foster) apart who recommended no visits with Chuck or Bernice Haynes on 7-7-17. See DFS letter here where it references his recommendation.

Children:

1) Mikaela Ann Haynes DOB: August 30, 2004 17RI-JU00011 & 17RI-JU00033 Juvenile criminal case filed by JO Pam Stark and JO Attorney Dean Million who GAL Jennifer Williams declined to represent Mikaela on.

2) Sara Mae Haynes DOB: February 26, 2009 17RI-JU00012

Parents:

Cynthia Haynes, Mother

Charles Haynes, Father (Was arrested on Dec 1, 2013, with pending sexual abuse criminal case 13RI-CR00907- 01). Criminal trial scheduled for the end of May 2018, after having been set off again and again over the past four years.

Chuck is trying his best through the “system” and his multiple lawyers to have the “two good kids” taken away from me if I will not kick Melissa out and stop helping her financially - then he said he believes she will sell out cheap and come begging for me to help her and then he wants me to tell her that if she won’t testify against him - she can move back home. You can see this in the transcript below - about the “two good kids” and taking them away from me if I would not help him get Melissa not to testify against him:

He stated this to me and admitted to molesting Melissa Hogg on May 29, 2014 in a video recording I made of him - Here is a transcript of the two videos and the actual videos:

1) Chuck Admits: transcript here and video here

2) Chuck Threatens: transcript here and video here

Judge Shock refuses an order of protection and even denies a hearing for Melissa Hogg on 12-21-16 here.

Melissa Hogg’s preliminary hearing on April 3, 2014, transcript here.

Melissa Hogg’s Forensic Interview on December 1, 2013, report.

Craig Cory Troop B Highway Patrol report. Incident # 130758453 Mo Highway Patrol troom B (Macon, MO)

Date Officer Craig took pictures off of Melissa's phone: December 19, 2013

Related report # 13336079000

County Code: 001

Defendant: Charles Haynes

Total: 4 compact disks:

1 SD card - copied to 1 disk

2 Disks from Iphone

1 32 gig disk - copied to disk

Picture of Chuck's hand in Melissa's shirt is what we were looking for on Melissa's old phone - that we no longer have ...and Officer Craig said he found it.

Melissa Hogg’s Feb 9, 2017 deposition by Ted Lewinsky here

Divorce case numbers:

1) 13RA-CV01291- I first filed in Randolph County (Moberly, Mo) on 12/10/2013 by Attorney Stephanie Luntsford.

2) 14RI-CV00038 - case was transferred to Ripley County because of clerical error on 01/17/2014 - case was dismissed on 9-22-14 without notice to me at all by Judge Clarkson who is a Uncle by marriage to my two older daughters (and other serious ethical/conflicts here) and started using 13RI-CV00554 that my former attorney filed against me on 12/17/2013 on behalf of Charles M. Haynes.

3) 13RI-CV00554 - Charles filed in Ripley via my own attorney (from 1997-2012) Siegrid Maness on 12/17/2013.

• • Cindy Haynes attorney:

  • James M. McClellan

  • 820 N Main St # A, Sikeston, MO 63801

  • Phone: (573) 471-8300

  • Email: jmm-law@swbell.net

  • Josh Rideout, Legal Assistant for my old attorney Jasper Edmundson who is a habitual drunk and on prescription pain meds so bad he cannot function as an attorney, but still practicing law. Josh Rideout knows a lot of facts about my case that no one else does because of his position.

  • 1980 State St, Poplar Bluff, MO 63901

  • Office: (573) 785-6416

  • Cell: (573) 579-0573

  • Stephanie Luntsford, 1st Attorney for Cindy Haynes case # 13RA-CV01291 filed Dec 10, 2013, now a prosecutor in Moberly, MO. She stated in a Jan 03, 2014 filing that:

• • Email: luntsfordlaw@hotmail.com

  • Cindy Haynes contact info:

  • RR 3 Box 7833

  • Doniphan, MO 63935-8773

  • 573-996-6401 cell

  • Email: weddingpartyprocession@gmail.com

  • Charles Michael Haynes contact info

  • RR 1 Box 2312

  • Doniphan, MO 63935

  • 573-996-6260 cell

  • Bernice C. Haynes, Intervenor as 90 year old Grandmother in case #13RI-CV00554. Children were removed from her home on or about Feb 3, 2016, after GAL Jennifer R. Williams and Judge John Shock placed them there despite serious safety concerns - see DOCKET MEMORANDUM because of “educational neglect” at December 7, 2016 hearing in Butler County Courthouse.

  • RR 3 Box 7899

  • Doniphan, MO 63935

  • Phone: 573-996-1895

  • Theodore E. Liszewski Charles (Chuck) Michael Haynes criminal attorney:

  • 220 N Main St

  • Sikeston, MO 63801-4212

  • Scott County

  • Phone: (573) 475-9290

  • Fax: (573) 475-9025

  • Theresa Whaley, BSW (our case manager for several years now - 2014-2017)

  • Missouri Children’s Division case manager)

  • Theresa Whaley, BSW

  • Children’s Service Worker IV

  • 36th Judicial Circuit

  • Ripley County

  • RR 2 Box 1143

  • Doniphan, MO 63935

  • Office: (573) 996-2175 ext. 238

  • Cell: (573) 718-2789

  • Fax: (573) 996-2238

  • Morrow, Keri (Children’s Division supervisor for Theresa Whaley, BSW)

  • 1903 Northwood

  • P O Box 8

  • Poplar Bluff MO 63902

  • Phone: (573) 840-9215

  • Cell: (573) 840-9066

  • Fax: (573) 840-9273

  • Roxann Ward

  • Missouri Children’s Division case manager (Chuck’s lawyer and JO Attorney Dean Million did not like Theresa Whaley’s report stating that Chuck & Bernice Haynes should not have contact with Mikaela and Sara - so they DEMANDED a new case manager):

  • RR 2 Box 1143

  • Doniphan, MO 63935

  • Phone: 573-996-2175 Doniphan Office

  • Phone: 573-840-9065 Poplar Bluff Office

  • Fax: 573-996-2238

  • Cell: 573-727-3979

  • Children’s Service Worker IV

  • Ripley County, 36th Judical Circuit

  • Roxann.L.Ward@dss.mo.gov

  • Sara Dickson CD Investigator

  • RR 2 Box 1143

  • Doniphan, MO 63935

  • Phone: 573-996-2175 Doniphan Office

  • Phone: 573-840-9065 Poplar Bluff Office

  • Fax: 573-996-2238

  • Cell: 573-

  • Children’s Service Worker IV

  • Ripley County, 36th Judical Circuit

  • Pamela Ray Stark

  • Deputy Juvenile Officer

  • 36th Judicial Circuit - Juvenile Division

  • Butler-Ripley Counties

  • 100 Court Square

  • Doniphan, Missouri 63935

  • Phone: (573) 996-4015

  • Fax: (573) 996-4562

  • E-mail: pamela.stark@courts.mo.gov

  • Timothy Fleener Mikaela’s public defender obtained after JO Pam Stark/Atty Dean Million filed criminal charges on Mikaela after GAL Williams forced Mikaela to go to public school where she was accused of contraband possession (12 year old daughter Mikaela A. Haynes Case No. 17RI-JU00033)

  • Attorney for Mikaela Ann Haynes

  • 948 Lester Street

  • Poplar Bluff, MO 63901

  • Phone: 573-840-9775

  • Fax: 573-840-9773

  • Email: timothy.fleener@mspd.mo.gov

  • Dean Million Attorney for Juvenile Office (and attorney for Paul E. Hogg who disinherited Mindy and Melissa Hogg and their father from millions of dollars - serious ethical and conflict of interest)

  • 2408 Crestwood Dr, Poplar Bluff, MO 63901

  • Phone: (573) 785-6419

  • Judith Moss, BS; MA (I completed a parenting class taught by Judith Moss and she is also Angelina Champion CASA volunteer’s boss) (she is a huge liberal and Hillary Clinton fan learned this from her parenting class) Program Director

  • CASA of the 36th Judicial Circuit

  • 644 Charles Street

  • Poplar Bluff, MO 63901

  • Tele: 573-776-7830 ext. 13

  • Fax: 573-776-6130

  • E-mail: casa36@thecrc.org

  • Angelina Champion, CASA volunteer for court on July 24, 2017 (see report I gave you)

  • CASA of the 36th Judicial Circuit

  • 644 Charles Street

  • Poplar Bluff, MO 63901

  • Tele: 573-776-7830 ext. 13

  • Fax: 573-776-6130

  • Cell: 573-225-6053

  • Melissa Hammond PA (Parent Aid) She has credentials to be a DFS case manager in another state but recently moved to Missouri and has not received the Mo License yet)

  • The Counseling Office (Counselor Sara Craig is her boss and my current counselor)

  • The Counseling Office

  • 97 Washington St, Doniphan, MO 63935

  • Office: (573) 996-2194

  • Cell: (928) 451-2159

  • Sara Craig, LCSW (Cindy’s new counselor at present, because of all the complaining done by Chuck’s lawyers and buddies on the case for my other counselors. Complaining people: JO Attorney Dean Million, Atty Siegrid Maness, GAL Williams, JO Pam Stark)

  • The Counseling Office

  • 97 Washington St, Doniphan, MO 63935

  • Office: (573) 996-2194

  • Cell: 573-707-3231

  • Loretta Fuge, Psy.D. (Psychological Evaluation of Mikaela on 8-16-17)

  • Mo. Licensed Psychologist

  • 827 Commercial Street

  • P. O. Box 47

  • Mansfield, MO

  • PH 417-924-8188

  • Fax 417-924-8190

  • Email: drfuge@go-rp.com

  • Web: www.go-rp.com

  • Dr. Roger Kingsley Bost (girls Pediatrician since they were babies)

  • Saint Francis Medical Partners

  • Kneibert Clinic

  • 686 Lester Street

  • Poplar Bluff, MO 63901

  • Phone: 573-686-2411

  • Fax: 573-778-7279

  • Cindy Moses, LCSW (our counselor for years)

  • LIVING BETTER BEHAVIORAL HEALTH, LLC

  • 502 Vine Street

  • POPLAR BLUFF, MO 63901

  • PH: (573) 785-5224

  • Cell: (573) 429-1743

  • Fax: (573) 686-6767

  • Chuck’s attorney Ted Liszewski's motion to get rid of Cindy Moses as a counselor for Mikaela and Sara (family counseling and for Melissa as well) (one they really liked and we all had a long relationship with).

  • Scott Foster, LCSW and? Mikaela & Sara and Cindy Haynes former counselor

  • The Counseling Office

  • 97 Washington St, Doniphan, MO 63935

  • Office: (573) 996-2194

  • Siegrid Maness, Attorney for Charles and now Bernice

  • 118 Washington St, the Maness Bldg., Doniphan, MO 63935

  • Phone: (573) 996-3814

  • Cell: (573) 660-0403

  • My letter to my former attorney’s Randy and Siegrid Maness (Click blue link to see document)- have not mailed it yet. These two attorney’s especially Siegrid Maness is working hard to get Chuck acquitted - however and whoever it hurts in the process they do not care in the least.

  • Matt Maness (Randy & Siegrid Maness’s SON who was the intake and case manager at http://www.ofra.org for the forensic interview done by Christi Patterson on Melissa Hogg on December 1, 2013. Siegrid and Randy Maness should not be involved with this case - just because of their son being on the Forensic interview case as contact person for us and who was in charge of the forensic interview process.

  • Ozark Family Resource Agency

  • P.O. Box 856

  • 204 Summit Street

  • Doniphan, MO 63935

  • Office: 573.996.2648

  • Fax: 573.996.2649

  • Crisis Hotline: 1.800.681.1419

  • Email: ofra@ofra.org

  • GAL Jennifer R. Williams

  • Spain, Miller, Galloway & Lee, LLC

  • 1912 Big Bend Rd

  • Phone: (573) 686-5868

  • Cell: (573) 718-3995

  • My letter to GAL Williams on July 6, 2017

  • John and Cassie Rideout, Foster Parents (Feb 3, 2017 to July 24, 2017)

  • Mikaela was hospitalized once while in their care at Twin Rivers Medical Center (seen by Dr. Roger Bost her Pediatrician at Twin Rivers Medical Center in Kennett Mo) for superficial cutting again - because she wanted to be back home so bad - because of GAL Jennifer Williams false allegation of “educational neglect” removing her from me without any findings of fact or hotlining her “concern” of “educational neglect” as a statutory mandated reporter.

  • RR 61, Box 2400

  • Naylor, MO 63953

  • Home: 573-429-8207

  • Cassie’s cell: 573-429-8320

  • John’s shop: 573-429-6666

  • Dr. Perez (SSM DePaul Hospital)

  • Bridgeton, MO

  • Dr. Roger Kingsley Bost (both girls Pediatrician - Mikaela was happy to see him while she was at Twin Rivers Medical Center, Kennett, MO)

  • Dr. Roger Kingsley Bost (girls Pediatrician since they were babies)

  • Saint Francis Medical Partners

  • Kneibert Clinic

  • 686 Lester Street

  • Poplar Bluff, MO 63901

  • Phone: 573-686-2411

  • Fax: 573-778-7279

    • Letter by Dr. Bost on April 25, 2017

    • Letter by Dr. Bost on July 27, 2017

  • Melissa Koetting, Attorney General’s Victim’s Advocate

  • Missouri Attorney General's Office

  • Supreme Court Building

  • 207 W. High St.

  • P.O. Box 899

  • Jefferson City, MO 65102 Map

  • Phone: 573-751-3321

  • Fax: 573-751-0774

  • Cell: 573-645-2784

  • Office: 573-751-0309

  • Email: melissakoetting@ago.mo.gov

  • Christy Patterson, (did Melissa Hogg’s forensic interview on Sunday afternoon, December 1, 2013 at http://www.ofra.org)

  • Ozark Family Resource Agency

  • P.O. Box 856

  • 204 Summit Street

  • Doniphan, MO 63935

  • Office: 573.996.2648

  • Fax: 573.996.2649

  • Crisis Hotline: 1.800.681.1419

  • Email: ofra@ofra.org

  • SCOTT SERGENT

  • Office of the Attorney General

  • Supreme Court Building

  • P.O. Box 899

  • 207 W. High St

  • Jefferson City, Missouri 65102

  • Phone: 573-751-8868

  • Scott’s work cell phone: 573-821-3616

  • Phone: 573-751-3321

  • Fax: 573-751-0774

  • Scott.sergent@ago.mo.gov

  • Assistant Attorney General assigned to Charles M. Haynes criminal case # 13RI-CR00907-01

  • Assistant Prosecuting Attorney Casey Proctor in Ripley County who is friends with Siegrid Maness and and her husband Randy Maness who first entered on Chuck’s criminal case even though he was not a criminal lawyer and then withdrew after paying Chuck’s bond from his personal funds, and who are also former law partners of Christopher J. Miller the prosecutor in Ripley County, Doniphan, MO where the criminal case is supposed to be tried and this assistant is now assigned to this case with Scott Sergent looking over his shoulder?:

  • Casey Proctor, Ripley County

  • Assistant Prosecutor assigned to case # 13RI-CR00907-01

  • Christopher Miller PA

  • 100 Courthouse Square Suite 8

  • Doniphan, MO 63935

  • Phone: 573-996-2138

  • Fax: 573-996-7762

  • Email: ripleycopa@windstream.net

NOTES:

JO Pam Stark should recuse off of Mikaela's case because of HIPPA violations in Melissa Hogg's case. Perhaps Pam Stark is mad at Mikaela Haynes and filed the criminal charges against her (17RI-JU00033) because of the things that were said by Melissa's friends against her daughter Beth Stark in a twitter account called DTOWNTHOTS - when Beth Stark told Melissa's case details to her friends at the public high school. Melissa's friends got together and made this twitter account to talk about Beth Stark having sex in a church pew and other things like that in retaliation to the things Beth Stark divulged to the Doniphan High School students. Melissa is the one that got called into the Principal's office and was punished by in-school suspension. Melissa took the blame for all of it to protect her friends. Melissa was the only one punished by in-school suspension, because of Pam Starks violation of HIPPA and ethical rules for Juvenile officers.

The Doniphan school allowed Melissa Hogg to be bullied (JO Pam Stark violated HIPPA among other things by sharing the details of Melissa Hogg’s child molestation case with her daughter Beth Stark) and then the Doniphan School punished Melissa for her friends creating a twitter account that talked about Beth Stark - having sex in a church pew - etc.:

Melissa Hogg In-School suspension 5-14-15.pdf

for Pam Stark's Beth Stark bullying Melissa by spreading all the intimate details of her sexual abuse case to the other kids at the Doniphan High school - it even was an uproar at the middle school. Melissa was severely embarrassed and crushed to realize that nearly the whole high school knew about the details of her case.

JO Attorney Dean Million should have recused off of the Juvenile [17RI-JU00011, 17RI-JU00012, 17RI-JU00033] cases as well - because he is the named attorney in a will, a personal representative for Paul E. Hogg that disinherits Melissa Hogg and my eldest daughter from millions of dollars

My own personal Notes about GAL Jennifer Williams infractions with these four cases:

17RI-JU00033 - Juvenile criminal case by JO Pam Stark on Mikaela

17RI-JU00011 Juvenile Mikaela Haynes DOB: 8-30-04

17RI-JU00012 Sara Mae Haynes DOB: February 26, 2009

My Notes about GAL Williams infractions:

Disqualify the Guardian Ad Litem and Appoint an Alternate Guardian Ad Litem in this matter, pursuant to Section 452.423, R.S.Mo., and in support thereof states to the Court as follows:

1. That the Court appointed attorney, Jennifer Williams, as Guardian Ad Litem in the captioned matter on or about May 6, 2016.

2. That Respondent requests the Court disqualify Jennifer Williams as Guardian Ad Litem, as a matter of right and appoint attorney, Cameron Bunting Parker, as Guardian Ad Litem.

3. That attorney, Jennifer Williams, recommended on December 7, 2016 that custody of the parties minor children be awarded to the Intervenor, Bernice Haynes.

4. That GAL Williams claimed there to be “educational neglect” regarding the parties’ minor children and suggested that to be the strong reason in removing the children from the custody of their mother without any factual evidence to support her allegations. GAL Williams, a statutory reporter, failed to hotline her concerns of “educational neglect” due to the lack of any evidence.

5. The Court awarded temporary custody to Intervenor on December 22, 2016 with full knowledge of the proximity of Petitioner to Intervenor. That GAL Williams was fully aware from the December 7, 2016 hearing of Intervenor’s “careless” neglect of court ordered supervision of Petitioner during visitation of minor children (see Judge Shock’s DOCKET MEMORANDUM), yet advocated in favor of Intervenor claiming unfactual “educational neglect” of minor children by Respondent.

6. That on December 7, 2016, twelve year old Mikaela testified under oath as to her wishes and they were completely disregarded by GAL Williams as not in her best interest and well being. See CASA volunteer report for July 24, 2017 hearing here.

7. That Petitioner was ordered to have supervised visitation yet continued to have unsupervised contact with the parties’ minor children, in contempt of this Court’s Order, and with the knowledge of GAL Williams. See Police Reports and notes of calls to GAL Williams that were never returned.

8. That GAL Williams was notified of continued unsupervised contact by Petitioner, being no secret about Petitioner and the allegations of egregious sexual misconduct against the minor children’s minor step-sister, and did nothing to prevent future unsupervised contact.

9. That GAL Williams was notified about Intervenor feeding the minor children aspirin on a daily basis, leading Sara to have chronic nose-bleeds and did nothing to prevent the abusive behavior.

10. That on or about January 29, 2017, Sara, was treated in the emergency room for a dog bite she received at Intervenor’s; the GAL was notified of same and continued to recommend the custody of the parties’ minor children to be with Intervenor, despite knowledge that the dog at Intervenor’s residence had a known history of attacking people.

11. That on or about January 24, 2017, Mikaela, in an effort to break the stalemate of her unwilling custody, attempted suicide using sleeping pills found in her grandmother’s house, which were unsecured, again with the knowledge of GAL Williams.

12. That because of GAL Williams actions to place the minor children with Intervenor in a known vulnerable, at risk, dangerous situation was deliberate, wilful, negligent and indifferent to protecting minor children from direct or facilitated harm by Intervenor.

13. Subsequent hospitalizations of Mikaela, where she has been administered powerful psychotropic medication which GAL Williams has failed to ensure are only administered to Mikaela safely and only when necessary.

14. That if the minor children were not removed from their Natural Mother at GAL Williams recommendation because of “educational neglect” in the December 7, 2016 hearing, (“educational neglect” has been found to be a false claim by two schools, Division of Family services and no hotline was made by GAL Williams regarding her claim), this life-threatening situation for Mikaela would not have occurred at Intervenor’s home.

16. The lack of oversight and coordination of care for Mikaela and Sara by GAL Williams is nothing short of dereliction of her duty to act in the well being and best interest of the children she is representing.

17. That GAL Williams has caused Mikaela and Sara to endure incomprehensible trauma and abuse and GAL Williams failed to ensure Mikaela and Sara were receiving comprehensive therapeutic counseling and mental health support to treat underlying issues while at Intervenor’s home from December 2016 to February 2017. [GAL did not see to it that adequate medical and counseling care for the foster children was provided while the girls were in Bernice Haynes home = Bernice Haynes refused to take the girls to see their regular counselor because Chuck Haynes did not want them to see Cindy Moses and GAL Williams failed to see that the girls had counseling while GAL Williams was forcing the girls to be in Bernice Haynes care and protection who constantly for every single decision called Petitioner to get approval and advice.

18. That on or about February 3, 2017, Respondent (Cindy Haynes) consented to the jurisdiction of the Juvenile Court for placement of the parties’ minor children into protective custody with the State of Missouri at her attorney’s (Jasper Edmundson) advice in an effort to protect her minor children from GAL Williams and Judge John Shock’s devastating actions that have harmed and endangered the minor children by putting them into Bernice Haynes home and care. (See DFS letter here).

19. Thereafter, the investigators with Children’s Division found no “educational neglect” as alleged by GAL Williams.

20. While in the placement of the foster family, Mikaela after being removed from a loving Mother and safe home environment and placed with Intervenor and ensuing trauma, spent approximately 5 days in DePaul Hospital and while taking Remeron, again attempted to harm herself at the Foster Parents home. Mikaela felt her voice did not matter to GAL Williams or Judge Shock (because she had testified under oath on December 7, 2016 that she wanted to be home with her Mother in front of all the attorneys and Judge John Shock) and felt helpless with a long stint in foster care a high probability, and again, GAL Williams failed to protect.

21. That GAL Williams asked for this Court to include records from the prior juvenile cases and this Court approved GAL’s request on February 3, 2017 which were three closed prior case numbers 14RI-JU00015, Melissa Hogg, 14RI-JU00016 Mikaela Haynes and 14RI-JU00015 Sara Haynes. The initial hotline call that brought the minor children into care in the prior case was investigated and deemed unsubstantiated by the Missouri Children’s Division in 2014. Yet the prior juvenile cases were not closed in 2014 when the report was deemed unsubstantiated, but went on and on for over a year. This first Missouri Children’s Division case manager (Ms. Winstead) by gross negligence mixed in another Charles and Cindy Haynes from Doniphan Mo. into these prior juvenile cases. This other couple also from Doniphan had their hotline reports and other information mixed into Respondent's prior juvenile cases which included mixing another Cindy Haynes information with all counseling and psychological evaluation summaries of Respondent for these prior juvenile cases. This was brought to the Missouri Division of Family’s case manager’s attention at the time (Maime Winstead - lots of the items I bought for the girls while they were in foster care which I gave to Maime Winstead to give the girls, never showed up at the Foster home), but no acknowledgement or apology for this gross negligence has been received by Respondent to date which to Respondent is unconscionable to the well being and best interests of Melissa Hogg, Sara Haynes and Mikaela Haynes. This gross negligence on the part of the State of Missouri Children’s Division (Maime Winstead) has intensified the feelings of helplessness of Melissa, Sara and Mikaela and of which I believe was at least one of the factors caused by the unfactual recommendations of “educational neglect” by GAL Williams causing twelve year old Mikaela to self harm again at the Rideout’s foster parents home because she felt there no end in sight in foster care again, with no substantiated report of neglect or abuse against Respondent, for the near future to be reunited with her Mother in the open juvenile cases today. Mikaela was hospitalized for the second time in Twin Rivers Regional Medical Center in Kennett, Mo. GAL Williams has requested the Court to include these convoluted counseling, psychological reports that include and mixes and entangles together another Charles and Cindy Haynes in Doniphan, Mo., and Respondent’s information has now been entangled into current Juvenile case numbers 17RI-JU00012 Sara Mae Haynes and 17RI-JU00011 Mikaela Ann Haynes, per the ruling of Honorable Judge John Shock.

22. Mikaela was then disciplined and suspended at Doniphan public school for allegedly obtaining contraband at school and then taking it back to school, where if she had not been subjected to the public school environment, promoted by GAL Williams, this would not have occurred. Bullying, assault and threats at the Doniphan public school and on the public school bus to Mikaela and Sara have occurred.

23. GAL Williams by her dereliction of duty in case # 13RI-CV00554 has endangered and damaged Mikaela’s future scholarship, educational and employment options (scholarship and school and some job applications ask if applicant has been suspended from school and want to know the reason and can cause disqualification) because she placed Mikaela and Sara in a school with multiple known contraband, bullying and bombing threats, which has endangered Respondent’s minor children and GAL Williams did not provide self defence training nor proper supervision or additional protection to keep her safe from the known contraband, bullying, physical assault or multiple bomb threat elements in the Doniphan public school system.

24. That GAL Williams knowingly has failed to protect Sara from being assaulted on the school bus until she had bruises on her legs and from forcing her to endure vulgar language while on the Doniphan public school bus and has failed to protect Mikaela from being bullied and threatened in the Doniphan public school system and who who is now facing Juvenile court for alleged contraband allegedly obtained while in the care and protection of the public school system chosen by GAL Williams, Intervenor and this Court.

25. That GAL Williams not only has provided no factual information to the court but also has failed to diligently advocate a position in the best interests and well being of the minor children nor has she advocated for the minor children’s religious, health and cultural upbringing nor their Constitutional rights.

26. That GAL Williams has not protected nor defended the futures of Mikaela and Sara at a vulnerable time in their lives.

27. That should the caseload of GAL Williams be too heavy, she should have taken appropriate steps to recuse or notify the Court. That on or about May 26, 2017 Respondent requested GAL Williams to recuse at Missouri Children’s Division 90 day FSTM on 5/26/17 meeting for failure to protect parties minor children and she refused to “voluntarily” recuse. That GAL Williams has not returned one single phone call of Respondents multiple attempts to contact her regarding serious concerns about the minor children placed in her care and protection and even berated Respondent in the Doniphan Hospital emergency room on or about February 3, 2017 for calling her about Mikaela’s self harming while in Intervenor’s care. Nor has GAL Williams been available for a meeting with Respondent claiming a heavy caseload schedule, and computer issues, and has stated to Respondent that she does “not have to meet with parents” despite multiple attempts by Respondent to set up a meeting with GAL Williams personally and through her secretary Glenda.

28. That GAL Williams was aware that Petitioner (Charles Haynes), unsupervised by Intervenor (Bernice Haynes) forced a distraught seven-year old Sara onto the school bus early in the mornings, where Sara has been bullied, assaulted physically and forced to listen to vulgar language and also that Petitioner, unsupervised, as court ordered by Intervenor, was picking minor children up from school bus. And, Petitioner, unsupervised and out of the hearing of Intervenor repeatedly with GAL’s knowledge endangered Sara and Mikaela by putting them up repeatedly day after day onto a dilapidated old rusty dangerous barn roof with exposed electrical high line wires to play.

29. That GAL Williams did not make sure the girls kept their friend relationships as per . Traumatizing them even more by keeping them from their friends.

30. That GAL Williams broke Standard 2.0 pursuant to Section 452.423, R.S.Mo.

29. That GAL Williams has a conflict of interest because she worked for the law firm Kennedy, Kennedy, Robbins & Yarbro, LC., wherein Christopher Lynn Yarbro, Bar No. 56659, represented Petitioner in case number 13RI-CR00907-01. Respondent believes GAL Williams should have recused because of her conflict of interest of working at this law firm who represented Petitioner regarding issues involved in this case. (See OCDC Article: Some Conflicts Are Without A Cure: http://www.mochiefcounsel.org/newsP.htm?id=22)

30. That GAL Williams worked in the 36th Circuit Butler County Clerk’s office wherein a conflict of interest occurs because of such interaction in and knowledge of other cases involved with Respondent. GAL Williams failed to inform Respondent of this conflict of interest.

31. That GAL Williams refuses to recommend placement of the girls with their Natural Mother despite the majority of the “TEAM” recommending immediate return of the minor children to their Natural Mother. GAL Williams stated she is on board with the DFS “TEAM” for the goal of “reunification” with Natural Mother, but that she is on a fishing expedition to see if she can find some other reason from a past closed case that was intertwined with another Cindy Haynes counseling and psychological reports to keep the girls in foster care. GAL Williams should know the devastating statistics that lifelong effects of foster care have upon children. Since GAL Williams did not have any factual evidence to take them away from Respondent since the December 7, 2016 hearing, which included testimony by Mikaela Haynes, and their physical removal on or about December 23, 2016 from their Natural Mother. The effects of the removal of the children from their Natural Mother have been devastating because of GAL Williams recommendations based on fabricated claims of “educational neglect” proven false. The majority of “THE TEAM” (FSTM) recommends the children be returned immediately to their Mother’s care and custody. See Dr. Bost’s letter dated April 25, 2017, Exhibit A, Counselor Scott Foster’s recommendation report, Exhibit B, Counselor Sara Craig’s recommendation report, Exhibit C, and Melissa Hammond’s Parent Aid notes, Exhibit D., and Dr. John Patty’s letter.

32. That GAL Jennifer Williams REFUSED to represent Mikaela after she was charged with a crime by conflict of interest (Dean Million worked hard as Paul E. Hogg’s attorney to disinherit Respondent's (Cynthia Haynes) children) Juvenile office Attorney Dean Million and conflict of interest (violated HIPAA by disclosing victims details to her daughter Beth Stark who disclosed details of crime victim Melissa Hogg to Doniphan Public School students on or about 5/14/15 in criminal case # 13RI-CR00907-01) Juvenile officer Pam Stark because of the Doniphan School complaint of Safe School policy violations (there is no better SAFE SCHOOL policy than SUPERVISION, and evidently the Doniphan Public/government School does not have enough student to teacher staff ratio especially for their AT RISK and especially vulnerable student population who are in FOSTER CARE (school had a copy of this court order on Mikaela Haynes of John and Cassie Rideout being the FOSTER PARENTS, considering the Doniphan Public School’s KNOWN drug trafficking and bullying and threat problem).

33, That GAL Williams REFUSED to recuse herself upon written request and filed in Ripley County circuit clerk Sharon Richmond on July 6, 2017 and July 7, 2017 by Respondent. GAL Williams flagrantly disregarded the notice sent by Respondent and blatantly dunned Respondent for $750 more in fees instead of refunding as requested ALL prior fees paid by all parties to GAL Williams and her law firm Spain Merrill and Miller LLC.

34, That GAL Williams on July 24, 2017 failed again to advocate for the best interests of Mikaela and Sara by allowing the Intervenor and Petitioner's attorney by not advocating no contact with Petitioner and Intervenor as recommended by Children’s Division depositional phase report on July 24, 2017, Mikaela and Sara’s Counselor Scott Foster’s report on 7/7/17, CASA worker’s report on July 24, 2017. Instead GAL Williams MADE NO OBJECTIONS to Judge or to the TEAM assembled on July 24, 2017 at 3:00 - 5:00 pm at the Juvenile Justice Center in Poplar Bluff, Mo - in fact the whole team who was there to help was not even invited to discuss the negotiations being made for a resolution/agreement with the TEAM which was court ordered on July 24, 2017 (See attached). The recommendations of the counselor, CD case worker, CASA worker’s recommendations were that the minor children should NOT have contact with Petitioner until after the outcome of Petitioner's pending criminal case is determined which GAL Williams flagrantly disregarded and who made NO OBJECTIONS to subjecting the minor children to more abuse and trauma.

35. That it would be in the best interests of the parties’ minor children, given the above circumstances and negative effects of GAL Williams’ influence, and for good cause shown, that GAL Williams be disqualified to act in the minor children’s best interests and well being because she has not faithfully performed her duties.

36. Respondent also requests a full refund to each party of the fees paid in this case from Guardian Ad Litem Williams and the Spain Merrill and Miller Law firm because she has endangered and compromised the best interests and well being of the minor children in the 36th Judicial Circuit Court and has not faithfully discharged her duties per State Statutes and Guidelines.

37. That the law firm Spain Merrell & Miller LLC employing GAL Williams has a conflict of interest with this case because Atty Karen Jolly Miller’s father sold a 2.5 million piece of property to Cindy and Danny Hogg on or about 2000-2001. In 2005 after Paul Daniel Hogg received this property as his part of the divorce sold his property to Paul Duckett for 2.5 million dollars. Atty Karen Jolly Miller of Spain Merrell and Miller LLC handled the sale of this property for Danny Hogg to Paul Ducket while Danny Hogg evaded a huge $400,000 plus IRS debt and child support arrearage in excess of $180,000 currently to Cindy Haynes and fled to the Philippines with the proceeds of this sale without taking care of family obligations or the IRS debt from a 2001 Federal and State tax returns that he was court ordered to pay in Hogg vs Hogg in case #’s 36V050100325, 15RI-TJ00001, 36V050100325-01, 09RI-TJ00100. To avoid paying child support in case #50985239 (arrearage over $180,000.00), Paul Daniel Hogg with the help of his good ol buddy system connections in the Ripley/Butler County area, had himself declared Incapacitated-Disabled in case #13BT-PR00384 to avoid possible jail time for failure to pay court ordered family obligations because of child support arrearage in excess of $180,000.00 currently.

WHEREFORE, Respondent, Cynthia K. Haynes, prays that the Court issue an Order disqualifying the Guardian Ad Litem, Jennifer Williams, and appoint attorney, Cameron Bunting Parker, as Guardian Ad Litem herein, and that the jurisdiction of Missouri Children’s Division (Juvenile case numbers and 17RI-JU00011 Mikaela Ann Haynes, and 17RI-JU00012 Sara Mae Haynes) that Respondent stipulated to while Mikaela was hospitalized in DePaul Hospital - SSM Health in Bridgeton, Missouri on or about February 3, 2017 be immediately terminated and the minor children placed back into the sole custody and care of Respondent pending the outcome of Petitioner’s criminal case number 13RI-CR00907-01 and for such other and further orders as the Court deems just and proper.

When the state acts to remove children into foster care due to circumstances of abuse or neglect, it assumes an affirmative duty to act in loco parentis to keep those children safe.

Mikaela has not been kept safe. She was taken from a safe school and placed in a known drug trafficking school with known issues of bullying [https://dese.mo.gov/governmental-affairs/public-school-laws-missouri/bullying] and threatening and drug problems. They have a known student to teacher ratio problem. Mikaela was not provided protection in this known drug element environment - and they provided her no drug awareness classes - especially for an “at risk” child (foster child).

The school's safety policy; There is no better safety policy than SUPERVISION. Mikaela was a minor in their care, and the Doniphan government school failed to keep her safe because of lack of supervision in a known drug trafficking environment while she was in their care.