About This Section
This section brings together the allegations raised against me and the parenting and co-parenting issues I believe are relevant to the custody evaluation. Under Disputed Allegations Against Father, the allegations are organized by the filing or source in which they were raised, together with my response and the related evidence. Under Parenting & Co-Parenting Issues for Review, I have organized the issues by subject and provided the relevant context and source records so they can be reviewed directly. Use the two buttons below to switch between them — each one changes the entire page.
Filing Groups & Allegations
June 2025 Emergency Protective Order Claims
Petition for Protective Order · 2025-06-24
Katie filed an Emergency Protective Order that included multiple narrative allegations against Stuart. This section breaks the filing into specific child-level claims so each one can have its own response, rebuttal evidence, witnesses, missing evidence, and notes.
Father's Position
I dispute the allegations in the Emergency Protective Order narrative. The purpose of this section is to separate the filing into specific claims and attach the evidence that rebuts each individual allegation.
Emergency Custody Claims - First Attempt
2025.06.30 Petitioner's Ex Parte Application for Emergency Custody (1).pdf · 2025-06-30
Emergency Custody Motion
Father's Position
Katie filed this first emergency custody application on June 30, 2025. The application was denied on its face. Because many allegations repeat or reframe the June 2025 Emergency Protective Order claims, these entries should be short and should cross-reference the corresponding PO allegation when applicable.
DVIS Risk Assessment: Initial and Amended Reports
DVS Domestic Violence Risk Needs Assessment (Initial & Amended) · 2026-08-17
DVIS completed a Domestic Violence Risk Needs Assessment after the protective order was entered. The initial report placed me at Level C. After I provided additional documentation, DVIS issued an amended report on August 17, 2026 that removed one previously scored risk factor and reduced the assessment to Level B, intermediate risk.
Father's Position
I am including both reports because the assessment itself explains that it does not determine guilt or innocence, and several of the scored factors were based on allegations contained in the protective-order application or collateral reports rather than independent findings made by DVIS.
Key Context
- •The reports are important to read in sequence.
- •The initial assessment scored several risk domains by relying on the protective-order proceeding and related collateral reports. For example, the initial report scored firearm access because the protective-order materials alleged that I still had access to firearms.
- •I then provided Tulsa Police Department documentation showing that the firearms had been surrendered after service of the protective order. In the amended report, DVIS expressly states that the firearm domain 'no longer applies.' The overall assessment changed from Level C to Level B.
- •The amended report similarly distinguishes between my denial of certain conduct and the allegations contained in the protective-order application. It states, for example, that the application 'details instances' of domestic violence and stalking/monitoring behavior.
- •The amended report also acknowledges that I provided documentation showing the child-welfare allegations were unsubstantiated, but states that the child-welfare domain is nevertheless scored because prior child-welfare involvement is counted 'regardless of outcome.'
- •For that reason, I think it is important that the risk score not be read as an independent finding that each underlying allegation occurred. DVIS itself states at the beginning of the assessment: 'This assessment does not determine a client's guilt or innocence.'
What I Want the Evaluator to Understand
- •My concern is not with DVIS applying its scoring instrument as designed. My concern is that the resulting risk level can be misunderstood if it is viewed without the source of each scored factor.
- •Some factors were based on allegations in the protective-order application or collateral reports. One of those factors, firearm access, disappeared once objective contrary documentation was supplied, and the overall level dropped from C to B.
- •Other allegations are not as easily resolved with a single receipt or property record. The child-welfare factor illustrates another limitation: DVIS expressly acknowledges the allegations were found unsubstantiated but still scores the domain because the involvement itself counts regardless of outcome.
- •I am providing the original report, the documentary correction, and the amended report together so the evaluator can see exactly how the scoring changed and what the reports themselves say about the limits of the assessment.
Amended Emergency Custody Claims - Second Attempt
20250707 Petitioner's Amended Ex-Parte Application for Emergency Custody.pdf · 2025-07-07
Amended Emergency Custody Motion
Father's Position
Katie filed this amended emergency custody application after the first emergency custody request was denied on its face. The July 7 emergency custody order was later dismissed, and Katie's request for ongoing emergency custody was withdrawn in the July 17, 2025 Agreed Interim Order. Most allegations repeat or reframe the June 2025 Emergency Protective Order claims and should be read with the related PO allegation cross-links.
Notable Changes From First Emergency Custody Attempt
- •The $3,000,000 life-insurance language tied to the Lilli Higgins allegation was removed from the amended application and does not appear in Lilli Higgins' affidavit.
- •The Lilli allegation was reframed as "endless amounts of pain, trauma, grief and stress" and Lilli's interpretation of harm to Katie and the children.
- •The "grooming" allegation involving Lane giving messages or massages was removed.
- •The cell-phone location tracking allegation through administrative account access was removed.
- •The retaliatory-motions allegation was removed.
- •The worker bribery / worker immigration-status intimidation allegation was removed.
- •The long boundary-message narrative from the first affidavit was shortened.
- •Some sexual-boundary and bathroom allegations were removed from the main application but remained in Katie's amended affidavit.
- •The request for sex-addiction treatment was removed from the requested relief, although personal sexuality/adult-conduct allegations remained in the affidavit.
- •The amended filing added Lilli Higgins' affidavit, Gayla Arnold's affidavit, and a new alleged therapist/DHS referral dated July 2, 2025.
November 2025 Contempt Filing Claims
1063136484-20251126-085628-.pdf · 2025-11-25
Verified Application for Contempt Citation — Six contempt counts alleging violations of the EPO, the July 17 Interim Order, GAL recommendations, and the automatic temporary injunction.
Father's Position
Katie filed this contempt application alleging six violations of the EPO, the July 17 Interim Order, GAL recommendations, and the automatic temporary injunction. This section is organized by the six contempt counts rather than every narrative statement in the filing. I dispute the contempt allegations as stated. The purpose of this section is to identify the count, give my short response, and attach the rebuttal evidence.