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chronolgy of sealed divorce from attorney rick A. Voytas

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Evidence Flipbook Case #1- Voytas (pdf)

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Chronology Related to Sealed Divorce of Attorney Rick Voytas

*Note: The period of time just prior to, and after, Judge Green was appointed to one of my domestic abuser’s lawsuits—when I was already reporting his criminal misconduct in my divorce from Attorney Rick Voytas— begins in Section III under “April 8-10 2022”

July 1, 2021

  • Following a year of separation, Attorney Richard 'Rick' A. Voytas (Petitioner), represented by Attorney Jack Cavanagh, filed a divorce petition in St. Louis County, Missouri, Family Court. Mr. Cavanagh emailed me on 07/01/21 to notify me that a divorce petition had been filed, but he delayed serving me with a copy of the pleadings, as evident in our email exchanges in July 2021.

July 14, 2021

  • Mr. Cavanagh’s paralegal emailed me the pleadings they filed on Mr. Voytas’s behalf on 07/01/21. This was following two weeks of me requesting copies from Mr. Cavanagh after his initial email to me on 07/01/21 when he notified me they had been filed. In addition, I was forwarded a copy of an order assigning the case to the division of associate circuit judge Joseph L. Green (Div. 36) of St. Louis County Family Court, which, according to the document, was assigned to his division on July 8, 2021.  


  • Links


  1. Petitioner Rick Voytas’s: Petition For Dissolution Of Marriage 
  2. Motion To File Under Seal *Note that this document included an assortment of lies suggesting that I had a “complicated custody situation”, when I had sole legal and physical custody of my sons from a previous marriage since 2018. They also claimed that my marriage to Mr. Voytas had been kept a secret from Mr. Voytas’s children, which was false. This was just the beginning of a barrage of materially fraudulent information that was about to ensue. It served to lay the foundation for undermining my character, as well as the character of my teenage sons, which only compounded as the litigation persisted.  
  3. Mr. Voytas's Property Statement

August 6, 2021

  •  Attorney Susan Jacobson filed an Entry of Appearance & Request For Additional Time To File Responsive Pleadings on my behalf (Respondent), which was granted.

August 30, 2021

  • Attorney Susan Jacobson filed pleadings in response to Mr. Voytas’s divorce petition. A joint-motion was filed by Ms. Jacobson and Mr. Cavanagh to request that the court file the parties' pleadings under pseudonyms, due to concerns related to my first-husband, and my sons’ and my known domestic abuser, Victor A. Ojeda. This was also necessary to correct the claims Mr. Cavanagh made in his Motion To File Under Seal which he filed with Mr. Voytas’s divorce petition in July (see 07/14/21).  


  • Links to Respondent Anne Ojeda’s:  


  1. Answer To Petitioner’s Petition For Dissolution Of Marriage
  2. Counter-Petition For Dissolution Of Marriage     
  3. Property Statement 
  4. Joint Motion For The Parties To Proceed By Pseudonym 

     

September 10, 2021

  •  The paralegal for Mr. Voytas’s attorney, Jack Cavanagh, emailed Ms. Jacobson to notify her that Mr. Cavanagh filed a Motion For Judgment On The Pleadings on Mr. Voytas’s behalf and scheduled a settlement conference for 10/06/21, and a hearing date for 10/19/21 in Judge Green’s division (Div.36).

October 6, 2021

  • Attorney Susan Jacobson and I called into Judge Green’s division for the settlement conference scheduled to take place via a conference call at 9:45am. Neither Ms. Jacobson or Judge Green’s clerk, Karrie Cooper, was able to get in touch with Mr. Voytas’s attorney, Jack Cavanagh, who ultimately ended up being a no-call/no-show. 


  • Ms. Jacobson followed up with an email to Mr. Cavanagh regarding his absence the same day. She told Mr. Cavanagh that the settlement conference would need to be continued due to his absence, and that I intended to proceed pro se moving forward.

October 11, 2021

  • Ms. Jacobson emailed Mr. Cavanagh a copy of her Motion To Withdraw from the case.  At this point Ms. Jacobson still had not received a response from her email to Mr. Cavanagh on 10/6/21 regarding his absence at the settlement conference. Ms. Jacobson’s motion included a copy of a formal letter filed with the court, which affirmed the information she previously communicated to Mr. Cavanagh following his absence from the 10/06/21 settlement conference. This served as a formal record reflecting the status of the case at the time she withdrew. 


  • Ms. Jacobson recommended that the settlement conference Mr. Cavanagh missed on 10/06/21 be continued to 10/19/21, since the parties had yet to have one since their petition and counter-petition for divorce were filed. Mr. Cavanagh never responded or acknowledged the need to continue the settlement conference that he missed on 10/06/21, or ever addressed his unexplained absence to Ms. Jacobson or the court.

October 18, 2021

  • Susan Jacobson emailed Jack Cavanagh after not receiving a response to her correspondence related to his absence for the scheduled settlement conference on 10/06/21. She told Mr. Cavanagh that Judge Green had not signed off on her Motion to Withdraw which she filed on 10/11/21.  


  • Ms. Jacobson told Mr. Cavanagh that I was copied on the email she sent him, to ensure that I was provided information regarding whether the court setting scheduled in Judge Green’s division for the following day (10/19/21) would be held in-person or online, since it was no longer going to be a hearing but rather a continuance of the settlement conference for which he was an unexplained no-call/no-show.  


  • Jack Cavangh responded to Ms. Jacobson’s email to let her know that the settlement conference on 10/19/21 would be held online on the court's video-conference system called Webex. He did not express any disagreement with Ms. Jacobson’s assertion that the following day, 10/19/21, was not going to be a hearing but rather a settlement conference to make-up the one he was absent for on 10/06/21.

October 19, 2021

  • I emailed Judge Green’s division clerk, Karrie Cooper, to confirm there was no need to call into the division for the settlement conference, which my former attorney, Susan Jacobson, had confirmed details about with Mr. Cavanagh by email the day before. Ms. Cooper emailed me back to let me know that it was still scheduled as a hearing, despite Susan Jacobson’s confirmation with Mr. Cavanagh that it would replace the settlement conference he was a no-show for on 10/6/21.  


  • Judge Green’s division previously acknowledged that the missed settlement conference would need to be continued (see 10/6/21 email between attorneys regarding the division’s plan to continue the settlement conference after no one could reach Mr. Cavanagh). 


  • At 4:00 PM, Mr. Cavanagh and I both logged into the court’s online platform (Webex) to attend a hearing, despite Mr. Cavanagh knowing that Ms. Jacobson confirmed with him just 24 hours earlier that the meeting would be treated as a continuation of the settlement conference he missed on 10/6/21.


  • Links


  1.  Video with audio and captions from the 10/19/21 hearing with Judge Joseph L. Green, held via the online platform Webex, which was supposed to be the parties' first settlement conference in the case rather than a hearing. 
  2. Certified Transcript from 10/19/21 which corresponds with video/audio linked above.


  • After the hearing, I never received a copy of any orders, or the interim judgment entered by Judge Green dissolving the parties' marriage in advance of the court even having accurate income and property statements from Mr. Voytas. I did not find out an interim judgment had been entered until months later (see events listed under 12/29/21).  


  • It wasn’t signed by the parties, and based on the transcript and audio of the hearing held on 10/19/21, Mr. Voytas and his attorney, Jack Cavanagh, had not submitted the minimum required information to proceed with a hearing, let alone for an interim judgment to be entered. 

November 8, 2021

  • Jack Cavanagh filed a Motion for Judgment and a Notice of Hearing for 01/04/22. His paralegal emailed me copies since I still did not have access to the case record or docket, or any means of receiving notifications when something was filed or altered. 

December 8, 2021

  • I filed a Motion in Objection through St. Louis County Court’s Domestic Relations Department’s e-filing system for pro se litigants in response to Mr. Cavanagh’s Motion For Judgment. I also emailed a copy of the motion to Judge Green’s division clerk, Karrie Cooper, and the opposing counsel, Attorney Jack Cavanagh.

Section II

December 14, 2021

  • I contacted Attorney Cynthia Albin to have her review the case and emailed her the documents that I had received copies of from Mr. Voytas’s attorney, Jack Cavanagh, up to that point in time. 


  • Since the time of the October 19, 2021 hearing in Judge Green’s division, I still had not received copies of the property statement Mr. Voytas needed to correct so we would have the minimum information to proceed with divorce litigation. There were other significant outstanding issues that were raised during the 10/19/21 hearing that remained unresolved.  Those issues included Judge Green’s denial that my former attorney, Susan Jacobson, filed an Answer and Counter-Petition of Dissolution on 08/30/21 (see links to filings listed under 08/30/21), and that 10/19/21 was supposed to be a continuation of the first settlement conference that was inexplicably missed by Mr. Cavanagh on 10/06/21.


  • It’s evident in my counter-motion to their Motion for Judgment, which was filed in November 2021 (copy provided to me via email by Mr. Cavanagh) that I was unaware an interim judgment was entered on 10/19/21. I did not have access to the case file at the level of security it had been placed under by Judge Green on 10/19/21.

December 21, 2021

  • I retained Attorney Cynthia Albin in advance of the hearing scheduled in January related to Mr. Voytas and Mr. Cavanagh’s Motion for Judgment and my counter-pleading filed in response, which Ms. Albin reviewed prior to entering the case. 

December 28, 2021

  • Cynthia Albin filed an Entry of Appearance, a Motion for Continuance and a Notice of Hearing related to Mr. Cavanagh’s outstanding Motion for Judgment and my counter-motion. 


  • Ms. Albin scheduled a settlement conference to be held on 02/09/22 with Mr. Cavanagh and Judge Green.  

December 29, 2021

  • I notified Ms. Albin via email that Mr. Voytas was six months away from getting remarried based on a wedding announcement posted online. Ms. Albin said that Mr. Voytas would need to finalize our divorce prior to his remarriage. She stated she would speak with Mr. Cavanagh regarding the issue causing the delay.  


  • Shortly after consulting with Mr. Cavanagh, Ms. Albin told me that the marriage had already been dissolved without the marital assets and liabilities even being identified. She said it was “atypical” and she knew that on 10/19/21 I wasn’t presented with the terms of that judgment, was not provided a copy to review or sign, hadn’t given my verbal consent, did not have my former attorney’s counter-pleadings recognized by Judge Green, nor did I have ongoing access to the active case file/docket. 


  • The interim judgment suggested that Mr. Voytas would be the only party to report what our marital liabilities and assets were, how they were going to be divided, and could submit that information to the court at a later date after the marriage was already dissolved. It was as if I was not a valid participant in the case. 


  • It didn’t appear to be a reasonable document that any party to a divorce would consent to. The document essentially waived one spouse’s rights to participate in the legal processes required to identify, and divide marital liabilities and assets in Missouri. This was consistent with the fact that on 10/19/21 Judge Green tried to intimidate me from affirming the truth about the counter-pleadings that were filed by my former attorney, Susan Jacobson (see 08/30/21), and that a settlement conference had not been held yet in the case. 


  • Judge Green and Mr. Cavanagh delayed/obstructed my ability to identify in real-time when materially fraudulent orders and judgments were being filed because I never had access to the active case file/docket. This was a well-documented issue throughout the litigation, and there was never a formal acknowledgment or remedy provided.  


  • The interim judgment provided to Ms. Albin by Mr. Cavanagh, represents the first legal document entered by Judge Green that constitutes criminal fraud based on the criteria set forth in MO Rev Stat § 570.095 as part of a Conspiracy Against Rights Crime (18 U.S.C.,Section 241)

January 2022

  • While the parties awaited the next case setting scheduled in the matter, which was scheduled for 02/09/22 by Ms. Albin (see 12/28/21), Attorney Jack Cavanagh was unresponsive to Cynthia Albin’s attempts to resolve the issue preventing the resolution of the parties' divorce. The issue was Mr. Voytas’s unwillingness to allow the court to enter an enforceable marital property settlement agreement, congruent with Missouri law and directed by the terms of the parties' postnuptial agreement.


  • While I was represented by Attorney Susan Jacobson she had the same issues with Mr. Cavanagh’s lack of responsiveness, including incidents like his unexplained absence at the only settlement conference that had been scheduled (see 10/06/21) since the parties' divorce petition and counter-petition were filed in the summer of 2021.  


  • Mr. Cavanagh and Mr. Voytas remained insistent that the marital property settlement agreement state that the former marital home was going to remain co-titled and the sale deferred, preventing me from fully severing ties with Mr. Voytas and regaining control of my individual liabilities and assets. This was particularly distressing as a sole custodian of two minors who I have been the sole financial provider for since 2017. 

February 9, 2022

  • Ms. Albin emailed me the morning of the settlement conference that was scheduled to be held between her, Jack Cavanagh and Judge Green on this day. In that email, Ms. Albin forwarded an exchange she had with Mr. Cavanagh in which she indicated to him that the marital property settlement agreement should reflect that the parties planned to sell the former marital home, rather than continue to co-own it. 


  • The opposing party's position was unchanged, despite the fact there was not a legal claim which would support what they were motioning to the court, as outlined in my Motion In Objection filed in response to the opposing party's Motion for Judgment. 


  • I emailed Ms. Albin that evening to ask her what happened at the settlement conference between her, Mr. Cavanagh and Judge Green earlier in the day. She said she would contact me afterwards but never did.

February 11, 2022

  • Ms. Albin emailed me to set up a time to discuss what occurred during the settlement conference on 02/09/22.

February 26, 2022

  • In an email exchange between Cynthia Albin and I following the settlement conference held on 02/09/22, I explained to Ms. Albin that I would not sign the Consent Judgment and Stipulation she and Attorney Jack Cavanagh were proposing at that time because it directly conflicted with Missouri law related to the division of marital property.  

March 1, 2022

  • I received an email from Cynthia Albin’s paralegal with a copy of Petitioner’s Motion For The Court To Declare Postnuptial Agreement For Full Division of Property and Liabilities of The Parties which was filed by Jack Cavanagh, on Mr. Voytas’s behalf. The email was sent to me on 03/01/22 but the motion attached to it was dated as being filed on 02/25/22.  


  • This motion was essentially the same as The Motion for Judgment Mr. Cavanagh filed in November 2021, and I filed a counter-motion in response to, which I retained Attorney Cynthia Albin to represent in December 2021. After a settlement conference on 02/09/22, the issues between the parties remained unresolved.  

March 3, 2022

  • Cynthia Albin and I had another email exchange regarding why I refused to sign the Consent Judgment and Stipulation she sent me a draft of following the settlement conference between her, Attorney Jack Cavanagh, and Judge Green on 02/09/22.

March 9, 2022

  • Cynthia Albin emailed me with the only correspondence she received in response to her attempts to contact Attorney Jack Cavanagh regarding the redundant motion they filed (see 03/01/22) which was the same as the one I already filed an outstanding counter-motion in response to. The only thing preventing settling the case was the court identifying and dividing the parties' liabilities and assets in a marital property settlement agreement entered by the court, which reflected the terms of the final home sale rather than a continued co-ownership.  

March 11, 2022

  •  I emailed Ms. Albin asking her if we needed to respond to their redundant pleadings, even though there was already an outstanding motion filed by me which objected to the same motion when they filed it in November 2021. 

Section III

March 14, 2022

  •  Ms. Albin emailed me to re-assert her position, which was totally opposite from the position she held upon her agreement to enter the case (see events listed under December 2021). The parties’ post-nuptial agreement specifically stated that the court would defer to “the wife” as to the date of the home sale, and that the court would perform a statutory review and strike terms no longer valid as a result, without invalidating the entire agreement, when entering a final marital property settlement agreement. 


  • In Missouri, pre- and postnuptial agreements include directives about how parties would like the court to execute the identification and division of their marital liabilities and assets in the event of a divorce being filed. In contrast, a martial property settlement reflects how the court actually did identify and divide parties’ marital liabilities and assets upon divorce, whether or not it was based on the directives of a pre- or post-nuptial agreement or not. A pre- or post-nuptial agreement is not legally equivalent to the court's final judgment. which is why in industries that require accountability to the law, such as mortgage lending, a pre- or post-nuptial agreement cannot be submitted in place of a final divorce judgment entered by the court to determine someone’s post-dissolution debt-to-income ratio and assets. 


  • Accordingly, the opposing party had no legal basis to suggest that the court would not serve its mandated function, and instead request that I sign a stipulated consent judgment stating that the way the property division was being handled was congruent with Missouri law. Ms. Albin read the motion I filed just prior to retaining her in December 2021 which cited Missouri law and case law that establish the legal bounds that Missouri Courts must operate within when dividing marital liabilities and assets in order to provide finality for the efficiency of the courts and preservation of the public's interests.  


  • In Ms. Albin’s email, she notified me that there was a hearing date set for the opposing party's Motion To Enter Post-Nuptial Agreement as Judgment on 04/19/22, which is the motion I emailed her about on March 11, 2022. I never received a response as to whether we needed to refile the counter-motion objecting to the same pleadings that I filed in December 2021 after they filed the same pleadings in November 2021. There had not been a hearing for those outstanding motions since the time of the 02/09/22 settlement conference with Judge Green, which left those motions unresolved by consent of the parties. 


  • The technique for advancing the crime Ms. Albin engaged in was repetitively gas-lighting me by suggesting that I was asking something of the court that Missouri law doesn’t require of it anyway. She would then use these claims to support why she would not represent me if I would not waive my right to protections provided by the terms within the postnuptial agreement, which provided for me to determine the date of sale at the time a divorce petition was filed and the marital liabilities and assets divided. Ms. Albin was aware this would prevent my sons’ and me from being able to establish a new home that I could afford to maintain post-divorce as a sole custodian and sole financial provider, and leave unresolved legal matters with someone who was months away from getting married again.  


  • I emailed Ms. Albin a link to the audio from the only other meeting between the parties and Judge Green in the case, which was held on 10/19/21, during which Judge Green and Mr. Cavanagh pretended there had been a settlement conference, and that my former attorney hadn’t filed counter-pleadings when it was clear that she had. In addition, it indicated that the property still had not even been identified by the court because the opposing party had not provided the information required to do so. I was requesting her to file a Motion to Disqualify For Cause which would need to be filed in the division of the presiding judge of the judicial circuit, Judge Mary E. Ott (Div. 7).

March 18, 2022

  • There was an email exchange between Ms. Albin and I regarding my request for her to file a Motion to Disqualify Judge Green for Cause on my behalf. The last message in the email thread was sent by me and I did not receive any further contact from Ms. Albin or her office, until an email correspondence I received from her paralegal on 03/30/22.

March 30, 2022

  •  Cynthia Albin’s paralegal emailed me a copy of a letter, Motion to Withdraw, and Notice of Hearing filed by Ms. Albin. Her Notice of Hearing requested a 04/11/22 date which was exactly seven business-days from the time she was notifying me of it. She did not even coordinate a date or time that I could be available. That date was also just a week away from the hearing Jack Cavanagh had set for April 19, 2022 for their Motion to Enter Post-Nuptial Agreement as Judgment.  


  • Ms. Albin knew that I requested that she, at minimum, notify the presiding judge of the St. Louis County judicial circuit, Judge Mary E. Ott, that she refused to file a Motion to Disqualify Judge Green for Cause on my behalf, and was requesting to withdraw from my case as a result of that disagreement. This would allow the presiding judge, who hears motions related to judicial misconduct of other judges practicing in the judicial circuit, to be aware there was an immediate issue significant enough to result in Ms. Albin’s withdrawal. 

April 8-10 2022

  • I had an email exchange with Mrs. Albin regarding my therapist’s (Stacey Smith) attempt to reach her. Ms. Smith had just notified another division a month before about what appeared to be an attempt by my two former spouses keep me tied up in two lawsuits at the same time, while they misrepresented a multitude of important facts that were material to the cases (see timeline for other case in March 2022). 

April 11, 2022

  • I corresponded via email with Ms. Albin in the days leading up the hearing held on 04/11/22 regarding the fact that I could not be present in-person at the day/time she chose for the hearing for her Motion to Withdraw because my son had an outpatient medical procedure scheduled that day. I implored Ms. Albin to ensure that upon her withdrawal from the case that she notify the division of the presiding judge of the judicial circuit, Judge Mary E. Ott, that she was withdrawing from a case because she refused to file a Motion to Disqualify Judge Green For Cause for a client. This was important so that Judge Ott would be aware that upon Ms. Albin’s withdrawal, she would be receiving that motion from me as a newly self-represented client. This was particularly important because Ms. Albin scheduled her hearing for her Motion to Withdraw a week before the opposing party scheduled a hearing for their Motion to Enter Post-Nuptial Agreement as Judgment and I did not want to proceed prior to having the presiding judge hear a motion regarding the criminal misconduct of Judge Green. This also included the misconduct of the attorneys who had been involved in the case up to that point. In addition, the issue of not having access to my active case file was also still unresolved, which Ms. Albin was aware of. 


  • I attended the hearing for Ms. Albin’s Motion to Withdraw on 4-11-22 via the online platform Webex, while the other parties attended in-person. Judge Green said there were technical issues preventing my audio from coming through, so I was only able to hear what was happening and not participate. However, I tested the audio prior to the hearing, since the Webex platform allows participants to ensure their audio and video are functioning prior to going “live” with a hearing, and there was not an issue. Regardless, during the hearing, Ms. Albin did not indicate to the court that our disagreement was regarding her refusal to file a Motion to Disqualify Judge Green for Cause or that I was concerned about it being filed prior to me being pro se again in Judge Green’s division.


  • Judge Green granted Ms. Albin’s withdrawal from the case. He also told the parties that we would proceed with the April 19, 2022 hearing scheduled for the opposing party's Motion to Enter Post-Nuptial Agreement as Judgment, and my counter-motion which was outstanding from December 2021 when I first retained Ms. Albin.  

April 15, 2022

  • As a pro se litigant since the time of Attorney Cynthia Albin’s hearing for her Motion to Withdraw on 04/11/22, I filed the Motion to Disqualify Judge Green for Cause that Ms. Albin would not. 


  • I filed an Emergency Motion to Disqualify Judge Green for Cause in two administrative divisions- one in the division of the presiding judge of the judicial circuit, Judge Mary E. Ott (Div.7) and the other in the division of the head of family court, Judge Jason D. Dodson (Div.10). 


  • I also filed an Emergency Motion for Continuance for the hearing that was scheduled to be held in Judge Green’s division on 4/19/22. I sent email correspondences confirming receipt of the filings with all parties on the same day, and to secure a date for the Motion to Disqualify Judge Green for Cause. 

 

  • Links


  1. Email to Attorney Jack Cavanagh with copies of filings and notice of The Motion for Continuance of the hearing that was scheduled for 4/19/22.  
  2. Email correspondence with the presiding judge's clerk, Carol Turner, copying all parties including Judge Green’s division clerk, Karrie Cooper.  
  3.  Email correspondence with Carol Turner who is the division clerk for the presiding judge of the judicial circuit, Judge Mary E. Ott. She directed me to file the motions in the division of the head of family court, Judge Jason D. Dodson (Div.10) and contact his clerk, April Moore.
  4. Email confirming receipt of filings from the Domestic Relations Office.  

April 19, 2022

  • April Moore, the clerk for the division of the head of family court, Judge Jason D. Dodson, emailed me to let me know that without a hearing, or formal response of any kind, Judge Dodson was communicating through her that the parties had to proceed with the hearing scheduled that day, April 19, 2022, in Judge Green’s division (36). 


  • The hearing scheduled for R.V.’s Motion to Enter Post-Nuptial Agreement as Judgment, and my counter-motion proceeded despite my Emergency Motion for Continuance requesting a hearing regarding my disqualification motion in an administrative judge's division, prior to proceeding with another hearing in Judge Green’s division following Ms. Albin’s withdrawal from the case on 4-11-22.


  • During the hearing, Judge Green denied that I filed pleadings related to his disqualification for cause and a continuance of the hearing scheduled for that day (4/19/22), despite the fact I was in receipt of a filing confirmation from the Domestic Relations Department. (transcript of hearing, pg. 8-11) When I requested that there be a resolution to the filing issues that I was experiencing exclusively in Judge Green’s division, he proceeded to mock my ability to follow instructions.


  • Judge Green told me that if I filed something that I would have received a notification from the court's online case filing system known as “Case Net”. Judge Green and Attorney Jack Cavanagh were aware that was false since the case file was sealed and he was the one who sealed it on 10-19-2, so there was nothing visible online related to the case (transcript of hearing, pg. 9, lines 19-25).


  • Judge Green stated that I would lose my right to give an oral argument to the court in the hearing that was about to take place should I continue to ask about resolving issues related to due process in his division. (transcript of hearing, pg. 11). 


  • During the hearing I continued to try and compel Judge Green to recognize that the governance MO statutes have over marital property division is not discretionary, but he continued to deprive me of my ability to engage the law. He continued to create the need for protracted litigation by suggesting a need for additional legal processes that were unnecessary to the issue being presented, which was a failure to state a legal claim by R.V. and his counsel. The court can’t enter something that isn’t legal- the law would supersede it (transcript of hearing, pg. 13 lines 1-41 and pg. 18, lines 7-19). 


  • At the end of the 4-19-23 hearing, Judge Green told the parties that he knew that I “wanted to get away from him” (transcript of hearing, pg. 17 lines 28-32) and the parties were then presented an order which they signed consenting for the case to be reassigned to another judge’s division to have the marital property identified/divided. 

June 3-8th 2022

  • After not receiving any kind of notice regarding whether the case had been reassigned to one of the other divisions the parties consented to at the end of the hearing on 4/19/22, I followed up with Judge Jason D. Dodson’s division by emailing his clerk, April Moore, who I previously corresponded with regarding the motion I filed for Judge Green’s Disqualification for Cause. In the email, I included a link to the audio of the hearing held on-record on April 19, 2022 in Judge Green’s division after Judge Dodson refused to allow me to set a hearing date for The Motion to Disqualify Judge Green For Cause. I let Ms. Moore know that there was still a need for Judge Dodson to hold a hearing because the issues were persisting, and I didn’t even have access to the case file. I did not receive further correspondence from Ms. Moore following the last email in that exchange. 

June 14, 2022

  • As evidenced by my correspondence the week prior with the clerk of the judge who was supposed to reassign the case to another division, Judge Dodson (Div. 10), the case remained unassigned, so further movement in the litigation was on hold.  


  • I emailed Attorney Jack Cavanagh to see if Mr. Voytas was willing to settle the outstanding litigation by agreeing to terms of a marital property settlement agreement, which would reflect the date the marital home would be listed and how the proceeds would be divided. We still hadn’t even identified the parties' marital liabilities and assets (see hearing 10/19/21) and Mr. Voytas was getting remarried in just a few weeks at this time.  


  • I never received a reply from Mr. Cavanagh. The next time Mr. Cavanagh contacted me was at the end of August 2022, a few weeks after Mr. Voytas’s destination wedding in July 2022. At that time, Mr. Cavanagh’s office provided me a copy of a motion they filed in a newly-assigned court division, which claimed I was in breach of the post-nuptial agreement (reference 8/23/24).

July 2022

  • There was no correspondence from the opposing party or the court during this month. Mr. Voytas was remarried by the end of the month. He was able to proceed with remarriage and fund a destination wedding, among other things, even though the court had not even identified his marital liabilities and assets with me (see 10/19/21 hearing), nor entered a plan for their division. Mr. Voytas was forming financial entanglements with a new spouse while I could not be recognized by financial institutions to establish new credit, because I could not provide a legal judgment indicating my post-dissolution debts and assets. 

August 23, 2022

  • I was not notified when the case was temporarily reassigned to Judge Mondonna Ghasedi in Division 43, prior to her ordering the case to be sent back to Judge Green after R.V. and Mr. Cavanagh filed a motion in her division titled Petitioner’s Motion For The Court To Find That Respondent Has Breached The Post-Nuptial Agreement And To Divide The Marital Property Equitably And In Accordance With The Source Of Funds Rule; For Rent From Respondent For Occupation Of The Real Estate; For Quantum Merit Of Rent Due From Respondent’s Occupation Of Real Estate. When Mr. Cavanagh filed this motion in Judge Ghasedi’s Division on 08/23/33, Attorney Jack Cavanagh’s paralegal emailed me a copy of the motion they filed and stated it was being filed in Division 43, which was the only way I found out the case had been assigned to a new division at that point, or that a motion had been filed.  


  • The reassignment of the case to another division, by consent of the parties at the 4/19/22 hearing in Judge Green’s division (Div. 36), was being handled by the head of family court, Judge Jason Dodson (Div.10). Judge Dodson’s clerk, April Moore, was aware that I did not have access to the case file and was not receiving notifications. On 06/03/22, Ms. Moore responded by email regarding my concern about my lack of access to the case file and inability to receive notifications about the status of the case reassignment. In that email, Ms. Moore assured me that she would notify me when the case had been assigned a new division; however, she did not, nor did she respond to my last email sent in the exchange on 6/9/22 related to the outstanding issues. 

August 24, 2022

  • The parties received an email from Judge Ghasedi’s Division (Div.43) notifying them Judge Ghasedi entered an order transferring the case back to Judge Green’s division the day after the opposing party emailed me a copy of the motion they filed in her division as a result of the reassignment, which I was unaware had even been made. Just two months prior, I contacted Judge Dodson’s division and notified his clerk, April Moore, that I did not have access to the case file and could not receive notifications.


  • In Judge Ghasedi’s order, she noted the reasons she was transferring the case back to Judge Green’s division for “further proceedings”, despite the parties' agreement for it to be transferred in April 2022. Judge Ghasedi cited the fact that the parties did not contact her division promptly when it was assigned to it, even though, as evidenced by my correspondence with Judge Dodson’s division clerk, April Moore, in June 2022, Ms. Moore said she would notify me since I didn’t have access to the case file—but she never notified me. The second reason Judge Ghasedi cited was the fact that the opposing party filed a motion that was unrelated to the legal issue the parties still needed to resolve, which was the identification and division of their marital liabilities and assets in the form of a marital property settlement agreement. 


  • The opposing party continued to act as though I was breaking a contractual agreement by asking that the court enter a marital property settlement agreement in accordance with Missouri law, even though it would be directed by the parties' postnuptial agreement. As stated in my counter-motion filed in December 2021 in response to their Motion For Judgment, Mr. Cavanagh and Mr. Voytas weren’t even asserting a legal claim. The terms of the parties' post-nuptial agreement directed the court to defer to me as to whether the former marital home sale would be delayed post-dissolution, since I would be responsible for the maintenance if it were, and strike terms that were no longer valid following a statutory review prior to the court entering the final judgment. 


  • Mr. Voytas did not want the court to execute a marital property settlement agreement that was legally enforceable and congruent with Missouri law. They continued to try and contort the simplicity of the issue when I would not consent to the court simply entering a divorce decree and agreeing that the parties had already sufficiently divided their liabilities and assets because they entered into a post-nuptial agreement. A pre- or post-nuptial agreement does not replace the court's marital property settlement agreement in a divorce, which contains terms that provide for a complete severance of ties and other criteria prescribed by Missouri law. 


  • Mr. Voytas, an attorney himself, wanted to prevent the finality and enforceability that a marital property settlement agreement entered in accordance with Missouri law possesses. This would have prevented his ability to weaponize legal proceedings in order to obstruct me from liquidating my stake in our most significant marital asset, the marital home, upon its sale. Mr. Voytas was attempting to use St. Louis County Court, and his network of legal colleagues within it, as a means to prevent me, and the two sons who I am the sole custodian and financial provider for, from regaining our financial independence post-divorce. 

Section IV

September 6, 2022

  •  Attorney Jack Cavanagh’s paralegal emailed me a copy of a notice of a settlement conference, filed by Mr. Cavanagh in Judge Green’s division (Div.36) related to the motion that he originally filed in Judge Ghasedi’s division two weeks prior (see 8/23/22). The matter was transferred back to Judge Green’s division after Judge Ghasedi noted in her Transfer Order that the motion Mr. Cavanagh filed on 8/23/22 indicated that the parties were not ready to proceed with a trial related to the identification and division of their marital liabilities and assets (see 8/23/22 and 8/24/22). 


  • Mr. Voytas scheduled the phone settlement conference with Judge Green for 11/03/22.

September 9, 2022

  •  I filed a second Motion To Disqualify Judge Green For Cause, since the first one I filed on 4/15/22 was denied a hearing and/or a formal response by the head of family court, Judge Jason D. Dodson. Despite the parties consenting to the case being reassigned to a different judge on 4/19/22, the case had been transferred back to Judge Green before I was even notified of its reassignment (see 8/23/22 and 8/24/22). 


  • That motion, and the 57 exhibits filed with it, presented a persistent pattern of due process obstruction and fraud. I specifically cited the federal civil rights codes which were applicable at that point in time, given the obstruction of my due process had proven to be intentional. 


  • A hearing date was set for October 11, 2022, in the division of the presiding judge (Div. 7), Judge Mary Elizabeth Ott.  


  • The first Motion to Disqualify Judge Green For Cause I filed on 4/15/22, four days after the withdrawal of my former attorney, Cynthia Albin, was originally filed in Judge Ott’s division but she requested that it be refiled in the head of family court’s division, Judge Jason D. Dodson, who ultimately refused to hold a hearing for it. 

October 11, 2022

  • A hearing was held for my Motion To Disqualify Judge Green For Cause in the division of the presiding judge of the St. Louis County judicial circuit, Judge Mary E. Ott (Div.7). 


  •   Links


  1.  Emergency Motion to Disqualify Judge Green For Cause filed by me in September 2022 in The Presiding Judge’s Division (Div.7)
  2.  Corresponding Exhibit Book filed with motion
  3.  Certified Transcript of the hearing held on 10/11/22 in Judg. Mary E. Ott’s Division (Div.7)
  4.  Audio of 10/11/22 hearing that corresponds with the certified transcript above


  • At the end of the hearing, Judge Ott was made aware that since the first time I contacted her division with a Motion to Disqualify Judge Green For Cause on April 15, 2022, that Judge Green was assigned to a second lawsuit that was filed against me by my first husband and known domestic abuser to the court, Victor A. Ojeda (see pages 32-35 of hearing transcript). Mr. Ojeda’s ongoing harassment of my teenage sons and I was one of the primary causes cited for my divorce from my second husband, Mr. Voytas, to be filed under initials. Reference 8/30/21 joint motion filed by my former attorney (Susan Jacobson) and Mr. Voytas’s attorney, Jack Cavanagh, to have my divorce from my second husband, Mr. Voytas, filed under pseudonyms.


  • In April 2022, Judge Ott referred the first Motion to Disqualify Judge Green For Cause that I filed at that time, to the head of family court, Judge Jason D. Dodson. However, Judge Dodson refused to hear the motion and instead assigned Judge Green to a second active case filed against the same woman who was reporting to Judge Dodson that Judge Green was engaging in criminal misconduct in another active case. 

 

  • It was just two months after my last email correspondence to Judge Dodson’s clerk regarding the ongoing issues I was experiencing with Judge Green in my divorce from local attorney Rick Voytas, that he assigned Judge Green to a lawsuit filed against me by my first husband and known domestic abuser, Victor A. Ojeda. 


  • Judge Ott was made aware at the end of the hearing in her division on 10/11/22, that Judge Green had begun scheduling dates in his division for the second matter, filed by Mr. Ojeda in June 2022 and assigned to Judge Green in August 2024. In fact, Judge Green scheduled the first case conference for the second legal matter assigned to him, filed by Mr. Ojeda, to take place less than 24 hours after the hearing we were having regarding his Disqualification for Cause in my divorce from Mr. Voytas on 10/11/22.  

October 13, 2022

  • I emailed Judge Ott’s division clerk, Carol Turner, to find out how I will be notified when a judgment has been entered from the hearing held two days earlier, on 10/11/22 in Judge Ott’s division. I explained to her that I had not had access to the active case file, nor was I receiving notifications electronically due to the level of security the case was further elevated by Judge Green in October 2021. I never received a response from her.  

October 18, 2022

  • I received a judgment via certified mail from Jude Ott’s Division (Div.7) approximately a week after the hearing was held. I did not know a judgement had been entered until this time. Despite contacting Judge Ott’s Division on 10-13-22 for a confirmation as to whether she entered a judgment yet and how I would be notified. No one would confirm a judgment was entered in the file and how/when I could review it.  


  • Judge Green proceeded with litigating the second case filed against me by a different former spouse, and known domestic abuser, Victor A. Ojeda. He met with Mr. Ojeda’s attorney, Roseanne Horan on 10-12-23 for the first time since the matter was assigned to his division, less than 24 hours after the hearing for his disqualification for cause in my divorce from Attorney Rick Voytas.  


  • The judgment summarized a legal argument and evidence, which the transcript from the hearing on 10/11/22 reveals is not what occurred in Judge Ott’s Division that day. This is particularly evident on pages 19-20 of the transcript when Judge Ott clarifies my argument, when compared to what she states it was in her judgment. The discrepancy is evident in reviewing the certified hearing transcript and exhibits filed, juxtaposed to the judgment entered.  


  • Judge Ott’s judgment claimed that my argument for Judge Green’s Disqualification For Cause was precisely what she clarified on-record that it was not. Based on the judgment, no one would even know that I accused Judge Green of intentionally obstructing my 14th Amendment Rights and covering it up with a fraudulent case record, which I still did not have the ability to access or receive notifications about when there was activity. 


  • Judge Ott engaged in the same crime that I brought to her attention in her role as the presiding judge of the St. Louis County judicial circuit. In her judgment, she described a set of materially fraudulent facts that would allow her to apply the law in a way that would result in the outcome her colleague, and the attorneys involved in the case, needed to conceal their crime and finish it to completion.  


  • In response, I filed an Emergency Motion for Relief From Judgement or Order In Accordance With MO Procedural Rule 74.06 , along with the corresponding exhibits, in Judge Ott’s division (see January 13, 2022). According to MO Procedural Rule 74.06, this motion can be granted by the court at any time upon a motion being filed, or by the court's own initiation, to remedy an order, judgment, or other part of a court record, which is not accurate due to clerical error, oversight, irregularities, the absence of due process which would render a judgment “void”, or intentional fraud.  

November 2, 2022

  • I received an email from Attorney Jack Cavanagh’s paralegal reminding me of the phone settlement conference they scheduled in Judge Green’s division for the following day related to their outstanding motion (see 9/6/22 when the notice was filed).

November 3, 2022

  • As instructed the day before by Mr. Cavanagh’s paralegal, via email, I waited for a call from Mr. Cavanagh just prior to 9:30am.  


  • I received a timely call from Mr. Cavanagh’s paralegal, Cindy Goepel, who then requested that I remain placed on-hold while Mr. Cavanagh called Judge Green’s division on another line. She said that once Mr. Cavanagh reached the division, he would take me off hold and merge my call with his and Judge Green’s. 


  • I remained on hold for at least thirty minutes before Mr. Cavanagh’s voice came on the line to tell me that no one was answering Judge Green’s division's phone-line and that his paralegal would email me about rescheduling the settlement conference.


  • His paralegal, Cindy Goepel, contacted me by email later that morning to reschedule the settlement conference that was missed because of Judge Green’s unexplained absence. In my response to her, I asked whether Mr. Cavanagh heard back from Judge Green’s division since he mentioned that he left a message with the division when no one answered after multiple attempts.


  • When Mr. Cavanagh’s paralegal, Cindy Goepel, emailed me again, my last response in the email thread, where I asked if they ever heard back from the division, was deleted, and she responded in a new email-thread without it.  


  • I requested that Ms. Goepel provide me with a copy of Mr. Cavanagh’s Motion once it was filed, which would continue the settlement conference that was inexplicably missed by Judge Green that day.  Mr. Cavanagh filed his notice that same-day, moving the conference to 1/05/23, and she emailed me a copy of his scheduling motion as I had requested.  


  • Recall that these case settings are for the last motion filed by Mr. Cavanagh on 8/23/22 in another division, which was transferred back to Judge Green’s division by Judge Ghasedi. She stated in her 8/24/23 transfer order that based on Mr. Cavanagh’s "breach of contract" motion filed on 8/23/24 in her division, the parties were not ready to proceed with a trial and therefore needed to go back to Judge Green for further pre-trial proceedings.

November 7-8, 2022

  • On 11/07/22 Attorney Jack Cavanagh copied me on an email he sent to a real estate appraiser, which prompted further email exchange between Mr. Cavanagh and I. 


  • In that email exchange, when Mr. Cavnagh mentioned the case being set for a trial, I told Mr. Cavangh that I was totally unaware and hadn’t received orders. This was particularly disorienting because the case had been transferred back to Judge Green’s Division because the parties were not ready for a trial based on Mr. Cavanagh’s outstanding motion. 


  • The last thing to occur in the litigation at this point was that Mr. Cavanagh filed a motion rescheduling the 11/03/23 settlement conference, that Judge Green was inexplicably absent for just three days prior to this email exchange. 


  • After responding to Mr. Cavanagh’s email to tell him that I had no idea what trial he was referring to, his paralegal forwarded copies of the orders that he referenced in our email exchange over the course of these two days. Upon review, I noticed that the date written next to Judge Green’s signature was 11/03/22, which was the day of Judge Green’s unexplained absence which resulted in Mr. Cavanagh rescheduling the settlement conference, for the last motion he filed.  


  • Judge Green entered orders for a trial on the same day he wasn’t available to participate in the scheduled actions in the case. What was scheduled on 11/03/22 was a settlement conference for the opposing party's outstanding motion, but Judge Green wasn’t available for it, nor did he follow-up with the parties following his absence. Now, four days later, I was learning that he and Mr. Cavanagh had other plans than making up that missed settlement conference.


  • Reference the events listed under 10/06/22 to see a similar situation related to a scheduled settlement conference. In that instance, it was Mr. Cavanagh that was a no-call/no-show to a settlement conference. Later, in Judge Green’s Division on 10/19/22, both Mr. Cavanagh and Judge Green acted as though a settlement conference had taken place. During the hearing on 10/19/22, when I started to speak about the fact that my former attorney and I were the only ones to show up for that conference because Mr. Cavanagh was a no-call/no-show, Judge Green quickly cut me off (see 10/19/21 transcript, pg. 13). He then warned me about how if I brought up what was said in a settlement conference again, it would be  contemptuous, but there never was a settlement conference. This was even noted in the letter my former attorney, Susan Jacobson, filed in Judge Green’s Division to document that all parties were on the same page about the state of the case. 


  • I still didn’t have access to the active case file, and wasn’t receiving notifications if something was entered in it- aside from what Mr. Cavanagh’s office would email me, but I was unable to view what was being entered in the court docket. Therefore, I had no way of knowing if it reflected what was actually happening in the case in real-time. My inability to access the active case file, among other obstructions to my right to due process of law, had remained unresolved for over a year at this point. The last time the parties had a hearing in Judge Green’s division, before agreeing the case could be reassigned, was on April 19, 2022. During that hearing I told Judge Green I still didn’t have access to the active case file and wasn’t being notified of entries in the court's docket. Those issues with access were reported yet again to the head of family court, but nothing was done and I was not notified when the case was assigned to her division in June 2022.


  • I appropriately reported those outstanding issues related to the obstruction of my right to due process in motions filed with the presiding judge of the St. Louis judicial circuit’s division, Judge Mary E. Ott. I included audio with certified transcripts, to demonstrate exactly how the opposing party and Judge Green were misrepresenting what was filed in the case, or what proceedings had taken place, more than once, to administrative divisions within the St. Louis County judicial circuit. However, the presiding judge of the judicial circuit, Judge Mary Ott, concealed what I had reported to her in her judgment (reference events listed under 10/11/22 and 10/18/22).  


  • Refer to when the case was reassigned to Judge Mondonna Ghasedi (Div. 43) without my knowledge, and she transferred it back to Judge Green’s division. In Judge Ghasedi’s 8/24/22 order, she cited that Mr. Cavanagh filed a motion in her division on 8/23/22 that indicated the parties had outstanding issues to resolve before proceeding with a trial. That was the last motion filed by the opposing party at this time, and the parties had not met with Judge Green since Judge Ghasedi entered her order transferring it back to his division on 8/24/22.


  • The only reason the case was transferred back to Judge Green’s Division was because the parties still had outstanding pre-trial issues which were evidenced by Mr. Cavanagh’s motion filed on 08/24/23. This motion suggested the parties were divorced and the court had already identified and divided the property and that I was in contempt of those orders.  


  • During the hearing for my Motion to Disqualify Judge Green For Cause held in Judge Ott’s division (Div.7) on 10/11/22, the issue of my inability to have my motions, which were confirmed filed with the court by the Domestic Relations Department, recognized by Judge Green was raised. However, the outstanding issue was that Judge Ott’s judgment described a legal argument and events of a hearing that were totally fraudulent and concealed that the obstruction of my due process rights had even been reported (reference 10/11/22 and 10/18/22). 

January 5, 2023

  •  The settlement conference that Judge Green was a no-show for on 11/03/22 was rescheduled by Attorney Jack Cavanagh for 01/05/23. According to the standing phone settlement conference orders in the division, Mr. Cavanagh was supposed to call me that morning so we could then conference our call into the court division's phone line for settlement conferences with Judge Green (identical to process on 11/03/22- only Judge Green was unexpectedly unavailable that day leading to the continuance).  


  • Mr. Cavanagh never called that morning prior to the time the settlement conference had been scheduled for at 9:30am.  


  • The first contact I received from Mr. Cavanagh was 45 minutes after the phone settlement conference was supposed to be held, in an email he sent at 10:15am to me. In his email, Mr. Cavanagh did not address what had happened but instead asked me to confirm that I would allow a real estate appraiser into the house the following day. 


  • In my email response, I confronted Mr. Cavanagh about what happened to the settlement conference scheduled that day. 


  • Mr. Cavanagh responded that he was in Judge Green’s Division (Div.36) at 9:30am. 


  • I responded to Mr. Cavanagh in an email, to which he never responded. In my response, I cited that the division's standing settlement conference orders stated that unless otherwise specified, all settlement conferences would be held by phone. Mr. Cavanagh knew this because it is the same procedure we abided by on 11/03/22, only we had to reset the date because Judge Green was inexplicably unavailable that time (see events listed under 11/03/22). When he filed his notice rescheduling that missed settlement conference, he did not request an alternate format, so in accordance with the division's orders, the conference would be held by phone.  

January 10, 2023

  •  I had to file a second Motion to Disqualify Judge Green For Cause related to the second lawsuit Judge Green was assigned to, filed by my sons’ and my known domestic abuser Victor A. Ojeda, when he already had a Motion to Disqualify him for cause in the matter with my second husband, St. Louis County Attorney Richard A. Voytas. 


  • Reference the transcript of the 10/11/22 hearing, on pages 32-35 where I tell Judge Ott that Judge Green was assigned to a second case by The Head of Family Court, Judge Jason D. Dodson, when he was aware there was an outstanding Motion to Disqualify Judge Green For Cause already in my divorce from my second husband, Attorney Richard A. Voytas.  

January 13, 2023

  • I filed an Emergency Motion For Relief From Judgement or Order In Accordance With Missouri Rule 74.06 in the division of the presiding judge of the St. Louis County judicial circuit, Judge Mary E. Ott (Div.7). This motion was related to the judgment she entered on 10/18/23 for the Motion To Disqualify Judge Green For Cause that I filed in my divorce from Mr. Voytas on 09/09/22, which she heard on 10/11/23. (review events listed under 10/18/23 as well as MO Rule 74.06)


  • In addition, I filed an Emergency Motion For Continuance in Judge Green’s division (Div.36) requesting to continue any scheduled proceedings in his division until the presiding judge of the judicial circuit, Judge Mary E. Ott, heard my motion. In the Emergency Motion For Continuance, I again cited the ongoing obstruction of my due process rights, including not having access to the active file and/or case docket which was cause alone not to proceed until that issue was acknowledged and rectified.  


  • I copied Judge Ott’s division clerk, Carol Turner, and Assistant U.S. Attorney for The Eastern District of Missouri, Hal Goldsmith, on the email I sent to the Domestic Relation’s Department of the St. Louis County Judicial Circuit. I reiterated in that email that I was experiencing a deprivation of my Fourteenth Amendment Rights in Judge Green’s division (Div.36) which was the cause for the motion being filed, as those issues remained outstanding. 


  • I emailed a copy of these motions to Attorney Jack Cavanagh, his paralegal, and Judge Green’s Division Clerk, Karrie Cooper, since they were time-sensitive. I let them know that Judge Ott’s Division Clerk, Carol Turner, was in receipt of them as well.

January 16, 2023

  • I did not receive a response from Mr. Cavanagh, or his office, regarding the Emergency Motion to Continue related to the pending Motion to Disqualify Judge Green For Cause in the second lawsuit he was assigned to while he had an outstanding Motion to Disqualify him in this matter. In addition, there was a Motion for Relief From Order or Judgement related to the judgement Judge Ott entered in October 2022 due to the discrepancies between the narrative in the judgment and what had actually been filed and heard in her division.  


  • I emailed Mr. Cavanagh and copied Judge Ott’s division clerk, Carol Turner, stating that if I did not hear back from Mr. Cavanagh prior to the time he told me that he and Judge Green had scheduled for a trial the following day, that I would come to Judge Green’s division at the scheduled time to make sure they didn’t proceed.  


  • In that email, I also addressed Judge Ott’s clerk, Carol Turner, directly about why I had copied her as well. I explicitly stated my concern that Judge Green would recklessly “bulldoze” ahead despite the motions that had been filed because he had a pattern of “going rogue” and being “aggressive with his abuse of power”. At this point the last two settlement conferences since being transferred back to Judge Green’s Division on 08/24/22, had been missed once because of Judge Green’s unexplained absence, and the other due to Mr. Cavanagh’s (reference 01/05/23).

Section V

January 17, 2023

  • Judge Green denied my Continuance Motion and instead told the parties that he would making a judgment on the motion related to his criminal misconduct, filed in Judge Ott’s Division as the presiding judge of the judicial circuit.


  • This was not appointed to him by an administrative judge. The reason my Emergency Motion For Relief From Judgement or Order In Accordance With Missouri Rule 74.06 was filed in Judge Ott’s Division (Div.7) was because it was regarding her judgment following a 10/11/22 hearing of my Motion to Disqualify Judge Green for Cause. As previously noted, Judge Ott’s judgment did not even acknowledge that I filed pleadings, exhibits, and gave oral motion during hearing, related to the intentional obstruction of my due process rights by Judge Green, Mr. Cavanagh and Mr. Voytas. This prevented resolution to those issues, which had to be remedied in order to proceed with litigation in any judge’s division.  


  • The transcript reflects that on 01/17/23 I told Judge Green I did not feel safe proceeding in his division and was objecting to engaging in further litigation in his division that day due to the ongoing pattern of the intentional obstruction of my Fourteenth Amendment Rights . I was forced to proceed, and security was called to the court as a result of me expressing my concerns. Subsequently, there was no option for me to do anything but be present for it.  


  • Nothing about what was said during the hearing would indicate that anything occurred by my own consent when I was asserting my Fourteenth Amendment Rights were being intentionally obstructed.  


  • In the certified transcript of the proceedings held in Division 36 on 01/17/23, page 4, lines 12-25, Judge Green stated:


  • “Also, the Court has brought security into the courtroom for a number of different reasons. Ms. Ojeda has said that she doesn't feel safe. And so therefore, they’re here, not only for her safety, but also Ms. Ojeda, the problem with representing yourself is -- and you've insisted to do it for over a year now in this case -- is that you don't know the procedures, you don't know the law and you think that the Court should run at your whim and it does not. And so, they're here to make sure that you're not out of order, that you're safe, and that you don't disrupt these proceedings. If you do, then -- and I find you in direct contempt, then one of the sanctions can be that you'll be taken into custody and transferred across the street. Do you understand that?”


  • In the certified transcript of the proceedings held in Division 36 on 01/17/23, page 8, lines 13-22, I stated to The Court:


  • “The issue, Your Honor, is that everything that is happening in this courtroom is based on obstructions of due process, distortions of law, distortions of what my arguments are, even what was just said, about what happened at that disqualification hearing. And that's an uncomfortable discussion to keep going with. When I say I feel unsafe, I want to clarify that it's not because I think you're going to physically harm me. It's because I feel like my Fourteenth -- I know, my Fourteenth Amendment rights have intentionally been obstructed.”  *and this is precisely what occurred that day- and under the threat of detainment in St. Louis County Jail.  


  • Nothing in the transcript suggests that I consented to a judgment that day. I was forced to be present for a trial that was proceeding despite me formally notifying the presiding judge of the judicial circuit that I didn’t even have access to the court file or the ability to have my pleadings recognized in Judge Green’s division. Following a hearing about those issues in Judge Mary E. Ott’s division on 10/11/22, a judgment was entered which concealed that those issues had even been reported to her which was why I filed an Emergency Motion For Relief From Judgment or Order In Accordance With Missouri Rule 74.06 in her division and a corresponding Emergency Motion For Continuance in Judge Green’s division (see events listed under 01/13/23).


  • In the certified transcript of the proceedings held in Division 36 on 01/17/23, Judge Green asked about whether the parties wanted to give a real estate commissioner the power to determine the sales price of the home. On page 82, lines 4-9, it is evident that I was not consenting to a partial judgment that ordered a real estate commissioner to proceed in advance because my response to him was:


  • “You know, it's -- so much depends on knowing what comes out of this judgment.” 


  • I couldn’t decide what the minimum amount I could afford to sell my primary residence was without knowing what Judge Green entered in a final judgment identifying what the parties' liabilities and assets were and how the court divided them upon divorce. I couldn’t determine what my financial situation was or what amount of money I had to relocate with my sons, who I am the sole custodian and provider for, in order to establish a new primary residence.

January 25, 2023

  • I was copied on an email that Attorney Jack Cavanagh sent to Judge Green which had attached to it a Motion to Correct and Amend Order and Judgment Regarding Commissioner’s Powers. The motion referred to a judgment that Mr. Cavanagh stated in the pleadings was entered on 01/23/23 regarding the powers of the real estate commissioner.


  • I had no idea what “order and judgement” Mr. Cavanagh’s motion was referring to because the parties were not in Judge Green’s division on 01/23/23, nor had they had a hearing regarding proceeding with a sale of the home in advance of the court identifying and dividing the parties' marital assets and liabilities. It was unclear how this judgement came to be when the parties didn’t have a judgement which identified what the parties' marital liabilities and assets even were yet, however the judgement was being presented as if it had been entered with the consent of the parties.


  • I “replied all” to Mr. Cavanagh’s email and addressed Judge Green directly in my response. I stated in my email that if an order and judgment had been entered on 01/23/23 as Mr. Cavanagh’s motion suggested, I was not in receipt of it. Neither Judge Green or Mr. Cavanagh ever responded. 

January 26, 2023

  • I sent Mr. Cavanagh another email and copied his paralegal’s email address as well, to assert again that I was not in receipt of the order and judgment he referred to in his Motion to Amend that he emailed to Judge Green and I the day prior.Mr. Cavanagh’s paralegal responded by email and attached the judgment Mr. Cavanagh was referring to in his Motion to Amend as being entered by the court on 01/23/23.


  • The Order and Judgment Regarding Commissioner’s Powers attached to that email was materially fraudulent. It stated that the parties entered into a consent judgment to sell the marital home in advance of the court entering a judgment identifying and dividing the parties' marital liabilities and assets, including The Parties’ equity in the marital home.


  • The judgment, which was unsigned by either of the parties, assigned a list of extraordinary powers to real estate commissioner, Attorney Bob Hamilton. It stated that we agreed that Mr. Hamilton could evict either of the parties for non-compliance, which didn’t make sense as Mr. Voytas had already purchased a new primary residence, since he is a high net-worth individual who can make large all-cash purchases of real estate.  


  • The only people living in the home at that time were my teenage sons and me, so a threat of eviction from our co-titled former marital home would only impact us. I required financing that I could not obtain without a marital property settlement agreement, which was one of the primary issues in the case, aside from the ongoing obstruction of my due process rights, which was evident even in how I came to find out a judgment had even been entered by Judge Green on 01/23/23 (see events listed under 01/25/23).  


  • This served to create a scenario in which Mr. Voytas could have us “evicted” by citing my contempt of a judgment that he and the perpetrators could say that I consented to, when they knew that I did not consent, nor would I have which is why they had to proceed via fraud.  


  • I was not asked to verbally consent to a partial judgment with these terms in Judge Green’s division on 01/17/23, let alone sign one, and yet Judge Green entered it anyway claiming the judgment was entered into by consent on 01/23/23 (see events listed under 01/17/23).  


  • I did not verbally consent to proceeding with the sale of the home in advance of the court's identification and division of the parties' marital liabilities and assets, nor did I sign a consent order or judgment when Judge Green dismissed the parties from his division on 01-17-23. Judge Green entered it anyway claiming the judgment was entered into by consent on 01/23/23 (see events listed under 01/17/23).  


  • This was not an outcome I could have predicted (see events under 01/17/23) given the fact we were supposed to be identifying and dividing the property so a final judgment, known as a marital property settlement agreement, could be entered, not holding a hearing about selling the parties' property in advance of even identifying it.


  • Based on the motion filed by Mr. Cavanagh on Mr. Voytas’s behalf on 08/23/22, which was the cause of the case being transferred back to Judge Green’s Division on 08/24/22, they wanted the court to proceed with “evicting” my sons and I because they claimed I was in “breach of contract”. They were trying to achieve the same thing, only make it look like I consented to it since Missouri law didn’t provide for it based on the fact the court still hadn’t identified and divided the parties' marital liabilities and assets.

January 30, 2023

  • I emailed the division of Judge Mary E. Ott, the presiding judge of the judicial circuit, whose clerk, Carol Turner, I had previously corresponded with via email on 01/13/23 and again on 01/16/23 regarding the Emergency Motion For Relief From Judgement or Order In Accordance With Missouri Rule 74.06 filed in Judge Ott’s Division at that time and the Emergency Motion For Continuance I filed in Judge Green’s division prior to the events which occurred in his division on 01/17/23 (see events listed under 01/17/23).  


  • In my email, I told Judge Ott’s clerk, Carol Turner, that I wanted to know what the soonest available dates were for Judge Ott to hear the Emergency Motion For Relief From Judgement or Order In Accordance With Missouri Rule 74.06 previously filed in her division on 01/13/23. I let Ms. Turner know that I had previously come to the division on 01/17/23 to try and secure an available hearing date, after emailing her and Mr. Cavanagh the day before on 01/16/23 regarding my concern that Judge Green and Mr. Cavanagh would try to recklessly move forward despite the motion I filed related to their intentional obstruction of my Fourteenth Amendment Rights, as part of a white-collar crime involving fraud and violations of Federal Civil Rights Code. 


  • I let Ms. Turner know that when I attempted to speak with her regarding Judge Ott’s schedule in Division 7 on 01/17/23, when court was not in session, that I was followed by two security guards and a bailiff to her division who prevented me from being able to secure a hearing date. I told her that I had an audio recording of the incident, which took place in Judge Ott’s Division on 01/17/23, which would correspond with footage that would have been captured by The Court’s security cameras. I told Ms. Turner what the approximate times and locations within the courthouse that security cameras would have captured what took place on 01/17/23 as I walked to Judge Ott’s division, what took place in the division itself between two security guards, a bailiff, and me, and afterwards as I was followed back to Judge Green’s division, who was attempting to make a ruling on my Emergency Motion For Relief From Judgement or Order In Accordance With Missouri Rule 74.06 that was not filed in his division, and was regarding his criminal misconduct (see events listed under 01/17/23). It was precisely the kind of reckless behavior that I told her I was concerned would happen that day in my email to her and Attorney Jack Cavanagh on 01/16/23.  

January 31, 2023

  • I emailed the division of Judge Mary E. Ott, the presiding judge of the judicial circuit, whose clerk, Carol Turner, I had previously corresponded with via email on 01/13/23 and again on 01/16/23 regarding the Emergency Motion For Relief From Judgment or Order In Accordance With Missouri Rule 74.06 filed in Judge Ott’s division at that time and the Emergency Motion For Continuance I filed in Judge Green’s division prior to the events which occurred in his division on 01/17/23 (see events listed under 01/17/23).  


  • In my email, I told Judge Ott’s Clerk, Carol Turner, that I wanted to know what the soonest available dates were for Judge Ott to hear the Emergency Motion For Relief From Judgment or Order In Accordance With Missouri Rule 74.06 previously filed in her division on 01/13/23. I let Ms. Turner know that I had previously come to the division on 01/17/23 to try and secure an available hearing date, after emailing her and Mr. Cavanagh the day before on 01/16/23 regarding my concern that Judge Green and Mr. Cavanagh would try to recklessly move forward despite the motion I filed related to their intentional obstruction of my Fourteenth Amendment Rights, as part of a white-collar crime involving fraud and violations of Federal Civil Rights Code. 


  • I let Ms. Turner know that when I attempted to speak with her regarding Judge Ott’s schedule in Division 7 on 01/17/23, when court was not in session, that I was followed by two security guards and a bailiff to her division who prevented me from being able to secure a hearing date. I told her that I had an audio recording of the incident which took place in Judge Ott’s Division on 01/17/23, which would correspond with footage that would have been captured by the court's security cameras. I told Ms. Turner what the approximate times and locations within the courthouse that security cameras would have captured what took place on 01/17/23 as I walked to Judge Ott’s division, what took place in the division itself between two security guards, a bailiff, and myself, and afterwards as I was followed back to Judge Green’s division, who was attempting to make a ruling on my Emergency Motion For Relief From Judgement or Order In Accordance With Missouri Rule 74.06 that was not filed in his division and was regarding his criminal misconduct (see events listed under 01/17/23). It was precisely the kind of reckless behavior that I told her I was concerned would happen that day in my email to her and Attorney Jack Cavanagh on 01/16/23. 


  • Ms. Turner responded to the email I sent to her on 01/31/23 the same day. Rather than responding in the same email thread as the one I sent her earlier that day, Ms. Turner responded in an old email thread between she, Mr. Cavanagh and I from 01/16/23. She provided dates that Judge Ott would be available for a hearing and I responded telling her that I would find out which one was preferable to Mr. Cavanagh and then file a Notice of Hearing.  


  • After copying Mr. Cavanagh on Ms. Turner’s email response providing Judge Ott’s availability for a hearing for my Emergency Motion For Relief From Judgement or Order In Accordance With Missouri Rule 74.06, Mr. Cavanagh sent an email response to Ms. Turner and I to say there was no need for a hearing on my motion. Mr. Cavanagh cited that Judge Green already entered an Interim Judgement regarding the sale of the house. The judgement Mr. Cavanagh was referring to was the one that Judge Green entered fraudulently stating it was a consent judgement when it clearly was not. 


  • I replied to Mr. Cavanagh’s response regarding Judge Ott’s availability to hear my motion, with Ms. Turner copied, to tell him that he should never again try and speak on my behalf regarding whether the court needed to hear a motion that I filed. In that response I also referenced the incident involving security guards in Judge Green’s Division on 01/17/23.

February 1, 2023

  • Mr. Cavanagh responded to the last email I sent to him the day prior on 01/31/23, with Ms. Turner copied, citing that he could not comply with my “demand” the day prior because he had an emergency surgery.  


  • I responded to Mr. Cavanagh to remind him that the day prior he tried to obstruct my ability to schedule a time to have my Emergency Motion For Relief From Judgement or Order In Accordance With Missouri Rule 74.06, which I filed on 01/13/23 and provided him with a copy (see events listed under 01/13/23), and so whatever urgent medical procedure he had the day when he sent that email was irrelevant. I told him to respond to me by 1pm that with his preference from the dates provided by Ms. Turner or I would choose one myself.  


  • Mr. Cavanagh responded that he would be available for a hearing in Judge Ott’s Division on 02/22/23. Note that prior to Mr. Cavanagh’s response, Ms. Turner sent a response of her own, reiterating that a hearing had not been scheduled yet but in her response she deleted one of my prior responses which referenced the incident involving security guards on 01/17/23.  


  • I emailed Mr. Cavanagh and Ms. Turner with a copy of the Notice of Hearing that I filed with The Court for 02/22/23 in Judge Ott’s Division (Div. 7).  

February 6, 2023

  • Mr. Hamilton sent an email to Mr. Cavanagh and I requesting a copy of “the complete divorce judgement to review the terms regarding the house”. Mr. Cavanagh responded and told Mr. Hamilton there was not in fact a complete divorce judgment, and therefore nothing to indicate what assets and liabilities The Court identified from the parties' marriage, and how it would be distributed.  


  • Mr. Cavanagh’s own admission about the parties not having a final judgment regarding their marital liabilities and assets contradicted his claims in previous motions, which at this point I had been claiming were fraudulent for a year and a half. That’s why when Mr. Cavanagh filed a motion on 08/23/22 in the court division the case was supposed to have been transferred to, the judge in that division, Judge Mondonna Ghasedi (Div.43) ordered the case to be transferred back to Judge Green. At that time Mr. Cavanagh was motioning the court to evict my sons and I from the marital home and pay retroactive “rent” to Mr. Voytas for our co-titled home because I was in “breach of contract”.

February 16, 2023

  • I met Attorney Bob Hamilton for the first time at an in-person meeting between the two of us and his assistant, Blake Sanders, after he contacted the parties via email on 01/30/23 to say he had been appointed by Judge Green. During that meeting, as evidenced in our recorded conversation, the following occurred:


  • Mr. Hamilton stated that he was receiving communications from Mr. Cavanagh regarding selling the home before he was in receipt of an order or judgment from Judge Green appointing him, and I confirmed that was the case for me as well (audio/transcript 02:06 - 03:07 minute-mark). *for full recording of entire conversation click here


  • Mr. Hamilton said that even he, as an attorney, could not access the case file and described it as “like getting into Fort Knox” (audio/transcript 03:07- 03:28 minute- mark).


  • Mr. Hamilton said that Judge Green contacted him with “a note” asking him what kind   of powers he would like Judge Green to enter, when he hadn’t received a copy of an order or judgment, like the one Judge Green claimed the parties entered into by consent (audio/transcript 02:34 - 02:53 minute-mark).


  • Mr. Hamilton said that he told Judge Green that he needed a copy of a divorce judgment because this was “not normal” since the final divorce judgment says “who got what” which is necessary for the title company upon sale (audio/transcript 03:53 -   04:56 minute-mark). *Note this is the same document that had been the underlying issue for the entirety of the divorce proceedings- Mr. Voytas did not want the court to enter that judgment according to Missouri law because it would be enforceable, and pre- and post-nuptial agreements are not the equivalent of the court's final divorce judgment.


  • When Mr. Hamilton asked about the parties' post-nuptial agreement, I told him that the parties disagreed because I requested a marital property settlement, which was the same document that Mr. Hamilton was referring to as part of a “complete divorce judgment" (audio/transcript 05:31-05:53 minute-mark).


  • I informed Mr. Hamilton that I wanted to sell the home at the time of divorce, but that Mr. Cavanagh and Mr. Voytas were preventing the court from entering a property judgment. I stated they claimed the court didn’t need to participate in the division of the parties' liabilities and assets and just needed to enter a divorce decree, resulting in the ongoing litigation preventing a sale (audio/transcript 07:25-07:52  minute-mark).  


  • I provided Mr. Hamilton a copy of my outstanding Emergency Motion For Relief From Judgment Or Order In Accordance With Missouri Rule 74.06 filed on 01/13/23 in Judge Ott’s Division. I told him that there was a hearing scheduled for 02/22/23 that would impact any other step that could be taken forward (audio/transcript 07:52 -08:23 minute-mark).  


  • Mr. Hamilton told me that his realtor could sell the house and the court keep the funds while the parties continued to litigate the matter. I informed him that would cause my sons and I to be homeless because I had to be able to identify my liabilities and assets (audio/transcript 08:45-08:55 minute-mark).


  • I explained in detail to Mr. Hamilton that I wanted to sell the marital home since the time the divorce petition was filed, but that I couldn’t do it without a legally enforceable marital and that my ex-husband, Attorney Richard A. Voytas, was doing everything in his power to prevent that, weaponize the legal system, and “financially stra property settlement agreementngle” me in the process (audio/transcript 13:25-16:02 minute-mark).


  • I told Mr. Hamilton that I had been clear about needing a marital property settlement all along, and Mr. Cavanagh and Mr. Voytas were abusing the legal system to “run me ragged and financially drain me”. In addition, I told him that I had two teenage sons who I was the sole custodian and provider for from a prior marriage, and if he proceeded without that document it would render us homeless. I also informed him that the mortgage lenders I had spoken to said they had never seen anything like this (audio/transcript 16:29-17:32 minute-mark).

February 22, 2023

  • There was a hearing scheduled to take place in the division of the presiding judge of the St. Louis County judicial circuit, Judge Mary E. Ott, for my Emergency Motion For Relief From Judgement Or Order In Accordance With Missouri Rule 74.06, which was filed on 01/13/23. This was the motion that Judge Green tried to make a ruling on himself on 01/17/23 despite the fact the motion was not filed in his division, as it was related to outstanding accusations that he was engaged in criminal misconduct and violations of Federal Civil Rights Code.  


  • Attorney Bob Hamilton, who I met with on 02/16/23, was present since he was appointed in a fraudulently entered order and judgment entered by Judge Green on 01/23/23 (see events listed under 01/17/23, 01/25/23, and 02/16/23). I asked him to attend the hearing when we met on 02/16/23, since during our recorded conversation that day he admitted that there wasn’t a consent judgment entered into by the parties giving him the authority to proceed with a sale of their former marital home in advance of the court entering a final judgment identifying and dividing the parties' marital liabilities and assets. I told him that it would be helpful for him to share the same things he shared with me on 02/16/23, to affirm to Judge Ott that the issues he was having were consistent with those I first began reporting to administrative judges in April 2022. 

 

  • Links


  1. Emergency Motion For Relief From Judgment Or Order In Accordance With Missouri Rule 74.06 filed by me in Judge Ott’s division on 01/13/23.
  2. Associated Exhibit Book filed with the motion in Judge Ott’s Division on 01/13/23.
  3. The certified transcript of the hearing held in Judge Ott’s Division on this day, 01/22/23.
  4.  Audio recording that corresponds with the certified transcript of the hearing on 01/22/23. 
  5. Judgment entered by Judge Ott two months after the hearing on 4-18-23, however I did not receive a notification when it was entered and received a copy via email from Mr. Hamilton and Mr. Cavanagh on 04/24/23, which was the night before the hearing that Mr. Hamilton scheduled in Judge Green’s division during the period of time this motion was pending a judgment after this hearing (see events listed under March 21, 2023).   

March 21, 2023

  •  Bob Hamilton’s assistant emailed The Parties a formal letter he wrote explaining why he filed a motion suggesting that the issue with proceeding with the home sale was anything other than the fact that there was not a consent judgement to proceed with selling it in advance of The Court identifying and dividing The Parties’ liabilities and assets with a Marital Property Settlement Agreement. He mentioned the pending Motions to Disqualify Judge Green For Cause which stilll needed to be ruled on by The Presiding Judge of The St. Louis County Judicial Circuit, Judge Mary E. Ott, but asserted that those should not interfere with proceeding with the sale.  


  • Despite Mr. Hamilton acknowledging the problem with access to the case file and the fact there was not a consent judgement agreed upon by The Parties (see 2-16-23 audio/transcript), he attempted to give the appearance that I was simply being difficult and non-compliant. This paved the way for Judge Green to later create additional orders based upon the pleadings of an attorney who was supposed to be serving as a third-party neutral, but in reality was lying that I was non-compliant with a judgement he knew simply did not exist.  


  • Links


  1.   Email sent to parties by Bob Hamilton’s Assistant
  2.   Letter Attached to Email from Bob Hamilton 
  3.   Bob Hamilton's Motion which in itself indicates there was not a consent judgement entered into by The Parties requesting the home be sold prior to The Court identifying and dividing liabilities and assets in a Marital Property Settlement Agreement. That is the reason why he was asking The Court to enter orders providing him with the authority to proceed, only based on the fraudulent pretense that I was violating a judgement which I consented to, when I did not.  
  4. Corresponding Notice of Hearing which Bob filed despite knowing that I had pending Motions to Disqualify Judge Green For Cause, had been provided a copy of the pending motions which indicated there was ongoing obstruction of my due process rights, and other issues which he himself previously acknowledged during our first meeting (see 2-16-23 audio/transcript of first meeting).   

April 24, 2023

  • I received an email from Bob Hamilton which forwarded an email he received from Mr. Cavanagh on this same day, which had attached to it a judgement from the “hearing” held in Judge Ott’s Division on 02/22/23 for my Emergency Motion For Relief From Judgement Or Order In Accordance With Missouri Rule 74.06.  


  • This was a total shock to me given the fact that Judge Ott told Mr. Cavanagh, Mr. Hamilton, and I, during what was supposed to be a hearing for my motion, that she would not be hearing the motion that day because she first needed to determine if she was “procedurally postured” to hear it, and would get back to The Parties once she determined how to proceed (see 02/22/23 transcript).


  • Refer to the events listed under 02/22/23 and the social media reel used to summarize Judge Ott’s participation in her colleague’s crime in two separate judgements which were blatantly fraudulent when juxtaposed to the audio/transcripts from her division on both 10/11/22 and 02/22/23 (refer to this link for transcripts and audio of each hearing, and the subsequent materially-fraudulent judgements, which expose Judge Ott’s participation in this crime in her role as The Presiding Judge of The St. Louis County Judicial Circuit).  


  • This email was sent to me by Mr. Hamilton on 04/24/23, which was the night before the hearing that Mr. Hamilton scheduled in Judge Green’s Division for 04/25/23, for a motion he filled on 03/21/23, despite the fact that he was present for the 02/22/23 hearing when Judge Ott said she would not hear my motion until she determined whether she was “procedurally postured” to, and that she had an outstanding judgment to make in the second matter Judge Green was assigned to in August 2023, forcing me to file yet another Motion to Disqualify him for cause, which she said she needed to rule on first- and still hadn’t as of this date (see 02/22/23 transcript).  


  • Mr. Hamilton was aware that I could not participate in any further litigation in Judge Green’s Division when I couldn’t even have a motion recognized by him, didn’t have access to the case file, and Judge Green was committing fraud which was extensively documented with evidence in the outstanding motions filed in Judge Ott’s Division which Mr. Hamilton was in receipt of (see events listed under 02/16/23). However, according to the judgement Mr. Hamilton forwarded me related to the hearing that was supposed to be held in Judge Ott’s Division on 02/22/23, that she said she needed to postpone because she needed to look into whether she was “procedurally postured” to hear it, something altogether different took place. Judge Ott simply engaged in the precise method of fraud and intentional obstruction of my Fourteenth Amendment Rights that required me to file an Emergency Motion For Relief From Judgement Or Order In Accordance With Missouri Rule 74.06 to begin with. 


  • This pattern of the perpetrators trying to stack litigation in such a way that I could not receive and respond to a judgement prior to the next fraudulent move they made in the litigation is evident in both this matter, as well as the second lawsuit filed against me by my sons’ and my domestic abuser, Victor A. Ojeda, after Judge Green and St. Louis County Court’s Administrative Judges became aware that I recognized a Civil Rights Crime was being committed.

May 2, 2023

  • Attorney Bob Hamilton’s assistant forwarded an email with a letter attached in which he referenced an Order and Judgment from the hearing he scheduled for 04/25/24 when I had two Motions to Disqualify Judge Green For Cause outstanding and told him that nothing should be scheduled until those were heard, as they included issues surrounding the obstruction of my due process rightd in Judge Green’s Division (see events listed under 02/16/23, 02/22/23 and 04/23/23). During our meeting on 02/16/23, that was recorded, Mr. Hamilton admitted that he knew that a consent judgment resolving The Parties’ marital liabilities and assets, including the sale of the home, did not exist. Mr. Hamilton also admitted he couldn’t access our case file because it was “like getting into Fort Knox” and that I also did not have access to it and was only receiving documents that Mr. Voytas’s Attorney, Jack Cavanagh, would send me (see events listed under 02/16/23).


  • The Order and Judgment Mr. Hamilton’s assistant emailed me is based upon Mr. Hamilton filing pleadings which made it appear that I had been non-compliant with a judgment which does not exist, he admitted himself does not exist, and was intended to further create an extensive court record built upon material fraud.  


  • In the letter attached to the email, Mr. Hamilton stated that he would no longer directly speak to me, and me alone, so that nothing could be “misconstrued”. It is apparent that Mr. Hamilton was actually concerned that I would collect evidence that would disprove the record they were trying to create so he needed The Court’s Record, based on fraud, to “speak for itself”.  


  • Also attached to the email was a copy of The Order and Judgment entered on 03/28/23 after they proceeded with a hearing despite Bob Hamilton knowing that I could not be present, nor could even respond yet given all of the outstanding issues related to Judge Green’s behavior revolved around intentional due process obstruction and fraud that were unresolved in The Presiding Judge’s Division. The order and judgment provided Mr. Hamilton with a court ruling which would give an appearance that based on the material facts of the case, and the orders and judgments filed, that he had legal authority to do all of the things he knew he didn’t have because the consent judgment he was pretending led to his appointment, did not exist.  


  • In that same Order and Judgment, it is suggested that there are “other people” living in the house that must also comply or “be evicted” when Judge Green, Mr. Hamilton, Mr. Cavanagh, and my sons’ former step-father Mr. Voytas, were aware those “other people” were the two minor children who I have been the sole custodian and financial provider for since 2018. They were threatening to “evict” my sons and I from a home which I purchased with Mr. Voytas using funds from the sale of our prior home, and it was co-titled. Their basis for the threat of our eviction was that I was non-compliant with a consent judgment that did not exist and Mr. Hamilton was caught on tape admitting that he knew it did not exist (see 02/26/23).  


  • The Order and Judgment also said that Mr. Voytas and Mr. Cavanagh’s Motion to Correct and Amend Order and Judgment Regarding Commissioner’s Powers (see events listed under 01/25/23) was denied and that Mr. Voytas would be paying for the utilities and home insurance- to be reimbursed when the sale of the home closed. However, Mr. Voytas had not paid for any costs associated with the home since the parties separated in June 2020, nor did he begin paying for them at any point during the litigation. The only purpose of Judge Green including that stipulation in the Order and Judgment he entered on 01/23/23, fraudulently claiming it was by consent of the parties, was to give the appearance Mr. Voytas had been the one responsible for the financial liabilities associated with the home while the divorce proceedings persisted, and therefore required reimbursement. In reality, it was precisely opposite as was the case for everything else being claimed at this point. The perpetrators consistently engaged in the psychological torture of my teenage sons and I, by engaging in a tactic known as “gas-lighting” and they were doing it by using the justice system, via fraudulent court orders and judgments, to create the greatest amount of psychological, emotional, and financial harm possible to us.  


  • By the perpetrators filing additional motions, orders and judgments on top of the ones I was already reporting were materially fraudulent, it served to create chaos and confusion to make it even more difficult for me to get the criminal relief my sons. and I so desperately needed at this point after nearly two years of being victims of this crime.  

Section VI

May 8, 2023

  • Email from me to Attorney Bob Hamilton in response to an email he sent the day before in which he continued to suggest we proceed with the sale of the home, despite knowing there was never a consent judgment entered that would give him the legal authority to proceed on the basis that I was in contempt of it. Instead, he was trying to move forward on orders Judge Green entered to make it appear that I was violating terms I consented to in a judgment that he knew did not exist. This helped attempt to bury the evidence further that the consent judgment upon which Attorney Bob Hamilton was asserting his authority to proceed, simply did not exist, and he was aware of it as of the first meeting he held with me on 02/16/23 which was recorded. By compounding upon the fraudulent pleadings being filed in the case, Bob Hamilton made it that much more challenging, and emotionally and psychologically taxing, to unwind the evidence of the crime my sons and I have fallen victim to involving this group of St. Louis County judges and attorneys. In this email I also reaffirmed to Mr. Hamilton that by proceeding based on fraud he was placing my sons in harm’s way.


  • Mr. Hamilton responded to my email the same day and in his response he told me that I was the cause of the harm brought upon my sons and I, that I was “not acting like a rational person”, and gas-lighted me on the highest level knowing there was no consent judgment entered into by the parties to begin with and HE was furthering the crime. In his response it is evident that he engaged in a tactic of “Deny, Attack, Reverse The Role of Victim and Offender” (aka DARVO) to try and cause the greatest detriment to my mental and emotional state because I was not bending in the truth the way the perpetrators needed me to.  


  • In the email exchange Mr. Hamilton said he had no choice but to file an Affidavit to Evict, knowing that the order he cited as the legal cause to file it, is based on fraud because I never signed a consent judgment agreeing to execute the home sale without a marital property settlement agreement. In fact, I specifically refused doing just that which is reflected in every hearing transcript, motion filed by me, and the email correspondence between all of the parties involved in the litigation. 


  • My final response to Mr. Hamilton’s email reply sent this same day can be viewed here.

May 25, 2023

  • There was a hearing held in Judge Green’s division for Attorney Bob Hamilton’s motion for the court to evict my sons’ and I from our home, based on his false claims that I was being non-compliant with the terms of a consent judgment—that simply did not exist and he was aware. I was present for the hearing and during it I stated that there never was a consent judgment entered in the case.  


  • Judge Green threatened me with jail at one point during the hearing in an attempt to further coerce me into not stating the truth about the material facts of the case because those facts were a direct contradiction to the fraud he was committing. He specifically mentioned my sons, who he knew I was the sole custodian and provider for, stating that they would not have a parent if he put me in jail. Neither Judge Green, Attorney Bob Hamilton, or Mr. Voytas’s representation, Jack Cavanaugh, were able to provide any kind of rational response to me saying the judgment they were suggesting I entered into by consent didn’t exist.  


  • Links


  1. Certified Transcript of 5/25/23 Hearing 
  2. Corresponding Audio of 5/25/23 Hearing


  • On page 21, lines 7-25, of the transcript from the 05/25/23 hearing, Judge Green acknowledged that all parties had signed an agreement to allow Attorney Bob Hamilton access to view the home and then said he would be “adding another paragraph” to the already-signed document. Judge Green stated that the paragraph he was adding, which was not agreed to or consented upon by the parties when the document was signed, was to ensure that no one could distort that everyone was in agreement to the orders and judgment he entered on 04/28/23. However, as evidenced by the audio and transcript from that hearing, Judge Green announced he was adding that paragraph after the document was signed, knowing that what he was claiming in that paragraph was precisely opposite of what I affirmed during the hearing about never having entered into a consent judgment regarding my marital property with Mr. Voytas.  


  • Later the same day I emailed Judge Green, Attorney Bob Hamilton, and Attorney Jack Cavanaugh a copy of the writ petition I filed with The Missouri State Court of Appeals (see links below).  A “writ” is a unique, and rarely granted motion, filed with the higher courts in situations that require extreme judicial relief if they meet very specific criteria. These motions are most often denied, which was what happened to the one I filed as it was denied without hearing the very next day (05/26/23). The higher courts are not required to provide an explanation or “findings of fact and conclusions of law” related to the denial of a writ. Note that because my writ petition was drafted prior to the day it was filed (05/25/23), nothing that transpired during the May 25th 2023 hearing could be included. I knew by this point in time that what was needed was federal criminal relief, which is why I also submitted these documents to The U.S. Attorney’s Office for The Eastern District of Missouri. 

 

  • Links


  1. Petition For Writ Of Prohibition filed on 05/25/23 and denied on 05/26/23. 
  2. Exhibit Book Corresponding with Writ of Prohibition filed on 05/25/23.


  • The denial of the writ is the only entry in the court record related to this case that can be accessed by me, or the public, because the case file has been kept under seal by Judge Green. The ongoing issue of my access to the official court record related to this matter is an issue mentioned throughout the hearings and motions. Even in my first meeting with Attorney Bob Hamilton on 02/16/23, he referred to gaining access to the file like “getting into Fort Knox” (for audio click here). Also there are email exchanges between myself and U.S. Attorney Hal Golsmith from The Eastern District of Missouri’s Office in St. Louis, that date back to the summer of 2022 in which we discuss the ongoing issue with access to the file, which he also admits at the time is filed at a level of security he is “not familiar with”. 

July 6, 2023

  • Real Estate Attorney Bob Hamilton’s assistant, Blake Sanders, emailed me copies of a “Motion and Affidavit For Eviction” and a Notice of Hearing scheduled for 07/26/24. Mr. Hamilton continued to assert in his pleadings that I had been non-compliant with the terms of a consent judgment, which he knew did not exist according to the audio recording and transcript of our first meeting on 2-16-23.  


  • The same day I responded by email to Mr. Hamilton’s assistant (Blake Sanders) regarding the motion filed by Mr. Hamilton to evict my sons and I from our home saying that I needed time to respond and set a mutually agreed-upon date for the hearing. There is no reply addressing those concerns and as of 05/02/23 Mr. Hamilton said he would no longer directly communicate with me because it could “distort the record”.  

July 7, 2023

  • Real Estate Attorney Bob Hamilton forwarded the parties a letter related to the motions he filed on 7/6/23, and continued to attempt to create formal documents which gave the impression that he was appointed as the result of a consent judgment, which he knew did not exist.

July 26, 2023

  • Attorney Bob Hamilton’s assistant, Blake Sanders, emailed me an Order and Judgment of Eviction based on Attorney Bob Hamilton’s statement filed with the court, which continued to assert that I had been non-compliant with a consent judgment, which he knew did not exist. The judgment gave my sons and I five days to be out of the home or else our belongings would be taken by Mr. Hamilton and placed in storage for two months which I would be expected to pay, and if at the end of those two months weren’t retrieved, would be disposed of.  


  • Between this judgment entered by Judge Green on 7/26/23, and the judgment entered in the second matter involving my sons’ and my known domestic abuser, Victor A. Ojeda on this very same day (see second case chronology), it was evident that Judge Green’s plan was to attempt to separate my sons from me after seven years of being their sole legal/physical custodian and sole financial provider, slander my character, seize my only asset (our home) and subject us to the precise kind of domestic abuse which Judge Green knew we had been subject to for many years (per the court's own records).  


  • What is particularly disturbing is that Judge Green knew that due to ongoing issues with Mr. Ojeda violating long-standing orders in place to prevent our further abuse, there were unique concerns surrounding my sons’ and my relocation from our primary residence. Judge Green’s knowledge of my history of being subject to domestic abuse, and status as a sole custodian and sole financial provider is evident in the transcript of our first hearing on 10/19/21, on page 6, lines 13-40, and page 7, lines 1-15. 


  • Judge Green used Mr. Ojeda, and the lawsuit filed by him shortly after I filed a formal motion regarding Judge Green’s criminal misconduct in my divorce from Attorney Rick Voytas, as a weapon that he could hide behind. Judge Green did this by creating fraudulent case records, built upon materially-false facts, which contradict the court's own record related to Mr. Ojeda’s history of domestic abuse in one case, and the existence of a consent judgment between Mr. Voytas and I regarding our marital property in another. 

September 8, 2023

  • Email from me to Assistant U.S. Attorney Hal Goldsmith forwarding Real Estate Attorney Bob Hamilton’s motion filed with the court requesting that he, and Attorney Roseanne Horan in the matter filed by Victor A. Ojeda, be paid money out of funds from the home sale which had just displaced my sons and I (see also Motion for Fees and Discharge). There was not a marital property settlement agreement in place and I was clear that I could not execute the sale of the home until there was. 


  • The justification for my divorce proceedings with Mr. Voytas to be filed under pseudonyms was due to Mr. Ojeda’s ongoing harassment despite a Full Order of Protection being in place. Judge Green knew Mr. Ojeda was my domestic abuser, and knew that he shouldn’t be in receipt of information which would allow for his attorney to coordinate with Mr. Voytas’s litigation pursuits in his divorce matter with me, let alone profit from it.  


  • From this point forward there was no further communication between Mr. Hamilton, Mr. Cavanagh, and I. I never received copies of any closing documents related to the home sale, nor did I know when or where it happened as I never consented to it or signed off on any documents related to it. I never received a final divorce judgment identifying and dividing The Parties Marital Liabilities and Assets, a divorce decree, etc.- but this was not surprising given the fact that I never had access to the active case file and was only being provided documents when the perpetrators selectively chose to share them with me. Now that their crime was complete and the evidence buried under a flurry of fraudulent motions/orders/judgement filed in two cases simultaneously presided over by Judge Green, rendering my sons’ and I homeless and fleeing our known domestic abuser, there was no need to engage in communication with me further.


  • At this time, I was trying to settle my teenage sons into a rental home after staying in a variety of short-term rentals, the address of which I could not disclose publicly. This was due to the fact that as of July 2023 Judge Green was using The St. Louis County Police Department to try and force my sons and I to be subject to the harassment and stalking of our known abuser to The Court, Victor A. Ojeda, citing Judge Green’s materially fraudulent orders and Interim Judgements he was entering in that matter to distract from the crime that began in this case (see chronology of second case involving Victor A. Ojeda).

Litigant on the Loose



contact- anne@litigantontheloose.com


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