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CAUSE NO. 15-03-02527-CV
IN THE INTEREST OF ) IN THE DISTRICT COURT OF
(
ALYSSA MARIE KRAULIS ) MONTGOMERY COUNTY, TEXAS
(
A CHILD ) 418™ JUDICIAL DISTRICT
SECOND AMENDED MOTION TO DISMISS FOR FAILURE TO STATE A
JUDICIABLE CAUSE OF ACTION
This Motion to Dismiss for Failure to State a Judiciable Cause Of Action is brought by
TED KRAULIS, Respondent, who shows in support:
1. Petitioner’s Motion to Modify Parent-Child Relationship filed on June 21, 2018
should be dismissed for failure to state a Judiciable Cause of Action pursuant to
Texas Family Code §156.102(b). In support hereof, attached as Exhibit 1 is
AFFIDAVIT OF THEODORE KRAULIS IN SUPPORT OF SECOND
AMENDED MOTION TO DISMISS FOR FAILURE TO STATE A
JUDICIABLE CAUSE OF ACTION. Such affidavit is incorporated herein as if
recited verbatim.
2. Pursuant to the averments in the aforementioned affidavit, Michelle Kraulis has
engaged in a course of action designed to harass this Movant by making false
accusations, filing frivolous pleadings, and abusing the process of this Court and
of the legal system in general.
3. Attorney's Fees, Expenses, Costs, and Interest
It was necessary for Respondent to secure the services of RICK BRASS, a
licensed attorney, to prepare and prosecute this suit. Judgment for attorney's fees,
expenses, and costs through trial and appeal should be granted against Petitioner
and in favor of Respondent for the use and benefit of Respondent's attorney; or, in
the alternative, Respondent requests that reasonable attorney's fees, expenses, and
costs through trial and appeal be taxed as costs and be ordered paid directly to
Respondent's attorney, who may enforce the order in the attorney's own name.
Respondent requests postjudgment interest as allowed by law.
Therefore Respondent prays that this Court dismiss Petitioner’s Motion to Modify
Parent-Child Relationship, for Attorney’s fees, and for such other and further
relief that may be awarded at law or equity.
SECOND AMENDED MOTION To Dismiss FOR FAILURE TO STATE A JUDICIABLE CAUSE OF ACTION
(ITIO ALYSSA MARIE KRAULIS)Respectfully submitted,
BRASS & MCCOTTER
207 Simonton
Conroe, Texas 77301
Tel: (936) 788-5700
Fax: (936) 788-5701
RICK BRASS
Attorney for Respondent
State Bar No. 02909450
rick@rickbrass.com
Certificate of Service
I certify that a true copy of the above was served on each attorney of record or party in
accordance with Texas Rules of Civil Procedure on August 21, 2018.
Yo 939-4
RICK BRASS
SECOND AMENDED MOTION To Dismiss FOR FAILURE TO STATE A JUDICIABLE CAUSE OF ACTION
(ITIO ALYSSA MARIE KRAULIS)CAUSE NO. 15-03-02527-CV
IN THE INTEREST OF ) IN THE DISTRICT COURT OF
(
ALYSSA MARIE KRAULIS ) MONTGOMERY COUNTY, TEXAS
(
A CHILD ) 4187 JUDICIAL DISTRICT
AFFIDAVIT OF THEODORE KRAULIS
IN SUPPORT OF SECOND AMENDED MOTION TO DISMISS FOR FAILURE TO
STATE
A JUDICIABLE CAUSE OF ACTION
THEODORE KRAULIS appeared in person before me today and stated under oath:
"My name is THEODORE KRAULIS. I am above the age of eighteen years, and I am
fully competent to make this affidavit. The facts stated in this affidavit are within my personal
knowledge and are true and correct.
"T am the Respondent in this case and the father of the child the subject of this suit.
First, the identity of the people named in this affidavit are as follows:
Theodore John Kraulis (hereafter “Ted”) — father of child;
Alison Michele Kraulis (hereafter “Michelle”) — mother of child;
Elizabeth Kraulis (hereafter “Beth”) — my wife, the child’s stepmother;
Alyssa Kraulis (hereafter “Alyssa”) — the child;
Alexia Camfield — (hereafter “Alexia’”) - the counselor
On May 24, 2018, ALISON MICHELE KRAULIS filed a Petition to Modify
Parent-Child Relationship which was unilaterally dismissed by Judge Gilbert on
the basis that the affidavit attached to the Petition to Modify Parent-Child
Relationship does not contain facts adequate to support an allegation as required
by Section 156.102(b) of the Texas Family Code.
On or about June 8, 2018, ALISON MICHELE KRAULIS refiled her suit in the
form of an Amended Motion to Modify Parent-Child Relationship requesting the
current custody, possession and access and child support Order dated December 11,
2017 which gave the exclusive right to me to determine the residence of the child and
to receive child support, together with an Affidavit in support thereof alleging
numerous misconducts on my part against my daughter, ALYSSA KRAULIS, the
majority of which are untrue, inaccurate or taken out of context.
On or about June 21, 2018, ALISON MICHELE KRAULIS filed a nonsuit and order
with prejudice dismissing the Amended Motion to Modify Parent-Child Relationship
and then filed on June 21, 2018 a Motion to Modify Parent-Child Relationship. This
Affidavit is in support of THEODORE KRAULIS’ Second Amended Motion to
Dismiss for Failure to State a Judiciable Cause of Action.
Page 1 of 9 EXHIBIT
if4. Taking the allegations in the Affidavit separately, I state as follow:
1. Michele alleges that in December 2017, Alyssa came to her with a serious cold and
infection that required medical attention which she states that she addressed. On 12/27/18
through Our Family Wizard (hereafter “OF W”) Michele relayed this information to me stating
that the doctor prescribed an antibiotic. Alyssa had been with Michele for the previous 7 days.
She had a cough for a few days before she went to Michele for Christmas on 12/14/17, which
was being treated with children’s cough syrup and there was no fever or other symptoms. See
Exhibit “1” attached hereto. She returned home on 12/28/17 and I continued to administer the
medicine prescribed. See Exhibits 1, 2, and 3. -She also states that I do not address Alyssa’s
medical issues. This is untrue, as will be exhibited below.
Alyssa did not have a yearly physical in 2017 because she saw her doctor, Dr. Wright,
many, many times that year. She has had many meetings with Dr. Wright where he performed
the necessary requirements of a yearly checkup.
Michele Kraulis scheduled a yearly medical checkup for Alyssa for 1/18/18 but Beth
ended up taking Alyssa to the doctor on 1/15/18 instead because she had the flu, and was advised
by the doctor’s office to cancel the 1/18/18 appointment and bring her back for a checkup when
she is feeling better. Michele was advised of this on OFW. See Exhibit 4 attached hereto.
Alyssa was then scheduled for her yearly checkup on 6/25/18.
5. On 1/15/18, when Beth took Alyssa to the doctor for the flu, she was diagnosed with Flu
A. The doctor advised to get her a flu shot over the upcoming weekend, so she would not get Flu
B. Michele was advised of this via OFW on 1/15/18 (Exhibit 4).
Michele replied on 1/15/18 that she will get Alyssa a flu shot that upcoming weekend.
Michele was scheduled to have Alyssa on January 20 and 21, 2018. Alyssa indicated that
Michele never took her to get a flu shot. See Exhibit 5 attached hereto.
6. Yearly checkup Dental Michelle scheduled a dentist appointment for Alyssa for
1/25/18. Alyssa was seen by a different dentist with Ted Kraulis in 2016. The result of her
dentist appointment on 1/25/18 proved that Alyssa’s teeth were very healthy and normal. She
did have one cavity which was repaired.
7. Michele’s allegations that I do not address Alyssa’s medical issues are unwarranted and
unfounded and nothing more than a fishing expedition to attempt to gain leverage for her
modification lawsuit.
8. Michele’s allegations that she discussed Alyssa’s “Poor study habits” with me in hopes
that I would work with her on her weekly tests is outrageous. Alyssa is and continues to be a
straight A student, has never gotten a grade lower than “A” and has excellent classroom
behavior. See attached report cards for years 2016/2017 and 2017/2018 attached hereto as
Exhibits “6” and “7.” I did not respond to her via OFW because of Michele’s antagonistic
emails on 1/1/18 and 1/3/18. See Exhibit “8” and “9” attached hereto.
9. Michele states that I did not provide her with the insurance card and a copy of the policy
information, when in fact, on 1/18/18 when Michele picked up Alyssa, I gave her a large manila
Page 2 of 9envelope containing a printed copy of the policy information together with several lists of In-
Network doctors, clinics, and hospitals. 1/18/18 was the first date that Michele had possession of
Alyssa in 2018.
10. Michele alleges that I did not respond to her OFW message inquiring about Alyssa’s
fever. I did not respond because Michele indicated to me that Alyssa told her that she has been
running a fever. See Exhibit 10 and Exhibit 11 attached hereto.
11. Michelle was provided with an update of Alyssa’s condition via OFW on 1/15/18,
directly after Alyssa’s appointment with the doctor. See Exhibit 12 attached hereto.
12. Michelle alleges that I failed to follow the doctor’s plan for Alyssa’s flu diagnosis, when
in fact I did follow the doctor’s plan. Dr. Wright prescribed ear drops for swimmer’s ear, and I
already had the same drops at home from a previous ear ache prescribed by Dr. Wright. Alyssa
had no fever at the doctor’s appointment. Dr. Wright also said she had a mild case of the flu A.
The side effects of Tamiflu were discussed with Beth. Tamiflu would only shorten the flu by
one day and it will not help her feel better during the first several days. Additionally, it can
cause extreme nausea, which would make her feel worse. He did not call Tamiflu in and told
Beth to keep treating with over the counter cold medicine and Children’s Advil.
In mid afternoon of the same day, I received several calls from Dr. Wright’s office stating
Michele was at the office and demanding to see Alyssa’s medical records. Michele questioned
Dr. Wright and insisted that Dr. Wright call in Tamiflu pills for Alyssa. Michele has no medical
background. While driving home from a Houston meeting, I received a message from Michele
at 5:31 pm stating she was going to my residence to give Alyssa the medication. Alyssa’s nanny,
Sharon Alcantara, had just left the residence and she called Beth Kraulis on the phone to let her
know she had seen Michele at the Shell Station on Walden Road acting very erratic and going
into a rant about something with the cashier while buying cigarettes. Beth was home alone with
Alyssa at the time and did not feel it was safe or in their best interests to let Michele have access
to our residence due to the events that had transpired in the doctor’s office and what Alyssa’s
nanny had just witnessed. See Exhibits 13, 14, 15 and 16 attached hereto.
13. Michele indicates that I would not provide Alyssa with a razor to shave. In fact, I
researched what age girls start shaving. During a meeting with the school counselor, I asked
“what age do girls start shaving?” In addition, during the two CPS visits (falsely placed or
invoked by Michele), I asked the two female agents “at what age do girls start shaving?” All
agreed that 10 is too young. After gathering all this information, Beth and I spoke with Alyssa
on why it is not appropriate for her age to shave. (See Exhibits 17, 18, 19, 20, 21 and 22
attached hereto).
14. Michelle alleges that Alyssa is afraid of me. She states that this conclusion results
from an occurrence at Alyssa's baptism on 04/21/18. Alyssa was on a weekend visit with
Michelle. On the way to the service, Alyssa's grandmother (Charlene) got a text asking if we
were there yet, as me, Beth and my parents rode together. She did not answer as we were
parking and walking in. Upon entering, we saw Alyssa's aunt, uncle & cousin. They said they
hugged her (later saying there were no signs of her being upset). This was about 20 minutes
before church started and her aunt (MY sister) said we had just missed her. We went in and took
our seats. Directly after the church service was to be the baptism. We saw Alyssa at that time.
Page 3 of 9She hugged all of us individually and looked excited for the baptism. She was
excited Beth had bought hot chocolate to give her since the baptism was outside in water and it
was chilly. There were no signs of her being upset at all.
15. On 04/23/18, Alyssa, myself and Beth were eating dinner and watching the Rockets
game. After the game, Alyssa was being silly by running through the room acting like a
monkey. She said a friend dared her to do that. We were all laughing. Directly after, Alyssa
went to her room and Beth went to do the dishes. Roughly 10 minutes later, Montgomery
County Sheriff's Office (hereafter “MCSO”) began knocking loudly at the door. Deputy
Douglas from MCSO approached me and asked, "Do you know why I am here?" I responded,
"No". Deputy Douglas responded "Neither do I. This is obviously a hoax 911 call." Deputy
Douglas stated someone called 911 saying Ted was highly intoxicated, physically abusive, and
was covering a wide variety of random subjects in a call that lasted six minutes. The deputy
assessed the situation and stated there were no signs of intoxication by anyone and everything
was completely normal (see report attached). He also said he thought chairs would be flying out
the windows based on the information from Michelle. He asked Alyssa if she was scared of her
dad and she said no. He asked if her dad had ever hit her and she said no. He talked to Alyssa
for a period and explained what her mother was doing was wrong and the dangerous situation her
mom created for the deputy, the public and our family. The deputy called Michelle back and
advised her of the situation. Michelle responded and said she thought she would get in trouble.
Exhibit 23.
16. Michelle alleges that in April 2018, she had to take Alyssa to the doctor because she
had Scabies and alleges that I did not respond to any information about her condition. This is not
true. The fact is, Alyssa had a slight rash under her right arm in February that Beth and I were
treating at home with hydrocortisone, change of soap and deodorant. Over the next month or so,
Alyssa did not complain of a rash or itching. Exhibit 24.
Michele sent an Our Family Wizard (“OFW”) message stating Dr. Wright is
"treating" her for scabies. She did not say if she was diagnosed with scabies. Exhibit 25.
Dr. Wright's summary of the office visit shows Alyssa's diagnosis as "Rash and other
nonspecific skin eruption (primary)". Nowhere does it state a diagnosis of scabies. Exhibit 26.
17. Alyssa saw her therapist, Alexia Camfield, in late April 2018. After her session, the
therapist contacted CPS to investigate me regarding Alyssa’s discussions with her and her
concerns for Alyssa's emotional and mental stability and physical appearance.
SUMMARY - CPS "Ruled Out" all allegations. Additionally, Alexia Camfield
notified me that she did not think the accusations were true but had to file them for fear of losing
her license. It was later determined by CPS the information Alexia used to file with CPS was part
of a fabricated plot by the mother, Michelle.
I emailed Alexia Camfield on 01/26/18 asking Alexia for advice about a crying
episode at school where Alyssa stated that she couldn't get mom up until 7:30 that morning and
that her mom was very sleepy the night before. I was concerned that Alyssa could not wake her
mother.
Page 4 of 9Michelle was also making statements to Alyssa that she was going to have me
thrown in jail, discussed with Alyssa the multiple lawsuits she filed against me, etc.
18. On 03/28/18, Alexia and I had’an email exchange concerning Alyssa's becoming
upset the day before the last few counseling appointments and going to see her Aunt Emily (a
teacher at her school) upset and crying. Alyssa stated to me that she no longer wanted to attend
the counseling with Alexia. Additionally, Alyssa had been going to her Aunt Emily's classroom
crying the Monday she returns from visits with her mom. Alyssa was upset that her mom was
discussing events in Michele's life, some being horrific, and most being fabricated and becoming
increasingly concerning. These discussions were increasing. I mentioned these conversations
between Michele and Alyssa were causing her stress and in fact, my family noticed a change in
Alyssa after visits with her mom. Alexia asked me if she could talk to Alyssa about this and I
agreed. Alyssa had stated she just wanted her mom to stop. Exhibit 27.
19. Email exchange dated 04/23/18 between me and Alexia where I voiced my concerns
that Michele had said Alyssa was going to see the school counselor (which was false), among
other concerns including the increasing drama Michele was creating. This was three days before
Alyssa's appointment. This was also the day Michele called 911 to my home that evening.
Exhibit 28.
20. Michelle alleges that on or about April 20, 2018 Alyssa wrote a letter to her
therapist, Alexia Camfield, prior to her baptism expressing her thoughts and issues and ongoing
difficulties with me and my care for her.
I learned of this letter during the CPS visit on Tues, 05/01/18, and have not seen the
letter.
Alyssa had an appointment with Alexia on 04/26/18, which is the date CPS said
Alyssa and her mom brought a letter to the session (not written at the session). Michele states the
letter was written prior to her baptism (04/21/18).
The morning of Alyssa's appointment on 4/26/18 with Alexia, Beth and I overheard
Alyssa on a Facetime chat with friends. One friend asked if she had gotten her "surprise" yet.
Alyssa responded, "my mom said I will get it if I do good in therapy today". This was confirmed
by CPS when they were at my house on 05/01/18. They took Alyssa outside and asked her about
the letter. CPS came back in and talked to me telling me I would be cleared of all accusations.
CPS confirmed the following to me and Beth- Alyssa stated her mom promised her a present if
she wrote the letter and gave it to Alexia Camfield. Alyssa told CPS she knew the letter was not
true. CPS asked Alyssa why she did not tell them in the school interview the letter was false and
her mom forced her to write it to gain a surprise. Alyssa stated she was worried I would punish
her for lying. CPS called a supervisor while at my house to get approval there would be no
restrictions put on me.
21. Michelle alleges that I continue to disparage her in front of Alyssa on a regular basis.
She stated that I said “Your mom has mental issues. The counseling is for your mom not me.”
Page 5 of 9To clarify, Alyssa had told her cousin Jake that her mom told her that CPS was
investigating her dad because he was going to a "mental doctor". This was not true. The above
text they reference is cut and paste out of context. The part of the text cutout was an accusation
by Michelle that CPS is involved because I am seeing a mental doctor.
22. Michelle alleges that Kelly Lowe was designated as Alyssa’s initial counselor at her
school. Madeley Ranch Elementary. She alleges that Alyssa complained that the school
counselor was not concerned or failed to show concern regarding complaints Alyssa was making
relating to her environment at her father's home. She also alleged that she requested a meeting
with the principal which resulted in Alyssa being able to have an “open door” policy with the
principal and assistant principal.
This is not true. Alyssa has never had a problem going to see Kelly Lowe, as she
did frequently three to four years ago when Michele was having issues with drinking and
frequently abandoning Alyssa. Alyssa has known Kelly Lowe since Kindergarten. It is not
typical of Alyssa to complain. When Beth and I had a meeting with Kelly Lowe to see if she had
been asking to come in (one of many things discussed), she said Alyssa had not asked to see
Kelly Lowe. Kelly said the only time it came up was when Michele was up at the school for
lunch and would ask Kelly to pull her from class to talk to her. Kelly checked with Alyssa's
teacher and the teacher stated Alyssa was getting straight A's, behaves well and is one of the
most popular kids in the class. Kelly refuses to pull Alyssa when all appearances are she is
excelling. Ted discussed with the school how great Alyssa is doing and is concerned that
ALYSSA's success seems to be something Michelle seems to want to discredit with school
officials.
There is no "open door" policy with the Principal and Assistant Principal at Madeley
Ranch, as they do not handle the counseling of children. Any child can see the Counselor at any
time if needed.
23. Michele alleges that in May 2018, Ted Krauiis took away Alyssa's phone for having
an opinion on Walmart's sheets and called her a-”stupid spoiled brat”. She alleges that I did not
respond when she questioned me about this.
Again, this is a false statement. Alyssa's phone was taken away for being
disrespectful when discussing getting a new sheet. She stated that "Walmart was not good
enough quality for me". I explained there is nothing wrong with sheets from Walmart and that
our family and her grandparents had the same. She had been disrespectful when Beth sent her
pictures on sheets while at Walmart. Exhibit 30.
She wrote an apology letter to Beth as well. Exhibit 31.
During the discussion, Alyssa stated a girl at school called her a "spoiled brat". I
replied that if she acts at school the way she was acting right then, that the girl was correct. I
never said STUPID. Exhibit 32.
24. Michele alleges that later in mid-May, 2018, Alyssa needed a training bra and had to
wear one all week because she had no others at her father’s house. She alleges that this caused
her “bad hygiene.” -
Page 6 of 9This is untrue. Alyssa has several bras at my house.
25. Michele alleges that on or about May 19 and May 20. 2018, I sent texts to our
daughter regarding the CPS investigation and my thoughts toward Michele.
I spoke to Alyssa regarding these texts and explained to her that I was frustrated after
receiving an increasing amount of inflammatory OF W message over the last six months, Michele
creating fabricated scenarios with school officials, questioning the doctor when not in possession
over a minor flu strain, randomly calling 911 and using Alyssa to create false allegations with the
counselor, etc. Michelle was also providing daily updates to Alyssa on the CPS investigation
(which were all based on fabrications and everything was ruled out). I did speak with Alyssa
apologizing for the tone of the text. Exhibit 33.
I understand my response on May 20th was wrong and I am now attending
counseling to deal with the repeated drama and fabricated escalations Michele continues to
pursue.
26. Michele alleges that on or about May 20, 2018, she received another email from me
berating her for her involvement with the CPS investigation which was based on Alexia
Camfield’s
On 04-23-18, I expressed in an email exchange with Alexia that I was frustrated and
responded to Michele after she had constantly sent accusations. Exhibit 34.
I was frustrated after receiving a huge amount of OF W emails that were increasing in
both size and intensity. Michele created fabricated scenarios with school officials, questioning
the doctor when not in possession over a minor flu strain, randomly calling 911 and using Alyssa
to create false allegations with the counselor which resulted in a fabricated CPS case. Michelle
was also providing daily updates to Alyssa on the CPS investigation (which were all based on
fabrications and everything was ruled out).
27. Michele alleges that on May 21, 2018, Alexia resigned as Alyssa’s therapist because
of ongoing issues with me.
In fact, Alyssa stated in March she no longer wanted to attend counseling with
Alexia. Alyssa had cried to her Aunt in March about attending counseling with Alexia (See
emails attached between Alexia and me)
The CPS investigators revealed to me and Beth that Michele was bribing Alyssa to
make false statements to Alexia. The counseling process is completely poisoned and cannot be
productive in this scenario. It also likely explains Alyssa not wanting to attend as she was being
pressured to lie to receive a big surprise for following along with the plot.
28. Michelle alleges that on or about June 1, 2018, she received an email from the school
principal Shelby Smith, regarding Alyssa's State of Texas Assessments of Academic Readiness
("STAAR") writing which was reviewed and flagged by the Texas Education Agency program.
Page 7 of 9Michele alleges that it is apparent from the writing that Alyssa is having a very difficult time at
my home and that she shared her thoughts in writing about her difficulties living at my home.
Alyssa told Beth that part of the STARR text was a creative writing assignment and
they had to use their techniques to keep the reader interested. There were many writing
assignments around this same subject. Attached hereto as Exhibit 35 is another assignment
Alyssa completed talking about how great it is to be home with me, Beth and her step sister.
29. Michele alleges that she is well acquainted with the present environment of Alyssa
and that Alyssa’s present environment endangers the Child's physical health or significantly
impairs the Child's emotional development. She alleges that I continue to slander and libel her
directly and in front of Alyssa without any explanation or concern and that I act against the
child's best interest. She alleges that the requested Order is necessary because the Child's present
circumstances significantly impair the Child’s physical health and/or emotional development for
which she has no other adequate remedy at law.
This is also False. There is no scenario where Michele can be "well acquainted"
with the present environment of the child in my possession. I remarried 2 years ago. Michele
has not stepped foot in my residence in 3+ years. At times, Beth and I had to speak to Alyssa
about different events that Alyssa was talking about after returning with her mother a few times.
During one of those talks, Alyssa responded by saying "moms stories change, and they are about
Dad" and "I know that didn't happen because I was there.” Each talk between Ted and Alyssa
ALWAYS included that we are happy she was spending time with her mother. Beth and I also
said, "we are happy when you are having fun and spending time with your mom." I always kept
it positive. Excluding the text incident, I nor any family member has ever said a disparaging
word about Michele to Alyssa.
Attached hereto and marked as Exhibit 36 is a timeline of conversations through Our
Family Wizard.
Attached hereto and marked as Exhibit 37 is a timeline of Alyssa’s medical and
dental appointments.
It is without a doubt that Michele is attempting to cause me as much grief as she can
in an attempt to beef up her position in the modification suit filed by her. It is my hope that the
Honorable Judge will see clear to grant the Motion to Dismiss for Failure to State a Judiciable
Cause of Action filed concurrently herein. Alyssa is very happy in her present environment and
expressed this on many occasions. See Exhibit 29 attached hereto.
Further affiant sayeth naught. JT2Y 2
TED KRAULIS
Page 8 of 9STATE OF TEXAS §
COUNTY OF MONTGOMERY §
SIGNED under oath before me on August 21, 2018.
hed Ty halZ.
Notary Public, State of Texas
A McDONALD
LN ry Public
STATE OF TEXAS
1D#79122
My Comm. Exp. April 16
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Minneapolis, MN 55413
http://www.OurFamily Wizard.com
Info@OurFamilyWizard.com
Message Report
Ted Kraulis generated this report on 05/28/18 at 11:05 AM. All times are listed in America/Chicago timezone.
Message: | of |
Date: 12/27/2017 6:53 PM
From: Michele Kraulis
Jo: Ted Kraulis (First View: 12/27/2017 6:55 PM)
Subject: Drappt
Attachments IMG_9561.JPG
IMG_9566.JPG
IMG_9565.JPG
Ted,
I took Alyssa to Dr. Wright's office this morning because the congestion in her chest had gotten worse and she started complaining about
her ear hurting yesterday. Suedafed wasn't cutting it. She's taken a dose of
z-pac today and I'll send the rest with her tomorrow to finish the last 3 days. Please see the attached invoices for the doctor and
prescription for partial reimbursement.
Also, I was advised she had not had her yearly check-up since 2016. I booked that Jan 18th at 4:30 and she will be getting a flu shot then
as well. Alyssa said she had not had one yet.
Alyssa also told me this summer that she had not been to the dentist and still has not. Her appt is Jan. 25th at 3:00.
Asa reminder, her appt with Alexia Camfield is Jan 17th at 3:00.
Thanks,
Michele
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Info@OurFamilyWizard.com
Message Report
Ted Kraulis generated this report on 05/28/18 at U1:14 AM. All times are listed in America/Chicago timezone.
Message: 1 of 1
Date: 01/15/2018 12:26 PM
From: Ted Kraulis
To: | Michele Kraulis (First View: 01/15/2018 12:26 PM)
Subject: Alyssa’s appt
Alyssa tested positive for Flu A. Her ear is bothering her but not infected...just swimmers ear. She will be out all week. Her yearly check
has been canceled. She will need to get a flu shot this weekend to cover other strains. Please reschedule her counseling appointment. Her
teacher is sending her work home. Will let You is she starts feeling worse, but she is feeling ok and no fever now.
Exibit 4SSM SUNT
KRAULIS, ALYSSA MARIE 092340
5/29/2018
3500 Madeley Ranch Rd
MONTGOMERY, TX 77356
936-276-4600
To the Parents/Guardians of:
KRAULIS, ALYSSA MARIE
48811 W COOL BREEZE LANE
MONTGOMERY, TX 77356
‘SERRILL, ANDREA C
4TH SOC STU 99
4TH MATH 97
4TH SCIENCE, 98
4TH MUSIC —
4TH ART E
4TH PE E
nmammmmm
99 SERRILL, ANDREA C
96 SERRILL, ANDREA C
97 SERRILL, ANDREA C
E BANEY, MARY
E BROWN, IVY
STROADE, KATIE.
g Shit
Days Present 32 41 36
Days Absent 0 3 4
Excused 0 0 4
Unexcused ° 3 0
Times Tardy 0 Q 0
[Promotion to the next grade level shall be based on an overall
laverage of 70 on a scale of 100 based on course-level, grade-level standards
\essential knowledge and skills) for all subject areas and a grade of 70
in readingftanguage arts and mathematics.
A= 90-100 E = Excellent
30-89 $= Salisfactory
5-79 N= Needs Improvement
ID = 70-74 U= Unsatisfactory
IF = 69 & Below
TEA Campus Rating: Met Standard with 1 Recognition
lON MISD WEB PAGE UNDER TxCONNECT PARENT PORTAL
IRE-REGISTER YOUR STUDENT FOR THE 2018-2019 SCHOOL YEAR! BEGINNING THE LAST WEEK
lOF JULY - for help with Parent Portal email donna.morris@misd.org
seas PROMOTED
Exhibit leKRAULIS, ALYSSA MARIE
092340
To the Parents/Guardians of:
KRAULIS, ALYSSA MARIE
48811 W COOL BREEZE LANE
MONTGOMERY, TX 77356
it
936-276-4600
TORCOLETTI, SHANNON
TORCOLETTI, SHANNON
TORCOLETTI, SHANNON
TORCOLETTI, SHANNON
STROADE, KATIE
Eutoareines) fel
|A= 90-100
1B = 80-89
IC = 75-79
ID = 70-74
IF = 69 & Below
[Promotion to the next grade level shall be
laverage of 70 on a scale of 100 based on course-level, grade-level standards
{essential knowledge and skills) for all subject areas and a grade of 70
lin reading/language arts and mathematics.
Excellent
S= Satisfactory
N = Needs Improvement
insatisfactory
‘TEA Campus Rating: Met Standard with 1 Recognition
FOR RETURNING STUDENTS REGISTER ONLINE FOR 2017-18 SCHOOL YEAR
ION MISD WEB PAGE UNDER TxCONNECT PARENT PORTAL - AUGUST 7th THRU AUGUST 14th,
se iat
3RD LANG ARTS 98 98 98 o1
3RD MATH 96 97 97 93 96 95 E 96
3RD SCIENCE 9993 96 100 100 100 E 98
3RD SOC STU 100 99 400 =©100 100 100 E 100
3RD PE — HE eE c€ HE —E c— HE
senate = a
Days Present 35 39 46 168
Days Absent 2 1 4 1 5
Excused 2 oO 4 0 3
Unexcused o 1 0 1 2
Times Tardy 0 0 0 0 o
08" PROMOTED
Exhibit 7The OurFamilyWizard® website
1302 2nd St NE Suite 200
Minneapolis, MN 55413 {
hittp://www.OurFamilyWizard.com
Info@OurFamilyWizard.com
Message Report
Ted Kraulis generated this report on 05/28/18 at 11:10 AM. All times are listed in America/Chicago timezone.
Message: 1of!
Date: 01/03/2018 2:20 PM
From: Michele Kraulis
To: Ted Kraulis (First View: 01/03/2018 2:22 PM)
Subject: Business relationship
Ted,
T.want to be crystal clear that our relationship is strictly business-like. That’s it. For the sake of Alyssa, we need to be cordial with one
another at functions. She notices.
Thave my reasons for forgiving you, but I will never, ever, ever forget your actions and behavior before our divorce when I was
extremely sick, how you took me to the cleaners in every aspect of our divorce fully aware of my condition, and the constant abuse,
harassment and continued issues in the past 830 days since I got sober.
Iwish you a healthy, happy and prosperous new year.
Regards,
Michele
Exhibit gMessage Report
‘The OurFamilyWizard® website
1302 2nd St NE Suite 200
Minneapolis, MN 55413
http:/Awww.OurFamilyWizard.com
Info@OurFamilyWizard.com
Ted Kraulis generated this report on 05/28/18 at 11. ':06.AM. All times are listed in America/Chicago timezone.
Message:
Date:
From:
To:
Subject:
Ted,
loft
01/01/2018 11:00 AM
Michele Kraulis
Ted Kraulis (First View: 01/01/2018 11:01 AM)
January spousal support missing
Again, the spousal support payment from you is not on time. I can hold you in contempt. Luckily, because you your childish actions with
text messages sent from Alyssa’s phone to me (which she knows about and asked to read) opened the door for me to explain that I do
have the ability to throw you in jail for simply not following directions.
Kind regards,
Michele
Eywbot 9The OurFamilyWizard® website
1302 2nd St NE Suite 200
Minneapolis, MN 55413
http://www.OurFamilyWizard.com
Tnfo@OurFamilyWizard.com
Message Report
Ted Kraulis generated this report on 05/28/1. 8 at 11:13 AM. All times are listed in America/Chicago timezone.
Message: 1 of 1
Date: 01/14/2018 6:32 PM
From: Michele Kraulis
To: Ted Kraulis (First View: 01/14/2018 6:34 PM)
Subject: Alyssa fever
Ted,
Alyssa let me know she’s running a fever. Please Jet me know what the status is in the morning. Or if something changes this evening,
that as well.
‘Thanks,
Michele
Evhibit 0The OurFamilyWizard® website
1302 2nd St NE Suite 200
Message Report Minneapolis, MN 55413
http://www. OurFamilyWizard.com
Info@OurFamilyWizard.com
Ted Kraulis generated this report on 05/28/18 at 11:14 AM. All times are listed in America/Chicago timezone.
Message: lof!
Date: 01/15/2018 9:52 AM
From: Michele Kraulis
To: Ted Kraulis (First View: 01/15/2018 9:58 AM)
Subject: Alyssa doctor
Ted,
What time is Alyssa’s doctor appt today?
Kind regards,
Michele
Eyhilort (|Message Report ‘Minneapolis, MN 55413
‘The OurFamilyWizard® website
1302 2nd St NE Suite 200
http:/Iwww.OurFamilyWizard.com ©
Info@OurFamilyWizard.com
Ted Kraulis generated this report on 05/28/18 at 11:14 AM. All times are listed in America/Chicago timezone.
Message:
Date:
From:
To:
Subject:
lofi
01/15/2018 12:26 PM
‘Ted Kraulis
. Michele Kraulis (First View: 01/15/2018 12:26 PM)
Alyssa’s appt
Alyssa tested positive for Flu A. Her ear is bothering her but not infected...just swimmers ear, She will be out all week. Her yearly check
has been canceled. She will need to get a flu shot this weekend to cover other strains. Please reschedule her counseling appointment. Her
teacher is sending her work home. Will let You is she starts feeling worse, but she is feeling ok and no fever now.
Eylniloit 12‘The OurFamilyWizard® website
1302 2nd St NE Suite 200
Minneapolis, MN 55413
hetp:Awww.OurFamilyWizard.com
Info@OurFamilyWizard.com
Message Report
Ted Kraulis generated this report on 05/28/18 at [1:15 AM. All times are listed in America/Chicago timezone.
Message: 1 of |
Date: 01/15/2018 5:13 PM
From: Michele Kraulis
To: Ted Kraulis (First View: 01/15/2018 5:31 PM)
Subject: Tamiflu prescription
Attachments Dr._Wright Flu_A_transcript_1-15-18.pdf
Tamiflu_prescription pdf
Ted,
‘After speaking with Alyssa earlier, she informed me she was not prescribed Tamiflu. To the best of my knowledge, the conversation was
¥ around kids throwing up on it. That's the liquid form. So Dr. ‘Wright called in the pill form for me for Alyssa as she needs to start on it
asap (she's still within the 48 hr window) to help lessen the symptoms. I will be bringing it over shortly so please have her come out to
get it so I can see her.
Trescheduled her yearly for Friday January 26th at 4:15 because she has her dentist appt on Thursday January 25th.
Dr. Wright's office informed me that most everywhere is out of children's flu shots. I will check around to see ifI can find a pharmacy, as
suggested, that still has them so she can get one this weekend.
“Alyssa tested positive for Flu A. Her ear is bothering her but not infected..just swimmers ear. She will be out all week. Her yearly
check has been canceled. She will need to get a flu shot this weekend to cover other strains. Please reschedule her counseling
appointment. Her teacher is sending her work home. Will let You is she starts feeling worse, but she is feeling ok and no fever now."
Kind regards,
Michele
Exhibit 13Summary View for KRAULIS, ALYSSA Page 1 of 2
Progress note
Patient: KRAULIS, ALYSSA Provider: Michael Wright, MD
Account Number: 10931
DOB: 03/17/2008 Age: 9Y9M Sex: Female Date: 01/15/2018
Phone: 832-338-6466
Address: 18811 W COOL BREEZE LN, MONTGOMERY, TX-77356-4992
Subjective:
Chief Complaints:
1, FEVER Acc:Mom. 2. Sick.
HPI:
General: . .
Last PM pt was c/o an upset stomach, and today she woke up with a fever 100.7 and her ears are bothering her.
ROS:
GENERAL:
GENERAL: denies change in activity. HEENT: denies headaches, sore throat. RESPIRATORY: denies shortness
of breath, denies wheezing. GI: denies abdominal pain, vomiting, diarrhea or constipation, no decrease in
appetite, DERMATOLOGY: denies rash.
Medical History:
Surgical History: Denles Past Surgical History.
Hospitalization/ Major Diagnostic Procedure: Denies Past Hospitalization.
Family History: Mother: alive, substance abuse recovery. Father: alive.
Social History: Exposure to second hand smoke? No.
IN 3rd GRADE, golf.
Medications: Taking Advil , Medication List reviewed and reconciled with the patient
Allergies: N.K.D.A.
Objective:
Vitals: Wt 59.7, Temp 98.2
CS, LVN.
Examinati
Examination, General: a
GENERAL APPEARANCE: well nourished, no acute distress, non-toxic appearing. HEENT: TMs normal, canal
erythema, bilateral conjunctiva clear without drainage, nasal congestion, rhinorrhea, pharynx and tonsils
normal, moist mucosa, no oral lesions. NECK: soft, supple, no lymphadenopathy. LUNGS: clear to auscultation
bilaterally, no rales, rhonchi or wheezes. HEART: regular rate and rhythm, normal $1S2, no murmurs. ABDOMEN:
soft, non-tender/non-distended, no mass or organ enlargement . SKIN: no rashes. NEURO: normal strength and
tone.
Assessment:
Assessment:
1. Influenza due to identified novel influenza A virus with other manifestations - J09.X9 (Primary)
2, Otalgia, bilateral - H92.03
Plan:
1. Influenza due to identified novel influenza A virus with other manifestations
Start Tamiflu Capsule, 30 mg, 2 capsule, Orally, twice 2 day (bid), 5 days, 20, Refills 0 .
LAB: Rapid Flu Positive
Flu A Pos +
Flu B Neg
Notes: supportive measures. monitor.
2. Otalgia, bilateral . . | .
Start Ciprofloxacin-Dexamethasone Suspension, 0.3-0.1 %, 4 drops into affected ear, Otic, Twice a day, 7 days, 1, Refills
https://eclinworks1 -mhhs.org:93 33/mobiledoc/}sp/catalog/xml/printChartOptions,jsp?encounterID=5 1769... 1/15/2018
Ext tort 4Summary View for KRAULIS, ALYSSA Page 2 of 2
oO.
Notes: supportive measures.
Follow Up: pm
Provider: Michael Wright, MD
Patient: KRAULIS, ALYSSA DOB: 03/17/2008 Date: 01/15/2018
*
bttps/feclinworks1.mhls.org:9333/mobiledoc/}sp/catalog/xml/printChartOptions jsp?encounterID=51769... 1/15/2018
Exh 4 lant,The OurFamilyWizard® website
1302 2nd St NE Suite 200
Minneapolis, MN 55413
http://www. OurFamilyWizard.com “
Info@OurFamilyWizard.com
Message Report
Ted Kraulis generated this report on 05/28/18 at 11:15 AM. All times are listed in America/Chicago timezone.
Message: 1 of L
Date: 01/15/2018 6:28 PM
From: Michele Kraulis
To: Ted Kraulis (First View: 01/15/2018 6:37 PM)
Subject: Refusing me at gate
Ted,
Just documenting you refused me at the gate with the tamiflu prescription.
Kind regards,
Michele
Exhilort 1S‘The OurFamilyWizard® website
1302 2nd St NE Suite 200
Minneapolis, MN 55413
Message Report http://www. OurFamily Wizard.com
Info@OurFamilyWizard.com
Ted Kraulis generated this report on 05/28/18 at 11:50 AM. All times are listed in America/Chicago timezone.
Message: | of 1
Date: 01/18/2018 11:12 PM
From: Ted Kraulis
To: | Michele Kraulis (First View: 01/18/2018 11:12 PM)
Subject: Engaging Mr. Brass and Laura Watson
Hello Michele:
The events of this week were quite theatrical on your part.
Ifyou take Alyssa to the doctor and treat her-I will respect you are doing the proper thing, I have been doing exactly what the doctor
has recommended. It is challenging when the doctors office is calling me repeatedly about your actions.
At this point, there is no legal proceedings between us. [am being sent emails where your attomey is continuing to copy Laura Watson
‘on false items. I have informed Mr. Brass that if there is future Jegal proceedings I will not agree to use her as the amicus or mediator.
Please inform your legal representation to discontinue copying her as she will not be an agreed part of legal proceedings based on this
unprofessional behavior. Mr. Brass agrees and has sent to your representation the same information.
Additionally, I have been informed Ms. Watson could bill for this continued involvement. I want to again stress - I will not pay
additional invoices from her since there is no litigation and I will refuse to sign on additional engagement. If a bill is presented from your
side involving her - that is your responsibility since you are engaging her. For the record - I think Laura is a tremendous person and
advocate for Alyssa. I am not going to send to Laura my side of the situation since she is not involved and Mr. Brass and I struggle to
understand why this is happening on your side.
The entire goal of the year long mediation was to get a long term solution. My understanding is that was achieved. There is no contact
from my side to you. Your Family Wizard communications continue to harass me, your representation continues to provide misleading
information to Mr. Brass and Laura Watson (who are both not involved) and now put us in a position where Ms. Watson will never be
involved again.
Thank you for your consideration and I hope you can respect the Jaw and new court orders signed.
Respectfully,
Ted.
Exhibit |The OurFamilyWizard® website
1302 2nd St NE Suite 200
Minneapolis, MN 55413
http://www.OurFamilyWizard.com
Info@OurFamily Wizard.com
Message Report
Ted Kraulis generated this report on 05/29/18 at 02:51 PM. All times are listed in America/Chicago
timezone.
Message: lof 1
Date: 04/12/2018 7:47 PM
From: Michele Kraulis
Jo: Ted Kraulis (First View: 04/12/2018 7:52 PM)
Subject: Razor for Alyssa
Attachments Razor_for_Alyssa__attach.jpg
Ted,
Alyssa shaved her legs tonight for the first time. She wanted me to convey to you that she wants the
Gillette Venus razor. Pic attached.
Kind regards,
Michele
Exdnloit 17Message Report
The OurFamilyWizard® website
1302 2nd St NE Suite 200
Minneapolis, MN 55413
http://www. OurFamily Wizard.com
Info@OurFamily Wizard.com
Ted Kraulis generated this report on 05/29/18 at 02:51 PM. All times are listed in America/Chicago
timezone.
Message: lofl
Date: 04/20/2018 11:35 AM
From: Michele Kraulis
To; Ted Kraulis (First View: 04/20/2018 11:36 AM)
Subject: Personal care for Alyssa
Attachments _Personal_care_for_Alyssa__attach jpg
Ted,
Alyssa asked me last night if you ever respond to emails I send which is saddening. Can you please get her
a razor for your house? Please see attached email I sent on the 12th.
Kind regards,
Michele
Exh 16On Fri, 04/27/18 at 4:56 PM, Ted Kraulis wrote:
To: Michele Kraulis
Subject: RE: Razor for Alyssa
Michele:
Please quil sending messages stating what I am doing and not doing. I received the transeript of your 911 call
today.
Sheriffs department is being contacted next week to file a harassment report and I am going to be filing a civil
slander case. You have been slandering me to many people in Montgomery and now did it on a 911 call which
is public record. The allegations are false.
Please stop sending anything unless it is a major / health issue.
Have a nice weekend,
Ted.
On Fri, 04/27/18.at 6:52 AM, Michele Kraulis wrote:
To: Ted Kraulis
Subject: Razor for Alyssa
Ted,
This is the third request. Will you or Beth please buy Alyssa the razor she needs to have her legs?
Kind regards,
Michele
Exdibit \4Message Report
The OurFamilyWizard® website
1302 2nd St NE Suite 200
Minneapolis, MN 55413
http://www. OurFamily Wizard.com
Info@OurFamilyWizard.com
Ted Kraulis generated this report on 05/29/18 at 03:04 PM. All times are listed in America/Chicago
timezone.
Message: of 1
Date: 05/14/2018 8:19 AM
From: Michele Kraulis
To: Ted Kraulis (First View: 05/14/2018 8:29 AM)
Subject: Razor and bras
Attachments Razor_and_bras_attach.jpg
Ted,
I personally went into school this morning and let them know a packaged razor and shaving cream is in her
backpack. I have repeatedly asked you to provide this necessity for a month and you have failed to do so -
so I did. I also sent two bras with her that we bought this weekend.
Kind regards,
MicheleThe OurFamilyWizard® website
1302 2nd St NE Suite 200
Minneapolis, MN 55413
http:/Awww.OurFamily Wizard.com
Info@OurFamilyWizard.com
Message Report
Ted Kraulis generated this report on 05/29/18 at 03:04 PM. All times are listed in America/Chicago
timezone.
Message: lof 1
Date: 05/16/2018 7:56 AM
From: Michele Kraulis
Yo; Ted Kraulis (First View: 05/16/2018 7:57 AM)
Subject: Razor and Vacation Bible School
Ted,
It is my understanding that you refused the razor yesterday from the principal at school. Why? She needs
one and you have not been willing to supply one for her.
Also, you have not yet responded to switching me weeks in June so Alyssa can attend VBS. I have
repeatedly asked you about this. I would appreciate a response.
Kind regards,
Michele
Exh No \ + 2)‘The OurFamilyWizard@ website
1302 2nd St NE Suite 200
Message Report Minneapolis, MN 55413
hap: Avww.OurFamily Wizard.com
Info@OurFamilyWizard.com
Ted Kraulis generated this vepovt an 06/13/18 at 10:10 PAL. All timas ava listed is: AmevicalChicago timezone,
Message: J of 1
Date: 06/03/2018 7:39 PM
From: — Michele Kraulis
To: Ted Kraulis (First View: 06/03/2018 8:19 PM)
Subject: Alyssa’s razor
Ted,
T attempted to send a razor home with Alyssa tonight and she wouldn't do it. She was so afraid you would find it, punish her for it and
take her phone.
Kind regards,
Michele04/26/18 MONTGOMERY COUNTY SHERIFF'S OFFICE 25952
15:37 CALL DETAIL REPORT Page: 1
Call Number: 18234226
Nature: WELFARE CHECK
Reported: 19:59:14 04/23/18
Revd By: CANDELARIA L How Revd: 9
Occ Btwn: 19:58:59 04/23/18 and 19:59:01 04/23/18
Type: 1
riority: 3
Address: 18811 W COOL BREEZE LN
City:
Alarm:
COMPLAINANT /CONTACT .
Complainant: , Name#:
Race: Sex: DOB: *¥/**/%*
Address: ,
Home Phone: Work Phone:
Contact: MICHELLE KRAULIS
Address: X:-095.653345 Y:+030.406047 U:00032
Phone: (713) 538-6848
RADIO LOG
Dispatcher Code Zone Agne Description
DOUGLAS K 20:01:01 04/23/18 5P1011 ENRT SO5 MCSO (MDC) Enroute to a call
incid#=18A110601 cali=18511
DOUGLAS K 20:06:31 04/23/18 5P1011 ARRV SOS MCSO (MDC) Arrived on scene
incid#=18A110601 cal1=18511
DOUGLAS K 20:58:04 04/23/18 5P1011 CLEA SO5 MCSO (MDC) Completed: call
incid#=18A110601 call=185i1
COMMENTS
CALLBACK=(713) 538-6848 LAT=+030.406047 LON=-095.653345 UNC=00032
49:59:41 04/23/2018 - CANDELARIA L
REP 10 YEAR OLD DAUGHTER JUST CALLED HER ABOUT 10 MIN AGO
19:59:50 04/23/2018 ~ CANDELARIA
SAYING HER FATHER IS INTOXICATED
19:59:53 04/23/2018 - CANDELARIA
NOT BEING VIOLENT
20:00:10 04/23/2018 - CANDELARIA
REP HAS SECONDARY CUSTODY
20:00:13 04/23/2018 - CANDELARIA
THE FATHER HAS PRIMARY
20:00:24 04/23/2018 - CANDELARIA
DAUGHTER DID NOT WANT TO GO BACK
20:00:46 04/23/2018 - CANDELARIA
REP HAS ALWAYS TOLD HER DAUGHTER
20:01:13 04/23/2018 - CANDELARIA
L
L
L
tt
L
TO HER FATHER
L
TO STAY AWAY FROM THE DAD IS DRUNK
L
Exhibit 2304/26/18 MONTGOMERY COUNTY SHERIFF'S OFFICE 25952
15:37 CALL DE! L REPORT Page: 2
REP =X ABUSED REP IN THE PAST. . .ABUSED HER PHYSICALLY IN THE PAST
30:01:38 04/23/2018 - CANDELARIA L
THI
Preview
CAUSE NO. 15-03-02527-CV IN THE INTEREST OF ) IN THE DISTRICT COURT OF ( ALYSSA MARIE KRAULIS ) MONTGOMERY COUNTY, TEXAS ( A CHILD ) 418™ JUDICIAL DISTRICT SECOND AMENDED MOTION TO DISMISS FOR FAILURE TO STATE A JUDICIABLE CAUSE OF ACTION This Motion to Dismiss for Failure to State a Judiciable Cause Of Action is brought by TED KRAULIS, Respondent, who shows in support: 1. Petitioner’s Motion to Modify Parent-Child Relationship filed on June 21, 2018 should be dismissed for failure to state a Judiciable Cause of Action pursuant to Texas Family Code §156.102(b). In support hereof, attached as Exhibit 1 is AFFIDAVIT OF THEODORE KRAULIS IN SUPPORT OF SECOND AMENDED MOTION TO DISMISS FOR FAILURE TO STATE A JUDICIABLE CAUSE OF ACTION. Such affidavit is incorporated herein as if recited verbatim. 2. Pursuant to the averments in the aforementioned affidavit, Michelle Kraulis has engaged in a course of action designed to harass this Movant by making false accusations, filing frivolous pleadings, and abusing the process of this Court and of the legal system in general. 3. Attorney's Fees, Expenses, Costs, and Interest It was necessary for Respondent to secure the services of RICK BRASS, a licensed attorney, to prepare and prosecute this suit. Judgment for attorney's fees, expenses, and costs through trial and appeal should be granted against Petitioner and in favor of Respondent for the use and benefit of Respondent's attorney; or, in the alternative, Respondent requests that reasonable attorney's fees, expenses, and costs through trial and appeal be taxed as costs and be ordered paid directly to Respondent's attorney, who may enforce the order in the attorney's own name. Respondent requests postjudgment interest as allowed by law. Therefore Respondent prays that this Court dismiss Petitioner’s Motion to Modify Parent-Child Relationship, for Attorney’s fees, and for such other and further relief that may be awarded at law or equity. SECOND AMENDED MOTION To Dismiss FOR FAILURE TO STATE A JUDICIABLE CAUSE OF ACTION (ITIO ALYSSA MARIE KRAULIS)Respectfully submitted, BRASS & MCCOTTER 207 Simonton Conroe, Texas 77301 Tel: (936) 788-5700 Fax: (936) 788-5701 RICK BRASS Attorney for Respondent State Bar No. 02909450 rick@rickbrass.com Certificate of Service I certify that a true copy of the above was served on each attorney of record or party in accordance with Texas Rules of Civil Procedure on August 21, 2018. Yo 939-4 RICK BRASS SECOND AMENDED MOTION To Dismiss FOR FAILURE TO STATE A JUDICIABLE CAUSE OF ACTION (ITIO ALYSSA MARIE KRAULIS)CAUSE NO. 15-03-02527-CV IN THE INTEREST OF ) IN THE DISTRICT COURT OF ( ALYSSA MARIE KRAULIS ) MONTGOMERY COUNTY, TEXAS ( A CHILD ) 4187 JUDICIAL DISTRICT AFFIDAVIT OF THEODORE KRAULIS IN SUPPORT OF SECOND AMENDED MOTION TO DISMISS FOR FAILURE TO STATE A JUDICIABLE CAUSE OF ACTION THEODORE KRAULIS appeared in person before me today and stated under oath: "My name is THEODORE KRAULIS. I am above the age of eighteen years, and I am fully competent to make this affidavit. The facts stated in this affidavit are within my personal knowledge and are true and correct. "T am the Respondent in this case and the father of the child the subject of this suit. First, the identity of the people named in this affidavit are as follows: Theodore John Kraulis (hereafter “Ted”) — father of child; Alison Michele Kraulis (hereafter “Michelle”) — mother of child; Elizabeth Kraulis (hereafter “Beth”) — my wife, the child’s stepmother; Alyssa Kraulis (hereafter “Alyssa”) — the child; Alexia Camfield — (hereafter “Alexia’”) - the counselor On May 24, 2018, ALISON MICHELE KRAULIS filed a Petition to Modify Parent-Child Relationship which was unilaterally dismissed by Judge Gilbert on the basis that the affidavit attached to the Petition to Modify Parent-Child Relationship does not contain facts adequate to support an allegation as required by Section 156.102(b) of the Texas Family Code. On or about June 8, 2018, ALISON MICHELE KRAULIS refiled her suit in the form of an Amended Motion to Modify Parent-Child Relationship requesting the current custody, possession and access and child support Order dated December 11, 2017 which gave the exclusive right to me to determine the residence of the child and to receive child support, together with an Affidavit in support thereof alleging numerous misconducts on my part against my daughter, ALYSSA KRAULIS, the majority of which are untrue, inaccurate or taken out of context. On or about June 21, 2018, ALISON MICHELE KRAULIS filed a nonsuit and order with prejudice dismissing the Amended Motion to Modify Parent-Child Relationship and then filed on June 21, 2018 a Motion to Modify Parent-Child Relationship. This Affidavit is in support of THEODORE KRAULIS’ Second Amended Motion to Dismiss for Failure to State a Judiciable Cause of Action. Page 1 of 9 EXHIBIT if4. Taking the allegations in the Affidavit separately, I state as follow: 1. Michele alleges that in December 2017, Alyssa came to her with a serious cold and infection that required medical attention which she states that she addressed. On 12/27/18 through Our Family Wizard (hereafter “OF W”) Michele relayed this information to me stating that the doctor prescribed an antibiotic. Alyssa had been with Michele for the previous 7 days. She had a cough for a few days before she went to Michele for Christmas on 12/14/17, which was being treated with children’s cough syrup and there was no fever or other symptoms. See Exhibit “1” attached hereto. She returned home on 12/28/17 and I continued to administer the medicine prescribed. See Exhibits 1, 2, and 3. -She also states that I do not address Alyssa’s medical issues. This is untrue, as will be exhibited below. Alyssa did not have a yearly physical in 2017 because she saw her doctor, Dr. Wright, many, many times that year. She has had many meetings with Dr. Wright where he performed the necessary requirements of a yearly checkup. Michele Kraulis scheduled a yearly medical checkup for Alyssa for 1/18/18 but Beth ended up taking Alyssa to the doctor on 1/15/18 instead because she had the flu, and was advised by the doctor’s office to cancel the 1/18/18 appointment and bring her back for a checkup when she is feeling better. Michele was advised of this on OFW. See Exhibit 4 attached hereto. Alyssa was then scheduled for her yearly checkup on 6/25/18. 5. On 1/15/18, when Beth took Alyssa to the doctor for the flu, she was diagnosed with Flu A. The doctor advised to get her a flu shot over the upcoming weekend, so she would not get Flu B. Michele was advised of this via OFW on 1/15/18 (Exhibit 4). Michele replied on 1/15/18 that she will get Alyssa a flu shot that upcoming weekend. Michele was scheduled to have Alyssa on January 20 and 21, 2018. Alyssa indicated that Michele never took her to get a flu shot. See Exhibit 5 attached hereto. 6. Yearly checkup Dental Michelle scheduled a dentist appointment for Alyssa for 1/25/18. Alyssa was seen by a different dentist with Ted Kraulis in 2016. The result of her dentist appointment on 1/25/18 proved that Alyssa’s teeth were very healthy and normal. She did have one cavity which was repaired. 7. Michele’s allegations that I do not address Alyssa’s medical issues are unwarranted and unfounded and nothing more than a fishing expedition to attempt to gain leverage for her modification lawsuit. 8. Michele’s allegations that she discussed Alyssa’s “Poor study habits” with me in hopes that I would work with her on her weekly tests is outrageous. Alyssa is and continues to be a straight A student, has never gotten a grade lower than “A” and has excellent classroom behavior. See attached report cards for years 2016/2017 and 2017/2018 attached hereto as Exhibits “6” and “7.” I did not respond to her via OFW because of Michele’s antagonistic emails on 1/1/18 and 1/3/18. See Exhibit “8” and “9” attached hereto. 9. Michele states that I did not provide her with the insurance card and a copy of the policy information, when in fact, on 1/18/18 when Michele picked up Alyssa, I gave her a large manila Page 2 of 9envelope containing a printed copy of the policy information together with several lists of In- Network doctors, clinics, and hospitals. 1/18/18 was the first date that Michele had possession of Alyssa in 2018. 10. Michele alleges that I did not respond to her OFW message inquiring about Alyssa’s fever. I did not respond because Michele indicated to me that Alyssa told her that she has been running a fever. See Exhibit 10 and Exhibit 11 attached hereto. 11. Michelle was provided with an update of Alyssa’s condition via OFW on 1/15/18, directly after Alyssa’s appointment with the doctor. See Exhibit 12 attached hereto. 12. Michelle alleges that I failed to follow the doctor’s plan for Alyssa’s flu diagnosis, when in fact I did follow the doctor’s plan. Dr. Wright prescribed ear drops for swimmer’s ear, and I already had the same drops at home from a previous ear ache prescribed by Dr. Wright. Alyssa had no fever at the doctor’s appointment. Dr. Wright also said she had a mild case of the flu A. The side effects of Tamiflu were discussed with Beth. Tamiflu would only shorten the flu by one day and it will not help her feel better during the first several days. Additionally, it can cause extreme nausea, which would make her feel worse. He did not call Tamiflu in and told Beth to keep treating with over the counter cold medicine and Children’s Advil. In mid afternoon of the same day, I received several calls from Dr. Wright’s office stating Michele was at the office and demanding to see Alyssa’s medical records. Michele questioned Dr. Wright and insisted that Dr. Wright call in Tamiflu pills for Alyssa. Michele has no medical background. While driving home from a Houston meeting, I received a message from Michele at 5:31 pm stating she was going to my residence to give Alyssa the medication. Alyssa’s nanny, Sharon Alcantara, had just left the residence and she called Beth Kraulis on the phone to let her know she had seen Michele at the Shell Station on Walden Road acting very erratic and going into a rant about something with the cashier while buying cigarettes. Beth was home alone with Alyssa at the time and did not feel it was safe or in their best interests to let Michele have access to our residence due to the events that had transpired in the doctor’s office and what Alyssa’s nanny had just witnessed. See Exhibits 13, 14, 15 and 16 attached hereto. 13. Michele indicates that I would not provide Alyssa with a razor to shave. In fact, I researched what age girls start shaving. During a meeting with the school counselor, I asked “what age do girls start shaving?” In addition, during the two CPS visits (falsely placed or invoked by Michele), I asked the two female agents “at what age do girls start shaving?” All agreed that 10 is too young. After gathering all this information, Beth and I spoke with Alyssa on why it is not appropriate for her age to shave. (See Exhibits 17, 18, 19, 20, 21 and 22 attached hereto). 14. Michelle alleges that Alyssa is afraid of me. She states that this conclusion results from an occurrence at Alyssa's baptism on 04/21/18. Alyssa was on a weekend visit with Michelle. On the way to the service, Alyssa's grandmother (Charlene) got a text asking if we were there yet, as me, Beth and my parents rode together. She did not answer as we were parking and walking in. Upon entering, we saw Alyssa's aunt, uncle & cousin. They said they hugged her (later saying there were no signs of her being upset). This was about 20 minutes before church started and her aunt (MY sister) said we had just missed her. We went in and took our seats. Directly after the church service was to be the baptism. We saw Alyssa at that time. Page 3 of 9She hugged all of us individually and looked excited for the baptism. She was excited Beth had bought hot chocolate to give her since the baptism was outside in water and it was chilly. There were no signs of her being upset at all. 15. On 04/23/18, Alyssa, myself and Beth were eating dinner and watching the Rockets game. After the game, Alyssa was being silly by running through the room acting like a monkey. She said a friend dared her to do that. We were all laughing. Directly after, Alyssa went to her room and Beth went to do the dishes. Roughly 10 minutes later, Montgomery County Sheriff's Office (hereafter “MCSO”) began knocking loudly at the door. Deputy Douglas from MCSO approached me and asked, "Do you know why I am here?" I responded, "No". Deputy Douglas responded "Neither do I. This is obviously a hoax 911 call." Deputy Douglas stated someone called 911 saying Ted was highly intoxicated, physically abusive, and was covering a wide variety of random subjects in a call that lasted six minutes. The deputy assessed the situation and stated there were no signs of intoxication by anyone and everything was completely normal (see report attached). He also said he thought chairs would be flying out the windows based on the information from Michelle. He asked Alyssa if she was scared of her dad and she said no. He asked if her dad had ever hit her and she said no. He talked to Alyssa for a period and explained what her mother was doing was wrong and the dangerous situation her mom created for the deputy, the public and our family. The deputy called Michelle back and advised her of the situation. Michelle responded and said she thought she would get in trouble. Exhibit 23. 16. Michelle alleges that in April 2018, she had to take Alyssa to the doctor because she had Scabies and alleges that I did not respond to any information about her condition. This is not true. The fact is, Alyssa had a slight rash under her right arm in February that Beth and I were treating at home with hydrocortisone, change of soap and deodorant. Over the next month or so, Alyssa did not complain of a rash or itching. Exhibit 24. Michele sent an Our Family Wizard (“OFW”) message stating Dr. Wright is "treating" her for scabies. She did not say if she was diagnosed with scabies. Exhibit 25. Dr. Wright's summary of the office visit shows Alyssa's diagnosis as "Rash and other nonspecific skin eruption (primary)". Nowhere does it state a diagnosis of scabies. Exhibit 26. 17. Alyssa saw her therapist, Alexia Camfield, in late April 2018. After her session, the therapist contacted CPS to investigate me regarding Alyssa’s discussions with her and her concerns for Alyssa's emotional and mental stability and physical appearance. SUMMARY - CPS "Ruled Out" all allegations. Additionally, Alexia Camfield notified me that she did not think the accusations were true but had to file them for fear of losing her license. It was later determined by CPS the information Alexia used to file with CPS was part of a fabricated plot by the mother, Michelle. I emailed Alexia Camfield on 01/26/18 asking Alexia for advice about a crying episode at school where Alyssa stated that she couldn't get mom up until 7:30 that morning and that her mom was very sleepy the night before. I was concerned that Alyssa could not wake her mother. Page 4 of 9Michelle was also making statements to Alyssa that she was going to have me thrown in jail, discussed with Alyssa the multiple lawsuits she filed against me, etc. 18. On 03/28/18, Alexia and I had’an email exchange concerning Alyssa's becoming upset the day before the last few counseling appointments and going to see her Aunt Emily (a teacher at her school) upset and crying. Alyssa stated to me that she no longer wanted to attend the counseling with Alexia. Additionally, Alyssa had been going to her Aunt Emily's classroom crying the Monday she returns from visits with her mom. Alyssa was upset that her mom was discussing events in Michele's life, some being horrific, and most being fabricated and becoming increasingly concerning. These discussions were increasing. I mentioned these conversations between Michele and Alyssa were causing her stress and in fact, my family noticed a change in Alyssa after visits with her mom. Alexia asked me if she could talk to Alyssa about this and I agreed. Alyssa had stated she just wanted her mom to stop. Exhibit 27. 19. Email exchange dated 04/23/18 between me and Alexia where I voiced my concerns that Michele had said Alyssa was going to see the school counselor (which was false), among other concerns including the increasing drama Michele was creating. This was three days before Alyssa's appointment. This was also the day Michele called 911 to my home that evening. Exhibit 28. 20. Michelle alleges that on or about April 20, 2018 Alyssa wrote a letter to her therapist, Alexia Camfield, prior to her baptism expressing her thoughts and issues and ongoing difficulties with me and my care for her. I learned of this letter during the CPS visit on Tues, 05/01/18, and have not seen the letter. Alyssa had an appointment with Alexia on 04/26/18, which is the date CPS said Alyssa and her mom brought a letter to the session (not written at the session). Michele states the letter was written prior to her baptism (04/21/18). The morning of Alyssa's appointment on 4/26/18 with Alexia, Beth and I overheard Alyssa on a Facetime chat with friends. One friend asked if she had gotten her "surprise" yet. Alyssa responded, "my mom said I will get it if I do good in therapy today". This was confirmed by CPS when they were at my house on 05/01/18. They took Alyssa outside and asked her about the letter. CPS came back in and talked to me telling me I would be cleared of all accusations. CPS confirmed the following to me and Beth- Alyssa stated her mom promised her a present if she wrote the letter and gave it to Alexia Camfield. Alyssa told CPS she knew the letter was not true. CPS asked Alyssa why she did not tell them in the school interview the letter was false and her mom forced her to write it to gain a surprise. Alyssa stated she was worried I would punish her for lying. CPS called a supervisor while at my house to get approval there would be no restrictions put on me. 21. Michelle alleges that I continue to disparage her in front of Alyssa on a regular basis. She stated that I said “Your mom has mental issues. The counseling is for your mom not me.” Page 5 of 9To clarify, Alyssa had told her cousin Jake that her mom told her that CPS was investigating her dad because he was going to a "mental doctor". This was not true. The above text they reference is cut and paste out of context. The part of the text cutout was an accusation by Michelle that CPS is involved because I am seeing a mental doctor. 22. Michelle alleges that Kelly Lowe was designated as Alyssa’s initial counselor at her school. Madeley Ranch Elementary. She alleges that Alyssa complained that the school counselor was not concerned or failed to show concern regarding complaints Alyssa was making relating to her environment at her father's home. She also alleged that she requested a meeting with the principal which resulted in Alyssa being able to have an “open door” policy with the principal and assistant principal. This is not true. Alyssa has never had a problem going to see Kelly Lowe, as she did frequently three to four years ago when Michele was having issues with drinking and frequently abandoning Alyssa. Alyssa has known Kelly Lowe since Kindergarten. It is not typical of Alyssa to complain. When Beth and I had a meeting with Kelly Lowe to see if she had been asking to come in (one of many things discussed), she said Alyssa had not asked to see Kelly Lowe. Kelly said the only time it came up was when Michele was up at the school for lunch and would ask Kelly to pull her from class to talk to her. Kelly checked with Alyssa's teacher and the teacher stated Alyssa was getting straight A's, behaves well and is one of the most popular kids in the class. Kelly refuses to pull Alyssa when all appearances are she is excelling. Ted discussed with the school how great Alyssa is doing and is concerned that ALYSSA's success seems to be something Michelle seems to want to discredit with school officials. There is no "open door" policy with the Principal and Assistant Principal at Madeley Ranch, as they do not handle the counseling of children. Any child can see the Counselor at any time if needed. 23. Michele alleges that in May 2018, Ted Krauiis took away Alyssa's phone for having an opinion on Walmart's sheets and called her a-”stupid spoiled brat”. She alleges that I did not respond when she questioned me about this. Again, this is a false statement. Alyssa's phone was taken away for being disrespectful when discussing getting a new sheet. She stated that "Walmart was not good enough quality for me". I explained there is nothing wrong with sheets from Walmart and that our family and her grandparents had the same. She had been disrespectful when Beth sent her pictures on sheets while at Walmart. Exhibit 30. She wrote an apology letter to Beth as well. Exhibit 31. During the discussion, Alyssa stated a girl at school called her a "spoiled brat". I replied that if she acts at school the way she was acting right then, that the girl was correct. I never said STUPID. Exhibit 32. 24. Michele alleges that later in mid-May, 2018, Alyssa needed a training bra and had to wear one all week because she had no others at her father’s house. She alleges that this caused her “bad hygiene.” - Page 6 of 9This is untrue. Alyssa has several bras at my house. 25. Michele alleges that on or about May 19 and May 20. 2018, I sent texts to our daughter regarding the CPS investigation and my thoughts toward Michele. I spoke to Alyssa regarding these texts and explained to her that I was frustrated after receiving an increasing amount of inflammatory OF W message over the last six months, Michele creating fabricated scenarios with school officials, questioning the doctor when not in possession over a minor flu strain, randomly calling 911 and using Alyssa to create false allegations with the counselor, etc. Michelle was also providing daily updates to Alyssa on the CPS investigation (which were all based on fabrications and everything was ruled out). I did speak with Alyssa apologizing for the tone of the text. Exhibit 33. I understand my response on May 20th was wrong and I am now attending counseling to deal with the repeated drama and fabricated escalations Michele continues to pursue. 26. Michele alleges that on or about May 20, 2018, she received another email from me berating her for her involvement with the CPS investigation which was based on Alexia Camfield’s On 04-23-18, I expressed in an email exchange with Alexia that I was frustrated and responded to Michele after she had constantly sent accusations. Exhibit 34. I was frustrated after receiving a huge amount of OF W emails that were increasing in both size and intensity. Michele created fabricated scenarios with school officials, questioning the doctor when not in possession over a minor flu strain, randomly calling 911 and using Alyssa to create false allegations with the counselor which resulted in a fabricated CPS case. Michelle was also providing daily updates to Alyssa on the CPS investigation (which were all based on fabrications and everything was ruled out). 27. Michele alleges that on May 21, 2018, Alexia resigned as Alyssa’s therapist because of ongoing issues with me. In fact, Alyssa stated in March she no longer wanted to attend counseling with Alexia. Alyssa had cried to her Aunt in March about attending counseling with Alexia (See emails attached between Alexia and me) The CPS investigators revealed to me and Beth that Michele was bribing Alyssa to make false statements to Alexia. The counseling process is completely poisoned and cannot be productive in this scenario. It also likely explains Alyssa not wanting to attend as she was being pressured to lie to receive a big surprise for following along with the plot. 28. Michelle alleges that on or about June 1, 2018, she received an email from the school principal Shelby Smith, regarding Alyssa's State of Texas Assessments of Academic Readiness ("STAAR") writing which was reviewed and flagged by the Texas Education Agency program. Page 7 of 9Michele alleges that it is apparent from the writing that Alyssa is having a very difficult time at my home and that she shared her thoughts in writing about her difficulties living at my home. Alyssa told Beth that part of the STARR text was a creative writing assignment and they had to use their techniques to keep the reader interested. There were many writing assignments around this same subject. Attached hereto as Exhibit 35 is another assignment Alyssa completed talking about how great it is to be home with me, Beth and her step sister. 29. Michele alleges that she is well acquainted with the present environment of Alyssa and that Alyssa’s present environment endangers the Child's physical health or significantly impairs the Child's emotional development. She alleges that I continue to slander and libel her directly and in front of Alyssa without any explanation or concern and that I act against the child's best interest. She alleges that the requested Order is necessary because the Child's present circumstances significantly impair the Child’s physical health and/or emotional development for which she has no other adequate remedy at law. This is also False. There is no scenario where Michele can be "well acquainted" with the present environment of the child in my possession. I remarried 2 years ago. Michele has not stepped foot in my residence in 3+ years. At times, Beth and I had to speak to Alyssa about different events that Alyssa was talking about after returning with her mother a few times. During one of those talks, Alyssa responded by saying "moms stories change, and they are about Dad" and "I know that didn't happen because I was there.” Each talk between Ted and Alyssa ALWAYS included that we are happy she was spending time with her mother. Beth and I also said, "we are happy when you are having fun and spending time with your mom." I always kept it positive. Excluding the text incident, I nor any family member has ever said a disparaging word about Michele to Alyssa. Attached hereto and marked as Exhibit 36 is a timeline of conversations through Our Family Wizard. Attached hereto and marked as Exhibit 37 is a timeline of Alyssa’s medical and dental appointments. It is without a doubt that Michele is attempting to cause me as much grief as she can in an attempt to beef up her position in the modification suit filed by her. It is my hope that the Honorable Judge will see clear to grant the Motion to Dismiss for Failure to State a Judiciable Cause of Action filed concurrently herein. Alyssa is very happy in her present environment and expressed this on many occasions. See Exhibit 29 attached hereto. Further affiant sayeth naught. JT2Y 2 TED KRAULIS Page 8 of 9STATE OF TEXAS § COUNTY OF MONTGOMERY § SIGNED under oath before me on August 21, 2018. hed Ty halZ. Notary Public, State of Texas A McDONALD LN ry Public STATE OF TEXAS 1D#79122 My Comm. Exp. April 16 Page 9 of 9‘The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 http://www.OurFamily Wizard.com Info@OurFamilyWizard.com Message Report Ted Kraulis generated this report on 05/28/18 at 11:05 AM. All times are listed in America/Chicago timezone. Message: | of | Date: 12/27/2017 6:53 PM From: Michele Kraulis Jo: Ted Kraulis (First View: 12/27/2017 6:55 PM) Subject: Drappt Attachments IMG_9561.JPG IMG_9566.JPG IMG_9565.JPG Ted, I took Alyssa to Dr. Wright's office this morning because the congestion in her chest had gotten worse and she started complaining about her ear hurting yesterday. Suedafed wasn't cutting it. She's taken a dose of z-pac today and I'll send the rest with her tomorrow to finish the last 3 days. Please see the attached invoices for the doctor and prescription for partial reimbursement. Also, I was advised she had not had her yearly check-up since 2016. I booked that Jan 18th at 4:30 and she will be getting a flu shot then as well. Alyssa said she had not had one yet. Alyssa also told me this summer that she had not been to the dentist and still has not. Her appt is Jan. 25th at 3:00. Asa reminder, her appt with Alexia Camfield is Jan 17th at 3:00. Thanks, Michele Exiilett | awe gs A | . VLE OAPI ALYSSA KRAULIS La we 68.96 18811 Montgomen oy ez tn 42127117 (713)538-6648. 773864992 ix 9.0 mi MIX 9.0 mi “Yo ur Insurance Saved You: $26.03 ide for important details . your medication. — ie 5 Etna.08 ATION AZ ity 15 IROMYCIN 200MG/5ML SUSP 15ML Your Walgreens Pharmacy Location 18900 Highway 105 W Montgomery, TX 77356 (936)582-0002 DOCTOR C. WRIGHT, MD PATIENT = ALLERGY ALLERGIES TORY NOT Kh iONS GIVE 5 ML BY MOUTH ONCE TODAY 2.5 ML BY MOUTH EVERY DAY FOR DAYS 2 BEFORE DOCTOR mycin Orai Suspension lay ZITH roe TELL YOUR DOCTOR: If you “tevin have any of hoarssnes . A fast heart ng in ble swallowing gor discharg pi S common to. have y of t bowel problem (ci or st check nenhlams treat loose, stools wi DESCRIPTI ~~ or swelling.of the mouth, tace, ‘lips, S it. A heartbeat. that does not ‘feel earing. Hearing: loss. Chest:pain or‘pressure. ures. Very bad dizzitiess or passing out: ig. Fever. Swollen-gland. Vaginal larthea, when taki ad form of diarrhea-called Clostridium ociated diarrhea (CDAD) mayxoccur. is): CDAD.may-happen wmonths after.you'stop Sometimes, is one, any err d 2 e you are ng this drug.or-within:a. do tor abou we iaking it. Cail your doctor.right away if you ave Stomach pain or. * G ~~ cramps, very loose watery stools,;.or loody stools. Do not tr g with-your.doctor. Very | Sve hannanad ieith this rir‘The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 hitp://www-OurFamilyWizard.com Info@OurFamilyWizard.com Message Report Ted Kraulis generated this report on 05/28/18 at U1:14 AM. All times are listed in America/Chicago timezone. Message: 1 of 1 Date: 01/15/2018 12:26 PM From: Ted Kraulis To: | Michele Kraulis (First View: 01/15/2018 12:26 PM) Subject: Alyssa’s appt Alyssa tested positive for Flu A. Her ear is bothering her but not infected...just swimmers ear. She will be out all week. Her yearly check has been canceled. She will need to get a flu shot this weekend to cover other strains. Please reschedule her counseling appointment. Her teacher is sending her work home. Will let You is she starts feeling worse, but she is feeling ok and no fever now. Exibit 4SSM SUNT KRAULIS, ALYSSA MARIE 092340 5/29/2018 3500 Madeley Ranch Rd MONTGOMERY, TX 77356 936-276-4600 To the Parents/Guardians of: KRAULIS, ALYSSA MARIE 48811 W COOL BREEZE LANE MONTGOMERY, TX 77356 ‘SERRILL, ANDREA C 4TH SOC STU 99 4TH MATH 97 4TH SCIENCE, 98 4TH MUSIC — 4TH ART E 4TH PE E nmammmmm 99 SERRILL, ANDREA C 96 SERRILL, ANDREA C 97 SERRILL, ANDREA C E BANEY, MARY E BROWN, IVY STROADE, KATIE. g Shit Days Present 32 41 36 Days Absent 0 3 4 Excused 0 0 4 Unexcused ° 3 0 Times Tardy 0 Q 0 [Promotion to the next grade level shall be based on an overall laverage of 70 on a scale of 100 based on course-level, grade-level standards \essential knowledge and skills) for all subject areas and a grade of 70 in readingftanguage arts and mathematics. A= 90-100 E = Excellent 30-89 $= Salisfactory 5-79 N= Needs Improvement ID = 70-74 U= Unsatisfactory IF = 69 & Below TEA Campus Rating: Met Standard with 1 Recognition lON MISD WEB PAGE UNDER TxCONNECT PARENT PORTAL IRE-REGISTER YOUR STUDENT FOR THE 2018-2019 SCHOOL YEAR! BEGINNING THE LAST WEEK lOF JULY - for help with Parent Portal email donna.morris@misd.org seas PROMOTED Exhibit leKRAULIS, ALYSSA MARIE 092340 To the Parents/Guardians of: KRAULIS, ALYSSA MARIE 48811 W COOL BREEZE LANE MONTGOMERY, TX 77356 it 936-276-4600 TORCOLETTI, SHANNON TORCOLETTI, SHANNON TORCOLETTI, SHANNON TORCOLETTI, SHANNON STROADE, KATIE Eutoareines) fel |A= 90-100 1B = 80-89 IC = 75-79 ID = 70-74 IF = 69 & Below [Promotion to the next grade level shall be laverage of 70 on a scale of 100 based on course-level, grade-level standards {essential knowledge and skills) for all subject areas and a grade of 70 lin reading/language arts and mathematics. Excellent S= Satisfactory N = Needs Improvement insatisfactory ‘TEA Campus Rating: Met Standard with 1 Recognition FOR RETURNING STUDENTS REGISTER ONLINE FOR 2017-18 SCHOOL YEAR ION MISD WEB PAGE UNDER TxCONNECT PARENT PORTAL - AUGUST 7th THRU AUGUST 14th, se iat 3RD LANG ARTS 98 98 98 o1 3RD MATH 96 97 97 93 96 95 E 96 3RD SCIENCE 9993 96 100 100 100 E 98 3RD SOC STU 100 99 400 =©100 100 100 E 100 3RD PE — HE eE c€ HE —E c— HE senate = a Days Present 35 39 46 168 Days Absent 2 1 4 1 5 Excused 2 oO 4 0 3 Unexcused o 1 0 1 2 Times Tardy 0 0 0 0 o 08" PROMOTED Exhibit 7The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 { hittp://www.OurFamilyWizard.com Info@OurFamilyWizard.com Message Report Ted Kraulis generated this report on 05/28/18 at 11:10 AM. All times are listed in America/Chicago timezone. Message: 1of! Date: 01/03/2018 2:20 PM From: Michele Kraulis To: Ted Kraulis (First View: 01/03/2018 2:22 PM) Subject: Business relationship Ted, T.want to be crystal clear that our relationship is strictly business-like. That’s it. For the sake of Alyssa, we need to be cordial with one another at functions. She notices. Thave my reasons for forgiving you, but I will never, ever, ever forget your actions and behavior before our divorce when I was extremely sick, how you took me to the cleaners in every aspect of our divorce fully aware of my condition, and the constant abuse, harassment and continued issues in the past 830 days since I got sober. Iwish you a healthy, happy and prosperous new year. Regards, Michele Exhibit gMessage Report ‘The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 http:/Awww.OurFamilyWizard.com Info@OurFamilyWizard.com Ted Kraulis generated this report on 05/28/18 at 11. ':06.AM. All times are listed in America/Chicago timezone. Message: Date: From: To: Subject: Ted, loft 01/01/2018 11:00 AM Michele Kraulis Ted Kraulis (First View: 01/01/2018 11:01 AM) January spousal support missing Again, the spousal support payment from you is not on time. I can hold you in contempt. Luckily, because you your childish actions with text messages sent from Alyssa’s phone to me (which she knows about and asked to read) opened the door for me to explain that I do have the ability to throw you in jail for simply not following directions. Kind regards, Michele Eywbot 9The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 http://www.OurFamilyWizard.com Tnfo@OurFamilyWizard.com Message Report Ted Kraulis generated this report on 05/28/1. 8 at 11:13 AM. All times are listed in America/Chicago timezone. Message: 1 of 1 Date: 01/14/2018 6:32 PM From: Michele Kraulis To: Ted Kraulis (First View: 01/14/2018 6:34 PM) Subject: Alyssa fever Ted, Alyssa let me know she’s running a fever. Please Jet me know what the status is in the morning. Or if something changes this evening, that as well. ‘Thanks, Michele Evhibit 0The OurFamilyWizard® website 1302 2nd St NE Suite 200 Message Report Minneapolis, MN 55413 http://www. OurFamilyWizard.com Info@OurFamilyWizard.com Ted Kraulis generated this report on 05/28/18 at 11:14 AM. All times are listed in America/Chicago timezone. Message: lof! Date: 01/15/2018 9:52 AM From: Michele Kraulis To: Ted Kraulis (First View: 01/15/2018 9:58 AM) Subject: Alyssa doctor Ted, What time is Alyssa’s doctor appt today? Kind regards, Michele Eyhilort (|Message Report ‘Minneapolis, MN 55413 ‘The OurFamilyWizard® website 1302 2nd St NE Suite 200 http:/Iwww.OurFamilyWizard.com © Info@OurFamilyWizard.com Ted Kraulis generated this report on 05/28/18 at 11:14 AM. All times are listed in America/Chicago timezone. Message: Date: From: To: Subject: lofi 01/15/2018 12:26 PM ‘Ted Kraulis . Michele Kraulis (First View: 01/15/2018 12:26 PM) Alyssa’s appt Alyssa tested positive for Flu A. Her ear is bothering her but not infected...just swimmers ear, She will be out all week. Her yearly check has been canceled. She will need to get a flu shot this weekend to cover other strains. Please reschedule her counseling appointment. Her teacher is sending her work home. Will let You is she starts feeling worse, but she is feeling ok and no fever now. Eylniloit 12‘The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 hetp:Awww.OurFamilyWizard.com Info@OurFamilyWizard.com Message Report Ted Kraulis generated this report on 05/28/18 at [1:15 AM. All times are listed in America/Chicago timezone. Message: 1 of | Date: 01/15/2018 5:13 PM From: Michele Kraulis To: Ted Kraulis (First View: 01/15/2018 5:31 PM) Subject: Tamiflu prescription Attachments Dr._Wright Flu_A_transcript_1-15-18.pdf Tamiflu_prescription pdf Ted, ‘After speaking with Alyssa earlier, she informed me she was not prescribed Tamiflu. To the best of my knowledge, the conversation was ¥ around kids throwing up on it. That's the liquid form. So Dr. ‘Wright called in the pill form for me for Alyssa as she needs to start on it asap (she's still within the 48 hr window) to help lessen the symptoms. I will be bringing it over shortly so please have her come out to get it so I can see her. Trescheduled her yearly for Friday January 26th at 4:15 because she has her dentist appt on Thursday January 25th. Dr. Wright's office informed me that most everywhere is out of children's flu shots. I will check around to see ifI can find a pharmacy, as suggested, that still has them so she can get one this weekend. “Alyssa tested positive for Flu A. Her ear is bothering her but not infected..just swimmers ear. She will be out all week. Her yearly check has been canceled. She will need to get a flu shot this weekend to cover other strains. Please reschedule her counseling appointment. Her teacher is sending her work home. Will let You is she starts feeling worse, but she is feeling ok and no fever now." Kind regards, Michele Exhibit 13Summary View for KRAULIS, ALYSSA Page 1 of 2 Progress note Patient: KRAULIS, ALYSSA Provider: Michael Wright, MD Account Number: 10931 DOB: 03/17/2008 Age: 9Y9M Sex: Female Date: 01/15/2018 Phone: 832-338-6466 Address: 18811 W COOL BREEZE LN, MONTGOMERY, TX-77356-4992 Subjective: Chief Complaints: 1, FEVER Acc:Mom. 2. Sick. HPI: General: . . Last PM pt was c/o an upset stomach, and today she woke up with a fever 100.7 and her ears are bothering her. ROS: GENERAL: GENERAL: denies change in activity. HEENT: denies headaches, sore throat. RESPIRATORY: denies shortness of breath, denies wheezing. GI: denies abdominal pain, vomiting, diarrhea or constipation, no decrease in appetite, DERMATOLOGY: denies rash. Medical History: Surgical History: Denles Past Surgical History. Hospitalization/ Major Diagnostic Procedure: Denies Past Hospitalization. Family History: Mother: alive, substance abuse recovery. Father: alive. Social History: Exposure to second hand smoke? No. IN 3rd GRADE, golf. Medications: Taking Advil , Medication List reviewed and reconciled with the patient Allergies: N.K.D.A. Objective: Vitals: Wt 59.7, Temp 98.2 CS, LVN. Examinati Examination, General: a GENERAL APPEARANCE: well nourished, no acute distress, non-toxic appearing. HEENT: TMs normal, canal erythema, bilateral conjunctiva clear without drainage, nasal congestion, rhinorrhea, pharynx and tonsils normal, moist mucosa, no oral lesions. NECK: soft, supple, no lymphadenopathy. LUNGS: clear to auscultation bilaterally, no rales, rhonchi or wheezes. HEART: regular rate and rhythm, normal $1S2, no murmurs. ABDOMEN: soft, non-tender/non-distended, no mass or organ enlargement . SKIN: no rashes. NEURO: normal strength and tone. Assessment: Assessment: 1. Influenza due to identified novel influenza A virus with other manifestations - J09.X9 (Primary) 2, Otalgia, bilateral - H92.03 Plan: 1. Influenza due to identified novel influenza A virus with other manifestations Start Tamiflu Capsule, 30 mg, 2 capsule, Orally, twice 2 day (bid), 5 days, 20, Refills 0 . LAB: Rapid Flu Positive Flu A Pos + Flu B Neg Notes: supportive measures. monitor. 2. Otalgia, bilateral . . | . Start Ciprofloxacin-Dexamethasone Suspension, 0.3-0.1 %, 4 drops into affected ear, Otic, Twice a day, 7 days, 1, Refills https://eclinworks1 -mhhs.org:93 33/mobiledoc/}sp/catalog/xml/printChartOptions,jsp?encounterID=5 1769... 1/15/2018 Ext tort 4Summary View for KRAULIS, ALYSSA Page 2 of 2 oO. Notes: supportive measures. Follow Up: pm Provider: Michael Wright, MD Patient: KRAULIS, ALYSSA DOB: 03/17/2008 Date: 01/15/2018 * bttps/feclinworks1.mhls.org:9333/mobiledoc/}sp/catalog/xml/printChartOptions jsp?encounterID=51769... 1/15/2018 Exh 4 lant,The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 http://www. OurFamilyWizard.com “ Info@OurFamilyWizard.com Message Report Ted Kraulis generated this report on 05/28/18 at 11:15 AM. All times are listed in America/Chicago timezone. Message: 1 of L Date: 01/15/2018 6:28 PM From: Michele Kraulis To: Ted Kraulis (First View: 01/15/2018 6:37 PM) Subject: Refusing me at gate Ted, Just documenting you refused me at the gate with the tamiflu prescription. Kind regards, Michele Exhilort 1S‘The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 Message Report http://www. OurFamily Wizard.com Info@OurFamilyWizard.com Ted Kraulis generated this report on 05/28/18 at 11:50 AM. All times are listed in America/Chicago timezone. Message: | of 1 Date: 01/18/2018 11:12 PM From: Ted Kraulis To: | Michele Kraulis (First View: 01/18/2018 11:12 PM) Subject: Engaging Mr. Brass and Laura Watson Hello Michele: The events of this week were quite theatrical on your part. Ifyou take Alyssa to the doctor and treat her-I will respect you are doing the proper thing, I have been doing exactly what the doctor has recommended. It is challenging when the doctors office is calling me repeatedly about your actions. At this point, there is no legal proceedings between us. [am being sent emails where your attomey is continuing to copy Laura Watson ‘on false items. I have informed Mr. Brass that if there is future Jegal proceedings I will not agree to use her as the amicus or mediator. Please inform your legal representation to discontinue copying her as she will not be an agreed part of legal proceedings based on this unprofessional behavior. Mr. Brass agrees and has sent to your representation the same information. Additionally, I have been informed Ms. Watson could bill for this continued involvement. I want to again stress - I will not pay additional invoices from her since there is no litigation and I will refuse to sign on additional engagement. If a bill is presented from your side involving her - that is your responsibility since you are engaging her. For the record - I think Laura is a tremendous person and advocate for Alyssa. I am not going to send to Laura my side of the situation since she is not involved and Mr. Brass and I struggle to understand why this is happening on your side. The entire goal of the year long mediation was to get a long term solution. My understanding is that was achieved. There is no contact from my side to you. Your Family Wizard communications continue to harass me, your representation continues to provide misleading information to Mr. Brass and Laura Watson (who are both not involved) and now put us in a position where Ms. Watson will never be involved again. Thank you for your consideration and I hope you can respect the Jaw and new court orders signed. Respectfully, Ted. Exhibit |The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 http://www.OurFamilyWizard.com Info@OurFamily Wizard.com Message Report Ted Kraulis generated this report on 05/29/18 at 02:51 PM. All times are listed in America/Chicago timezone. Message: lof 1 Date: 04/12/2018 7:47 PM From: Michele Kraulis Jo: Ted Kraulis (First View: 04/12/2018 7:52 PM) Subject: Razor for Alyssa Attachments Razor_for_Alyssa__attach.jpg Ted, Alyssa shaved her legs tonight for the first time. She wanted me to convey to you that she wants the Gillette Venus razor. Pic attached. Kind regards, Michele Exdnloit 17Message Report The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 http://www. OurFamily Wizard.com Info@OurFamily Wizard.com Ted Kraulis generated this report on 05/29/18 at 02:51 PM. All times are listed in America/Chicago timezone. Message: lofl Date: 04/20/2018 11:35 AM From: Michele Kraulis To; Ted Kraulis (First View: 04/20/2018 11:36 AM) Subject: Personal care for Alyssa Attachments _Personal_care_for_Alyssa__attach jpg Ted, Alyssa asked me last night if you ever respond to emails I send which is saddening. Can you please get her a razor for your house? Please see attached email I sent on the 12th. Kind regards, Michele Exh 16On Fri, 04/27/18 at 4:56 PM, Ted Kraulis wrote: To: Michele Kraulis Subject: RE: Razor for Alyssa Michele: Please quil sending messages stating what I am doing and not doing. I received the transeript of your 911 call today. Sheriffs department is being contacted next week to file a harassment report and I am going to be filing a civil slander case. You have been slandering me to many people in Montgomery and now did it on a 911 call which is public record. The allegations are false. Please stop sending anything unless it is a major / health issue. Have a nice weekend, Ted. On Fri, 04/27/18.at 6:52 AM, Michele Kraulis wrote: To: Ted Kraulis Subject: Razor for Alyssa Ted, This is the third request. Will you or Beth please buy Alyssa the razor she needs to have her legs? Kind regards, Michele Exdibit \4Message Report The OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 http://www. OurFamily Wizard.com Info@OurFamilyWizard.com Ted Kraulis generated this report on 05/29/18 at 03:04 PM. All times are listed in America/Chicago timezone. Message: of 1 Date: 05/14/2018 8:19 AM From: Michele Kraulis To: Ted Kraulis (First View: 05/14/2018 8:29 AM) Subject: Razor and bras Attachments Razor_and_bras_attach.jpg Ted, I personally went into school this morning and let them know a packaged razor and shaving cream is in her backpack. I have repeatedly asked you to provide this necessity for a month and you have failed to do so - so I did. I also sent two bras with her that we bought this weekend. Kind regards, MicheleThe OurFamilyWizard® website 1302 2nd St NE Suite 200 Minneapolis, MN 55413 http:/Awww.OurFamily Wizard.com Info@OurFamilyWizard.com Message Report Ted Kraulis generated this report on 05/29/18 at 03:04 PM. All times are listed in America/Chicago timezone. Message: lof 1 Date: 05/16/2018 7:56 AM From: Michele Kraulis Yo; Ted Kraulis (First View: 05/16/2018 7:57 AM) Subject: Razor and Vacation Bible School Ted, It is my understanding that you refused the razor yesterday from the principal at school. Why? She needs one and you have not been willing to supply one for her. Also, you have not yet responded to switching me weeks in June so Alyssa can attend VBS. I have repeatedly asked you about this. I would appreciate a response. Kind regards, Michele Exh No \ + 2)‘The OurFamilyWizard@ website 1302 2nd St NE Suite 200 Message Report Minneapolis, MN 55413 hap: Avww.OurFamily Wizard.com Info@OurFamilyWizard.com Ted Kraulis generated this vepovt an 06/13/18 at 10:10 PAL. All timas ava listed is: AmevicalChicago timezone, Message: J of 1 Date: 06/03/2018 7:39 PM From: — Michele Kraulis To: Ted Kraulis (First View: 06/03/2018 8:19 PM) Subject: Alyssa’s razor Ted, T attempted to send a razor home with Alyssa tonight and she wouldn't do it. She was so afraid you would find it, punish her for it and take her phone. Kind regards, Michele04/26/18 MONTGOMERY COUNTY SHERIFF'S OFFICE 25952 15:37 CALL DETAIL REPORT Page: 1 Call Number: 18234226 Nature: WELFARE CHECK Reported: 19:59:14 04/23/18 Revd By: CANDELARIA L How Revd: 9 Occ Btwn: 19:58:59 04/23/18 and 19:59:01 04/23/18 Type: 1 riority: 3 Address: 18811 W COOL BREEZE LN City: Alarm: COMPLAINANT /CONTACT . Complainant: , Name#: Race: Sex: DOB: *¥/**/%* Address: , Home Phone: Work Phone: Contact: MICHELLE KRAULIS Address: X:-095.653345 Y:+030.406047 U:00032 Phone: (713) 538-6848 RADIO LOG Dispatcher Code Zone Agne Description DOUGLAS K 20:01:01 04/23/18 5P1011 ENRT SO5 MCSO (MDC) Enroute to a call incid#=18A110601 cali=18511 DOUGLAS K 20:06:31 04/23/18 5P1011 ARRV SOS MCSO (MDC) Arrived on scene incid#=18A110601 cal1=18511 DOUGLAS K 20:58:04 04/23/18 5P1011 CLEA SO5 MCSO (MDC) Completed: call incid#=18A110601 call=185i1 COMMENTS CALLBACK=(713) 538-6848 LAT=+030.406047 LON=-095.653345 UNC=00032 49:59:41 04/23/2018 - CANDELARIA L REP 10 YEAR OLD DAUGHTER JUST CALLED HER ABOUT 10 MIN AGO 19:59:50 04/23/2018 ~ CANDELARIA SAYING HER FATHER IS INTOXICATED 19:59:53 04/23/2018 - CANDELARIA NOT BEING VIOLENT 20:00:10 04/23/2018 - CANDELARIA REP HAS SECONDARY CUSTODY 20:00:13 04/23/2018 - CANDELARIA THE FATHER HAS PRIMARY 20:00:24 04/23/2018 - CANDELARIA DAUGHTER DID NOT WANT TO GO BACK 20:00:46 04/23/2018 - CANDELARIA REP HAS ALWAYS TOLD HER DAUGHTER 20:01:13 04/23/2018 - CANDELARIA L L L tt L TO HER FATHER L TO STAY AWAY FROM THE DAD IS DRUNK L Exhibit 2304/26/18 MONTGOMERY COUNTY SHERIFF'S OFFICE 25952 15:37 CALL DE! L REPORT Page: 2 REP =X ABUSED REP IN THE PAST. . .ABUSED HER PHYSICALLY IN THE PAST 30:01:38 04/23/2018 - CANDELARIA L THI