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All You Have to Do is Make the Protective Parent Look Unstable

This is a letter the FCVFC sent to the Psychology Licensing Board about a psychological evaluation that appeared to be designed to discredit the protective mother. Family names are redacted.


Purpose of this Complaint

This complaint sheds light on the facts and circumstances that should have been addressed in Dr. Caroline Scheiber’s psychological report on Our Client. As a result, we will demonstrate that this report is filled with components that can only be called glaringly fraudulent.

Besides this complaint going to the Psychology Licensing Board, malpractices suits are being filed on behalf of the client that Dr. Scheiber sought to destroy.

Introduction to Our Client and her Family

Here is the client whose psyche and reputation Dr. Scheiber has tried to tear to shreds.

Our Client is the wife of Mr. X and mother of Son A and Son B, now 17 and 15 years of age respectively.

Our Client’s father was an engineer with hundreds of patents to his credit for work in the areas of Magnetic Resonance Imaging, light bulb filament technology, and microwave technology. He worked for the Department of Defense, Sun Electric, TRW, Zenith, and Phillips Magnavox, to name a few.

Early traumas and disruptions, including tawdry familial darkness, mobilized this woman to move away from a toxic past, to take hold of her own being, to strive to reinvent herself, to move toward health, and to develop her education and a career. As a tall, outgoing young beauty whose perfect face with blonde hair caused her to be compared to “Barbie,” Our Client was perceived as a Barbie doll on the runway to stylists and modeling agencies.

Her youthful aspiration to become an Olympic freestyle skater led to later athletic experiences such as skydiving, motorcycling, and other adventures. She became a bodybuilder and engaged in photographic modeling. She has had a stellar business career and then became a wife and mother. As a successful working mother, Our Client engaged in a lucrative, prestigious executive position, creating a financial network of property and assets.

Mr. X

The husband this client married pursued her for more than ten years. She took his pursuit of her as a sign of his love for her, not the narcissism of a depraved, driven, malignantly jealous stalker who had to prevail in his pursuit of her to gratify his need to conquer and control.

It appears that Mr. X took her love as a sign of weakness and stupidity and used her love to attempt to isolate, manipulate, and exploit her.

Mr. X, currently 55 years old, set out early on committing marital crimes that abusers typically commit (listed on the Duluth model, the domestic violence wheel of power and coercive control). It is as if he wanted to destroy his wife’s self-confidence, sanity, sense of self, career, her health, and relationship with her children, as well as her children’s stability and health.

In the early years of their life together, Our Client was unaware of her husband’s criminal history as a violent felon, or his sexual escapades and sexual deviance. But ignorance and denial could not last indefinitely. These were eventually erased by his vicious words and actions, his impulsive rages, his physical attacks of domestic violence, and the unidentified sexually transmitted diseases he passed on to her, with long-term consequences in both her physical health and her emotional well being, as well as that of the children. In 2010 he was convicted of domestic violence and child abuse.

For many years, “experts” told Our Client that her husband was “sick” and needed “treatment.” She tried to comply, offering help, support, and understanding, within the confines and limits of the program and the clinicians working with her and her husband for over a decade. In her drive to preserve the marriage and the relationships with the children, Our Client sought many sources for help with sexual disorder treatment for sex addiction. In this attempt, she engaged with close to 50 therapists over three decades.

More recent treatments for the husband have included twelve-step programs, safe shelters, human services, intervention programs, anger management classes, Love and Logic parenting classes, and an eight-day psychological profile.

However, this engagement in so-called treatment actually constituted a romp through the escapades of the Marquis De Sade, as the innocent spouse was treated to a chilling confrontation with the truth of a parallel life of which she was never aware existed.

At some point the husband saw that his wife was not going to easily relinquish all that she had and the life she had invested in. She was not going to back off and leave everything to him. So he began divesting her of all financial assets while at the same time divesting her of any intellectual credibility by having her appear, if not outright insane, at least incompetent to participate in her divorce or parenting future.

The husband’s sadistic practices included well-planned disclosures to his wife that as he knew in advance would send her into paroxysms of rage and despair. He had hidden cameras throughout the house, set to remote video engagement as soon as she reacted to his wrenching disclosures of his sexual escapades, including but not limited to telling her about his paramour of forty years, his sexual addictions, his sexual offenses, the incest had had committed against their sons, and multiple acts of financial fraud funding his double life, including using her credit and forging her signature to take out loans.

Then the videos were harvested and edited. Paul LeRoux, attorney for the husband for the past ten years, presented motions to the court using these “set up” videos to humiliate and disparage Our Client, without proper evidence submission.

The Sons

The two sons are currently ages 17 and 15. Both boys are tall, muscular, and handsome. Through the years these boys have been forced to watch their mother be viciously brutalized and held hostage, her mental state hijacked, powerless to come to her rescue. They are emotionally traumatized and disturbed young men.

Furthermore, the sons have criminal records from early on in their lives for crimes related to alcohol and drug abuse, theft and disorderly conduct. They were trained in and then assisted in criminal activity leading to felony charges. This led to placement on a criminal diversion programs and restorative justice program, through the Longmont DA’s office (Pattie Moreno) for minors. The children were both 12 years old (2015/2018 for instances that occurred as young as 10 years old, then revealed in the 7th grade).

The father is a felon, a fact noted by the F5, F3 convictions and another felony related to one or more DUIs. In 2013 when the father was arrested with a DUI and the boys were only 9 and 7, they were left with unsafe intoxicated adults only to be driven home the next morning still not knowing where their father was or why he had disappeared.

The husband had a large number of guns around his property, described as an arsenal in the house. The father taught the young boys from a young age to lie, cheat and steal. Further, he encouraged them to be sexually active with their teen female friends as well as with older women, as they learned to solicit hookups and conceal this criminal activity from their mother.

When pornography was discovered, the children were blamed and the father took charge, offering to “have the talk.” Instead, he gave these children locker room talk advice, sharing in individual sessions with each boy how they should “smell pussy to make sure it does not smell like a can of tuna” so they were able to not wear condoms and avoid STDs. The advice given was don’t tell your mother, don’t talk to cops, never tell the truth. Sexuality was a secret. Reports are that the husband had his sons pee in containers, while he was in court mandated programs.

One son has special needs IEP and 504 at the school district since first grade illiterate. He is the child “left behind.”

This son was so severely ill in 8th grade (age 13) that when taken to the doctor he had STD testing but was found to have illness from smoking cannabis, consuming alcohol, and daily ingesting hallucinogens including the drug Molly (Ecstasy). That led to ER interventions, shaming, reckless behaviors, and concealing illnesses. Spontaneous vomiting during sports events, fainting, insomnia, amnesia and psychotic breaks finally required more ER visits, which led to brain scans that identified other past injuries like traumatic brain injuries (TBI) with brain bleeds. This in turn was followed by referrals for evaluations and medical treatments, with inpatient recommendations.

The father refused to sign off for intervention treatments like addiction rehab facilities.

The other son, the “golden child,” was a straight A honors student, varsity athlete. The father exploited this son’s successes to help him conceal his own extramarital affairs.

But this son was also a drug addict and alcoholic, living a double life with a criminal lifestyle. mirroring his father’s values as a life member in a biker club. He was indoctrinated into the father’s motorcycle club, riding his own Harley and participating in tavern-to-tavern runs and rallies at 15, his father passing him off as 21.

The special needs subject, diagnosed as Dyslexia/ illiteracy, abdominal Migraines suicidal, depression (8 years old triaged into Children’s Hospital neurology headache clinics). This is a child who has been particularly marked for abuse by his father who denies his disabilities regularly calls him “lazy” ,”Pothead”. then instructed to “pull his head out of his ass”.

At well below the age of majority the father is still taking these two teenage boys to adult venues, drinking then driving with them, speeding aggressively and recklessly. Driving history is public record and extensive.

As a matter of record, Mr. X also took the old “Barbie doll” imagery to a different sphere, cutting off the heads of Barbie dolls and placing their heads on poles with their mouths duct taped, to be stuck on the back of his motorcycles in effigy. This the sons witnessed and even photographed.

Their father locks the boys out of their own domicile so that they have to wait for him until he returns home, either at a friend’s house or on the street. Their lives are chaotic, their physical and emotional health challenged, their schooling disrupted.

To make matters far worse, a series of obscene decisions made by a parade of family court judges have allowed this appalling situation to degenerate to the depths of corruption, as these two boys have been placed in the custody of this criminal father.

The two sons are now living in the custody of Mr. X. Only on a limited basis and in the presence of a court-approved monitor are they allowed to visit their home and pets and to receive their mother’s unconditional support and love.

No Help through Law Enforcement or the Court System

Through the years, reports made indicating that the abusive husband/father was high on drugs and alcohol were never met with consequences, however often reported.

Police were repeatedly unresponsive.

Long-standing Protective Orders were dismissed, leaving Our Client terrified and without assistance.

In her present situation in the family courts, the client has stated clearly and articulately that she feels that she has been “placed in a vice” with no place to go and no source of help in the family court system.

Regarding this “no source of help,” the client’s perceptions are accurate. The client was not able to retain legal counsel despite exhaustive attempts. Instead, she has been rejected by an inordinate number of attorneys within the jurisdiction.

Our Client paid consult fees and had her case accepted, only to find then that it was suddenly dismissed without explanation, or the attorney suddenly withdrew with claims that the husband owed the firm money. In fact, multiple firms had apparently had contact with Mr. X as a potential client, just before he confronted his wife with a demand for a divorce.

Dr. Scheiber and her Psychological Evaluation of Our Client

Dr. Scheiber was hired by a group of attorneys, blessed by a court that has enabled proceedings that have been meant to dismantle the client’s psyche, just as they have attempted to dismantle her marital assets and the lives and well-being of her two teenage sons.

The education and experience that Dr. Scheiber presents indicate that she is well trained in testing and scoring procedures. However, Dr. Scheiber is so uninformed about the client she seeks to disparage that she is unaware of the strengths of the client, such as her nearly perfect eidetic memory and her inveterate need for order, logic, and completeness.

These strengths have helped us to reconstruct the masticated version of events given by Dr. Scheiber in her evaluation, presented with the apparent intent to raise up Our Client’s soon-to-be ex-husband and to eviscerate Our Client with lies and defamatory statements.

Problems with the Psychological Evaluation

In the psychological evaluation, Our Client has described Dr. Scheiber as rude, dismissive, irritable, aggressive, and hostile, treating her in a humiliating, demeaning, and confrontational manner.

Upon review of Dr. Scheiber’s seventeen-page document, we find that it is replete with fraudulent statements about the client, with careless and negligent statements of psychological testing, missing critical topics relevant to any psychological evaluation.

Dr. Scheiber states that she herself conducted all phases of the work she claims to have performed. “Interviews, psychological testing, scoring, review of collateral information and report writing were conducted by Caroline Scheiber, PhD, MA”, so that there is no one else to blame for any problems of commission or omission on the testing.

Dr. Scheiber does not analyze, document, or support any of her disparaging statements about the subject client, Our Client. Her report appears to descend to the level of diatribe without stating the metrics, the science, or the meaning and impact of the terms she uses. She appears to be only intent on degrading and humiliating. She has engaged in techniques to denigrate a human being who has overcome incredible odds to become the survivor and conqueror she is today.

  1. Fraudulent “Testing”

Dr. Scheiber’s timeline of her meeting with the subject client indicates that she could not have administered the testing that she claims to have performed: the Minnesota Multiphasic Personality Inventory-3 (MMPI 3), the Rorschach Inkblot Test, and the Montreal Cognitive Assessment (MOCA).

We do not have proof that test material was forwarded to the MMPI headquarters for scoring, nor do we have the code presented by MMPI that attests to payment received to have scoring electronically calculated for authenticity. The client never “took a test,” was never given the instructions to answer the MMPI questions, in a room by herself with no one else present.

Therefore we conclude from Dr. Scheiber’s discourse that she conflated taking a history with administering the MMPI 3, which was never administered to the subject. The fact that there is no reference to scores or scoring, nor is there any interpretation of sets of scores, supports the thesis that Dr. Scheiber has confabulated the administration of an MMPI 3.

The Rorschach test requires a procedure as described by Hermann Rorschach psychodiagnostics – Verlag Hans Huber, Berne Switzerland. A diagnostic test based on perception was not properly administered to the client, who was asked to provide three conceptions of what she saw in cards hastily presented to her and then withdrawn.

The Sorenson Scale, used as a guideline by the Office of the State Court Administrator to protect client rights, was never administered or applied in any manner to protect the subject client’s rights. If the Sorenson Application had been applied, the subject client would have scored amazingly well, for as she has some conditions of concern, her cognitive strengths and natural intelligence and eidetic memory serve to compensate for injuries that may have been more problematic than they in fact are, despite the current traumatic experiences being inflicted on her.

  1. Primary Sources of Information: Husband and GAL

Dr. Scheiber lists two people as primary sources of information about her subject: (1) the Guardian ad Litem (GAL), Madeline Duncan, who requested the psychological evaluation, and (2) Our Client’s husband, Mr. X.

  • The abusive sex-addicted husband

As has already been shown in this complaint, Our Client, the subject of the evaluation, was the subject of fully documented extensive domestic violence, physical and sexual abuse charges, as well as the mother of the children who have been abused. But Dr. Scheiber never mentions the husband’s criminal history as a felon or his other extensive criminal history described above.

Dr. Scheiber’s report completely avoids the facts involving the husband’s psychiatric disorders and addictions. Dr. Scheiber had to be fully aware, following her evaluation of this subject’s husband, that he fits all criteria on the HARE scale for a psychopathy score as well as having active, ongoing sexual addictions. “Treatment” of this category of people is tantamount to giving them guidelines to abuse bigger and better. Dr. Scheiber had to know that this individual is not to be trusted in any relationship, accountability, or anywhere empathy plays a central role.

Because neither Dr. Scheiber nor the Guardian ad Litem had any interest in gathering this information, the facts related to his avoidance were never officially documented.

Rather, in her review of the edited videos provided by Mr. X (described earlier in this complaint), Dr. Scheiber refers to him in an informal and friendly manner as “Bill,” viz., “I also watched several movies provided by Mr. X that showed [Our Client] assaulting Bill….”

The lurid details of the means used by the husband father to evade consequences for drug and alcohol abuse are available in full detail from his sons.

Dr. Scheiber took the word of the husband, who wishes to take over his wife’s assets, leaving her with liabilities, and take full custody of the boys whose lives he has severely compromised and whom he can turn into further sources of income via application for SSI for both of them.

Dr. Scheiber interviewed the subject’s husband and then created an evaluation of the subject client, Our Client, which is evidently directed with conscious, malicious intent to thoroughly dismantle this client’s psyche in real time and as a report to the court to find her incapacitated.

  • Complaints against the Guardian ad Litem

Dr. Scheiber related that the major amount of history received was derived from GAL Madeline Duncan, an individual that the subject client did not trust for many well documented reasons. Ms. Duncan is familiar with this subject’s complaints against her, as she refers the client for a competency evaluation.

Some of these issues were shared with Dr. Scheiber, who reportedly dismissed the subject’s concerns. But the FCVFC has 100 pages (plus) of well-articulated complaints against Ms. Duncan, Our Client’s mistrust of her, and the accusations against her. Here are a few:

Ms. Duncan has summarily dismissed proof of Mr. X’s fraud and theft.

Ms. Duncan has excluded the subject client from all court proceedings, documentation orders, motions, and rulings. The subject client was not receiving any documentation until most recently as per the presence of the FCVFC.

Ms. Duncan does not answer Our Client’s questions.

Ms. Duncan related the husband’s reports that his wife broke into his house. But this has been denied, and given the subject client’s severe physical injuries to her knees and requiring a walker to be mobile, it is very hard to imagine her doing such a thing.

The subject client has seen Ms. Duncan as being aligned with her husband, who stood to benefit greatly from taking over all of the considerable marital assets.

Ms. Duncan was criticized for showing no interest in the boys and failing to attend to their needs.

Ms. Duncan was made aware of the significant list of concerns noted by the subject client in the divorce proceeding.

But in spite of all these valid reasons for concern, Dr. Scheiber liberally criticizes and ignores the subject client’s complaints about Ms. Duncan.

Dr. Scheiber has failed to include the client’s statements that clearly and meticulously nailed Ms. Duncan for every failure to answer her questions and do her job.

  1. Ignoring a Significant Source of Information

Dr. Scheiber references and dismisses her attempt to reach Judy Innes, “one of Our Client’s counselors,” but fails to note that this counselor treated both Mr. X and Our Client for approximately 10 years, more consistently and intensively than any other treatment professional. Dr. Scheiber then states that she did not seek information from this most significant source, saying it did not seem “clinically necessary” to seek any further information, any objective information from collateral contacts or medical information on the client.

4. Ignoring the Abusive Dynamic and Our Client’s extensive medical records

Any understanding of Domestic Violence Victim profiles begins with an understanding of the low self-esteem and the profound fear of being blamed for wrong doing, being shamed and punished (often corporally), the deep confusion, and other symptoms of post-traumatic stress disorder.

Our Client has been physically disabled since 2011. Documentation on her applications and hearings for SSDI in 2015-2018 as a homebound cripple, unable to work, was omitted. Currently she has ten disability qualifiers, most recently C-PTSD. All of this could be easily verified with a phone call to the primary care physician. Yet Dr. Schreiber did not think disabling conditions would be significant to include under medical history.

Dr. Scheiber made no attempt to gather medical records on the subject of inquiry in order to better understand the neurological or psychiatric anomalies that might be related to multiple well documented injuries sustained at the hands of the husband. This would also include an inordinate number of unusual sexually transmitted diseases that were substantiated as having been contracted specifically from him, dating from the period when the subject relates that she was aware of neither her husband’s sexual addiction nor the number of random partner with whom he was engaged.

  1. Ignoring Information about the Sons

Dr. Scheiber made no effort to inquire into the massive amount of information on the children or how that may relate to Our Client’s emotional state.

Dr. Scheiber’s report fails to even mention the unfathomable abuse suffered by the children at the hands of their father, who is well documented as a criminal. Completely ignored were the years of violent domestic abuse, sexual violence, infidelity, fraud, and theft of marital assets. Never mentioned are the issues related to well documented child abuse, teaching the children to become criminals, alcoholics, and drug addicts, hiding a deviant double life of sexual behaviors.

Further, as neither GAL Duncan nor Dr. Scheiber has had any interest in procuring medical records or interviewing the teenage boys, the information masquerading as facts that they have put forward is completely uncorroborated.

Perhaps Dr. Scheiber was fearful that the facts related to the life and experiences suffered by the wife and children would interfere with the plan to further enrich a depraved criminal alcoholic, drug addict, child abuser, domestic violence wife beater, psychopath, clearly the parent preferred by Dr. Scheiber as per the clearly pre-fixe allotted menu.

What the FCVFC is Doing

At the end of her “evaluation,” Dr. Caroline Scheiber stated she did not “recommend for Our Client to review this report on her own as she may become more distressed and decompensate further.” The report was then approved by Ms. Duncan and Judge Andrew MacDonald to be released to Mr. X and Our Client. The report was then emailed directly from Ms. Duncan to Our Client, at which point she opened and read the evaluation.

In much the same manner as the subject’s husband used techniques to shock, confuse, and demean her, so did Dr. Scheiber use similar techniques.

Consequently, the FCVFC will be filing malpractice actions on behalf of the subject of Dr. Scheiber’s fragmented, falsified psychological report, which has been used to further victimize the subject in question.

Each accusation presented by the report subject is documented in great detail as to precipitating events along with emails and other communications surrounding each complaint, offering detailed explanations as to the subject’s thoughts and reactions. Incidents and interactions are also documented. All of this material will be included in the malpractice documentation being prepared against Dr. Scheiber and against GAL Duncan. The detailed material contains intimate, disturbing material that upon first introductory contact we feel it inappropriate to send.

The experts working with the FCVFC include a world renowned forensic psychiatrist whose explicit, detailed reports will be included in further work being sent to this licensing board. All information and exhibits provided by our office are vetted, corroborated, and verified by objective sources. This includes information on the client’s husband as vetted through forensic criminal research and security background checks. Medical records and psychosexual evaluations are also subject to review by relevant members of our forensic team.

For these reasons, when it comes to the veracity of our statements, we can speak with a significant level of confidence. We expect to see this subject client, Our Client, fully vindicated.


Jill Jones Soderman
Forensic Advocate and Executive Director
Foundation for Child Victims of the Family Courts

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