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Court Ordered Coordinated Collusion to Try to Discredit Multiple Child Outcries

Court Ordered Coordinated Collusion to Try to Discredit Multiple Child Outcries

Complaint Against Kerry Smith, PhD, psychological evaluator

To the Board:

I am writing to you as the Executive Director of the Foundation for Child Victims of the Family Courts, which litigates and advocates for the protected civil rights of vulnerable children and protective parents.

Background of the complaints

Preliminary complaints are being filed to place various court actors on notice that their reports indicate a conscious, malicious attempt to obfuscate and deny the presence of life threatening, criminal abuse of a child. Attempts by multiple court actors to clumsily and maliciously discredit testimony of eyewitnesses to events, failure to disclose facts and circumstances of child endangerment, all are being documented in each individual complaint lodged against specific court appointees of Judge Martinez, as well as documenting information that indicates that various experts and court actors were well aware of multiple child disclosures before multiple witnesses.

The disclosures made by the child are well and fully documented by eye witnesses. But those responsible for reporting to the court, to police, and to child protective services, Kerry Smith, PhD, andattorney Blalock, assigned to represent the minor child, did nothing more than snidely dismiss the child’s statements.

As solid, self-assured and outspoken as the child is, her mother is sweet, immature, tremulous, fearful, and insecure. She seeks to please, not offend. She presents as hoping that the terrible acts of cruelty directed against her child are not true, a mistake. The harm to the mother by the husband she hoped would make her into a wife and mother, him into a husband and father in some existential wish has come to be understood with time and suffering, that the wish does not necessarily conform to reality. The reality is as the child reports, not as a nightmare that the mother would wish away.

Kerry Smith PhD was the court-appointed expert charged with writing the evaluation of the married adults with a child before the family court of Judge M Martinez, seeking divorce and custody assessment of their daughter.

Those naysayers had no competence, credentialed or otherwise, to pass judgment on the quality, quantity or inherent credibility of the child’s statements. As will be presented in evidence to follow in fully documented complaints and malpractice actions, the “team” of Blalock and Smith, in coordination with attorney for the Plaintiff, locked arms to exclude critical evidence. The material that should have been included, if only to appear as material to be explored and vetted, was not even mentioned. Critical material, of which there are literally hundreds or thousands of pages of excellent documentation, has been scrupulously left out of any mention whatsoever in reports of Kerry Smith PhD, evaluator, and attorney Cory Blalock.

The underlying argument is clear: how can the court rule on material unknown? The answer is that no ruling is possible if the material is not presented. Because victim statements are not being included in critical documents presented as an evaluation or a report from the attorney for the child, no direction, much less conclusion can be taken.

Allegations of abuse ignored

A plethora of documents and critical reporting has been consciously, deliberately excluded from the court record and has been noted in prior complaints. Chain of custody material has been violated and compromised by Judge Martinez and Attorney Blalock as is documented.Multiple court actors including Judge Martinez and attorney Blalock are aware of VSI video documentation that validates the child’s veracity. The court, as per Judge Martinez and attorney for the child, has scrupulously avoided dealing with VSI forensic investigation video documentation of child abuse disclosure for over one year.

Court actors have failed to investigate known, credible evidence, and have left a 3-4-year-old little girl in the unfettered custody of the biological parent she has articulately, repeatedly reported to authorities as the perpetrator of specific acts of sexual abuse. The acts of sexual abuse and physical abuse, harm and life-threatening endangerment will be enumerated below because these acts have failed to be documented by Kerry Smith PhD, evaluator, and Cory Blalock, attorney for the child, who interviewed the child on two occasions and has never written a report of his findings.

The massive amount of material documenting the child’s statements as well as evidence of physical and sexual abuse portrays a picture of an extraordinarily intelligent child, thoughtful, logical, and capable of conceptualization and humor beyond her four-year-old age. She is verbal, irrepressible, and committed to her right to speak, be heard and respected.

She is loving, willing to forgive, but honestly and clearly very frightened of her father and her paternal grandmother.

The four-year-old reached out for help to Kerry Smith PhD whom she described in curdling honesty describing Smith as “rolling her eyes” when she was supposed to be listening to me. “She appeared to look bored and as if she did not believe me.” With profound honesty and sadness the child stated, “I don’t think she cares.”

Kerry Smith has omitted any description of the child or her mother, yet fully and completely exonerates her biological father, accused sexual/physical abuser. But the material omitted by Kerry Smith PhD from the evaluation is critical to the evaluation. The nature of the fraud, the perjury committed by Smith, is of a level of criminality that writing to her licensing board and all oversight agencies that manage her license will not be adequate to address the degree of harm, personal injury, and trauma that she is responsible for inflicting on this child. Malpractice action will be filed against Smith to prosecute on behalf of the child and her mother.

We have an Affidavit stating that Kerry Smith PhD was a present, alert witness to the child’s disclosure, that she was aghast at what she heard….. and then never mentioned in her report.

Kerry Smith PhD was a witness to the child’s disclosure that her father asked her to touch his penis. This event is not commented upon by Kerry Smith PhD, though the entire event has been documented and verified in the Forensic review of the FCVFC.

As Smith describes her entrance to the father’s home she relates hearing the child screaming, yelling, crying that she hates him. Smith completely ignores this interaction between father and child and only relates to, once she is present and meets the father, Smith focuses on how loving the father is to the child and never asks – what just happened here?

The faulty evaluation

Dr. Smith stitched together a biased, vapid, superficial, edited “evaluation” document filled with inadmissible hearsay and little else. The facts and evidence in the case, known to Smith, have been gutted from the report, eliminated to make sure that there is no hint of evidence against the father or paternal grandmother.

All the elements of even the most basic, simple, psychological evaluation were missing. While she did provide the guide book instructions for interpreting scores, she failed to submit any form of meaningful comment or interpretation of what scores might mean for the actual subjects of the evaluation. She did not send scores to the MMPI center for analysis of content, thus leaving the court with an absolutely meaningless shell of a fabricated, manipulated report that represents fraud, duplicity, and criminal intent on the part of the writer to suppress criminal physical and sexual abuse of a child, as well as physical and emotional abuse of the child’s mother.

Dr. Smith’s report of 25 pages complete does not even offer the professional respect to the subjects to describe them as people with whom she has met and engaged, and as a result could offer some insight and reflection on theirdemeanor, presentation, affect, overview and meaningful interpretation of testing / personal engagement. In fact, the report is flat, meaningless, and devoid of content – largely because Kerry Smith made the conscious decision to eviscerate this report of all meaningful, relevant, factual material that clearly establishes the veracity and clarity of the child.

Smith has absolutely no experience or training to evaluate psychopathy, or evaluation of children, ages birth to one year, one year to three years, three years to five years, and on. For example, Smith misuses the technical term “magical thinking.” Magical thinking is a technical psychiatric term that relates to psychosis, not children accurately describing the abuse that has occurred to them.

Smith is so rude to the child, so underestimating the child’s intelligence and the child’s evaluation of her, that Smith does not expect the child to go back to respectful adults who in fact listen to her. The words of the child, her experience with Smith, is fully documented and recorded for use in the litigation process exposing Smith as a fraud and herself a child abuser by proxy.

Apart from noting the numerous faults and inadequacies of the “evaluation” written and submitted to the court of Judge M Martinez, the fact that critical evidence of an extremely dangerous environment in which the child was isolated with the father charged by the child with sexual abuse, assault, physical abuse, threats, intimidation, Kerry Smith never, not in one sentence of this report, provided any information as to allegations of abuse or misconduct. The Smith report states that PTSD diagnosis was ruled out when in fact hospital records state that the child’s diagnosis is PTSD.

Kerry Smith’s lack of cooperation

Kerry Smith has failed to cooperate with any questioning or sharing information demanded by the attorney for the Respondent, the child’s mother. She failed to appear for a deposition scheduled for Nov. 5, 2021, where she intended to allow the biological father unsupervised access to the child (page 25 on her report), with her recommendation of a person of the biological father’s choosing to be present at visitation, not in a supervisory role, but as a witness to the father.

Kerry Smith has failed to provide reports, records and documents of those experts with whom she spoke as per development of theories / assessments of the custody subjects.

Kerry Smith PhD failed to audio and videotape her interviews with the subjects that she met with for her report. All validity, reliability and credibility of the interviews is nonexistent.

Other Material Facts Omitted from the Smith “Evaluation”

Allegations about abuse by the grandmother

Kerry Smith PhD never mentioned, much less discussed the seriously concerning allegations related to the father’s biological mother, with whom he lives. The paternal grandmother has beenthe supervisor for her son’s visitation with his child, the individual accused of corporal punishment of the child when placed alone with the paternal grandmother.

The paternal grandmother has been accused of not only beating the child with a ruler, but also of “cutting” the child with a knife. A picture drawn of the paternal grandmother by the child depicts her carrying a knife. The allegations/statements made by the child, documented, known to Kerry Smith PhD, are not mentioned in her report though the allegations are chilling and are fully documented by photographs, documented statements, medical and police reports.

More disturbing allegations about the grandmother:

Leaving the father alone with the child as she wandered off for parts unknown for hours at a time…..

Allowing the biological father to take the child into his bedroom at night.

Driving with the child without her being placed in a car seat, sitting in the front seat of the car unbuckled, as witnessed by the mother. ……… unbuckled mother witnessed. The child told several people, “Grandma drives me in the car without my car seat. I am scared to drive with Grandma.”

The child also made these statements:

“I am scared of Grandma.”

“Grandma hates me.”

“Grandma washes my vagina angrily.”

“It hurts when she washes my vagina.”

“Grandma kissed my vagina with Daddy. They ate fruit out of my vagina.” Multiple, graphic, clear, explicit articulations of the child re: having a variety of fruits placed in her vagina and then having the father “eat” from her vagina.

Allegations of a dangerous pet

Kerry Smith PhD barely mentioned the presence of two dogs as members of the biological father’s household, even though one of them is described as a clear and present danger to the child. This dog, Scarlett, is described as having to be muzzled – all the time. Scarlett is described as extremely vicious, having savagely injured and wounded the other dog, as well as having been known to attack the child, who is afraid of it.

On one of the police visits, Scarlett bit a police officer who advised the family to get rid of her. The Animal shelter said they would not take her because of her history, and they advised to put her down. But the father would not agree; this dog is described as his preferred pet. It appears that he has chosen to ignore what can only be described as a clear and present danger to the child.

The FCVFC has extensive, in-depth knowledge of the relationships and dynamics existing between abuser parents and their animals. Vicious animals being given preferential treatment over children, or used to threaten and intimidate children, is an extremely important dynamic in an alleged abuser household. The dynamic in which there is an aggressive pet and a passive pet that is being abused is of course also quite notable.

For purposes of full disclosure, the FCVFC has a division devoted to dealing with pets housed in the homes of child victims. “Rescue Me And Me and Me” is the division that deals with rescuing and caring for at-risk pets from abusive households. The FCVFC provides medical care, housing, foster care or adoption services where required for vulnerable pets of all kinds. This information is being disclosed to assert our unique level of expertise in attention to the presence and meaning of pets in high-conflict homes.


The critical material excluded from the “evaluation” prepared by Kerry Smith must be considered to be fully invalid due to the conscious, planned, manipulated exclusion of material facts relevant to a fair, professional family and child assessment.

The number of factual, documented events consciously fully excluded from the Smith report are all related to events and facts that relate to child abuse, child endangerment, and child sexual abuse. All of the material consciously excluded must be stated as being known to Kerry Smith PhD.

The conscious exclusion of such material introduces fatal bias into the report and thus excludes the report from any possible use in any legal forum dealing with any hearing on behalf of the child.

The nature of the manipulation of the material excluded places the child in imminent harm of physical injury, emotional trauma and possible death by murder.

Jill Jones Soderman
Executive Director, FCVFC









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