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Angelica G. Hale3175 S. Sepulveda Blvd. #303Los Angeles, CA 90034

(310) 503-7717

Angelica G. Hale, In Pro Per ENDORSEDNOV 282011

Clerk of the Napa Superior CourtBy: J. OLIVER

Deputy

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF NAPA

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Conservatorship of Christian Angelo Vassell l;~:;;;~~6~~ VASSELL'SNOVEMBER 17,2011 REPLYDECLARATION

Date: December 7, 2011Time: 8:30 AMDept: B I

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My name is ANGELICA G. HALE, biological mother ofproposed conservatee Christian Vassell,

testifying in opposition to the Conservatorship petition ofLloyd Vassell. 'The following facts are

within my personal knowledge and if sworn as a witness I can and will truthfully and competently

testify thereto, except to those matters stated upon information and belief.

1. Petitioner states that the declaration I previously provided the court is irrelevant to Christian's

present and immediate needs. I will rely upon the good graces of the court to make the

determination ofwhat is relevant in my initial declaration. I believe it is all· relevant, including

the documentation that calls into question the moral and ethical conduct ofMr. Vassell.

REPLY DECLARATION OF ANGELICA G. HALE 1

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2. Mr. Vassell insists that the living arrangement for Christian and Taylor in 1999 was "foster

care" and not temporary respite. He goes on to falsely characterize my actions in leaving the

state of California as "abandonment."

3. As conclusive evidence ofthe nature ofthe children's living arrangement while my husband

and I were seeking work on the east coast I offer a sworn affidavit from the children's care

provider when I left California in April 1999: Mae Alderson. Ms. Alderson has been a care

provider for children for over 20 years. In her sworn affidavit, Ms. Alderson reveals intimate

details ofher relationship with Mr. Vassell that I had never known, such as him asking her for

money so he could feedJhe boys on the weekends. I remember him trying to take the TV when

Melvin wanted it to stay. Lloyd's home had a television that the boys could watch, and we fully

expected to make sure they had what they needed. Before we put our household items in storage

in Hercules, Lloyd brought over a close friend and took the boy's bunk beds to his own place in

Oakland. We gave Lloyd their beds before we left. We made absolutely sure Lloyd was part of

the planning before leaving them at Ms. Alderson's home, and he ALWAYS had her contact

information, and she had his. Whenever it suits him, Lloyd has amnesia.

4. In an email to Melvin Hale on March 19, 2009, Mr. Vassell categorically stated that: "I never

bad mouth Angelica to anyone!" This is exactly the opposite of the truth. Mr. Vassell has

systematically defamed and slandered me viciously from the very moment he took possession of

my children, documented as early as June 26, 1999. See the Thank You card I received from

Taylor and Christian in Exhibit A. Exhibit B, also provided as Exhibit # 25 from my original

Declaration, documents Mr. Vassell lying on me to a medical provider.

5. Not only did I not abandon my children, I have continued to financially and morally support

them. Exhibit C shows receipts for clothes that I bought for my boys in Alexandria, VA in the

REPLY DECLARATION OF ANGELICA G. HALE 2

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amount of$127.81, and a money order in the amount of $200, all ofwhich I sent to Mr. Vassell

in December 1999. It's only by the grace of God that I found these rapidly fading receipts,

printed on thermal paper. I have lost dozens of receipts just like them over the years.

6. Mr. Vassell and the North Bay Regional Center allege that I have not seen Christian since the

summer of2008. I provided clear and convincing evidence in Exhibit #20 of my previous

declaration that I was in Northern California in April 2010 to see both Taylor and Christian. In

addition, I also spent time with my children just three months earlier in December 2009. I would

like to use this recurring diabolical lie to expose the typical anatomy ofa Lloyd Vassell lie.

Rather than 'refer to Exhibit #20, which clearly shows me with Christian and Taylor and my frienQ.

Nora and her son Ryan at her home in Fair Oaks on April 16, 2010, Mr. Vassell tries to deflect

the truth by stating that I used Exhibit #19, showing me at Taylor's graduation in 2009 to prove

that I haven't seen Christian since 2008, which is a lie. I have attached Exhibit #20 to this

document as Exhibit D.

7. I believe that Mr. Vassell has always given himself over to moral impropriety in search of

financial gain and social acceptance, whether that gain comes via the children's Social Security

money, or from the wages ofhis wife Lauren, who made $93,000 in 2010 while Lloyd only made

$26,000; this according to Taylor's 2010 FAFSA (financial aid application for college),

-Exhibit E, which shows that Lloyd Vassell allowed Taylor, who is developmentally disabled, to

take out $19,000 in unsubsidized student loans. The FAFSA then goes to show that they

reported - $11,000 in income for the year. He refuses to comply with providing me the court-

required Income and Expense Declaration I served on him earlier this year allowable through the

Placer County Department of Child Support Services. I have the certified mail return receipt

proving that he signed receipt ofthe requested documents. Mr. Vassell's finances deserve close

REPLY DECLARATION OF ANGELICA G. HALE 3

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examination in light ofhis asking children's service providers, like Mae Alderson, for money. As

stated in my previous declaration, because Lloyd Vassell is asking for broad powers over

Christian's life from now and forever more, I believe that his financial, credit card and identity

theft history, I believe, IS relevant to his petition for Conservatorship of Christian Vassell's

Estate (Exhibit #4 in my original declaration).

8. Mr. Vassell makes a strange detour into fantasyland with his discourse in his declaration

regarding "Horton Hatches the Egg." More pertinent to this case are the recent revelations at

Penn State, where All-American Football Coaches looked the other way while a colleague

committed sexual assaults on minors. It went on for decades, and now the stench is

overpowering. I have held my peace for many years, so as not to create a climate of dissension in

my children's lives, but I am done holding my peace. Neither the Regional Center nor the School

District have shown that they are working in the best interests of Christian, especially while they

have aided Mr. Vassell in his practice of "pay-to-play" and "parental alienation" by not vetting

his slanderous depictions ofme. They have made official decisions that have forever affected the

lives and course of me and my sons. For example, Christian was not even present at his 2011 IEP\

(Individualized Education Plan) meeting after he turned 18, and no one in attendance (including

the North Bay Regional Center Case Worker and also the IEP coordinator for the school, Lori

Paisley, who knew Christian had turned18 years old) would have stopped the meeting if Melvin

didn't ask: "Where's Christian?" That IEP ended, and I was thanked by the Susan Montoro ofth

Napa Valley School District offices for bringing up the fact that Christian should be at his own

IEP. She told Lloyd Vassell that it was not OK to take Christian to school instead ofhis own IEP,

d~e to the fact that he is an adult and she dismissed the meeting to be rescheduled. Ms. Montoro

then stated that I would be receiving a copy ofthe IEP notes and again, thanked me for giving the

REPLY DECLARATION OF ANGELICA G. HALE 4

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IEP team this important information - that Christian is an adult and needs to be at his own IEP.

But afterwards, their tune changed, and we were banned from IEP meetings. This happened

when Lori Paisley, Christian's school assistant said in her email to me later, "As you are aware,

Christian is 18 and holds his own educational rights. At his (Christian's) request, your presence

will not be warranted at his IEP meeting." So, relating to the actions ofLloyd Vassell, like at

Penn State, convenience and financial gain took precedence over ethics and morality. Lloyd

Vassell's behavior shows moral malice. Ask Christian yourself; Christian does not understand,

neither would he use the word, warranted. This is undue influence.

9. My son Taylor, 20, who is disabled, and is leasCable to defend himself from the serious

allegations made by Mr. Vassell and Deon Booker, needs to be present in court. The court cannot

afford to make a conservatorship decision re: Christian without seeing and hearing from Taylor,

in his own words. Taylor lived in the Vassell home until May 2011. In the conservatorship court

transcript dated September 26,2011, Lloyd's then attorney Laura Dunst states that Taylor still

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lives in Napa, but in reality, he was removed by Lloyd on May 21,2011. As some background,

Taylor donated his bone marrow to Christian for his bone marrow transplant, and Taylor is

Christian's only friend and brother. After the violent incident in May, Lloyd waited until July to

let Christian see or talk to his brother Taylor. So, again, Taylor is disabled, but his voice needs to

be heard by the Judge. Lloyd was ordered not to hit the boys after an incident in 2001, in which~.

both boys were removed from the Vassell home by CPS (Exhibit F).

10. It is only after I filed a complaint for contempt against him relating to visitation in Alameda

County that LLoyd brought Christian to Fairfield to see his brother on July 16,2011 which is

amazingly 2 months after the incident. Almost 2 months later, Lloyd brought Christian to see

Taylor on August 26th, 2011. To this day, although they have the bond that everyone talks about,

REPLY DECLARATION OF ANGELICA G. HALE 5

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Lloyd has only allowed Taylor and my parents to see Christian twice since Taylor's removal in

May 2011. That is only twice in more than 6 months. Now everyone else in my family is facing

the same visitation and isolation issues that I have been subject to in the last 12 years, and the

reason why a visitation and access to Christian by family should be ordered in this case or else

Adult Protective Services may need to be involved in this matter. They have been notified, but

they have not provided any support. Note that Lloyd's contempt case in Alameda County on

November 7,2011 was Dismissed Without Prejudice due to the broad interpretation of the 2002

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order signed by judge Dombrick. During this hearing a few weeks ago, Commissioner Dleon

stated that ~loyd Vassell's actions may be a case ofbad parenting (Exhibit G) by not permitting

visitation and access to Christian, and offered to make the case available to retry with additional

evidence and clarification. In other words, the case had enough merit for Commissioner Dleon to

rule Dismissed Without Prejudice. I can provide a transcript for the court to review the details

upon request.

I declare under penalty ofperjury under the laws of the State ofCalifornia that the forgoing is

18true and correct, executed at Los Angeles, CA.

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20 12. DATED: November 22,2011

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Angelica G. Hale

REPLY DECLARATION OF ANGELICA G. HALE 6

EXHIBIT A

A LL'(\9 e\ i'C'~ H ~ e,

3 \75 S. Seyvv~d~ t\vd.

~DSAh~e,b, LA qOO3~

A~+#303

Thank: You card sent to meby Christian an.d Taylor,postmarked. Jan. 12,2010.

This is typical" of myrelationship with my sons.

EXHIBIT 8

This is an enlargement of portions of the medical record for Taylor, written byDr. Lenoir in Exhibit A, on June 23, 1999.

It states:

"Oad single parent. Patient', mother moved and leff kids and ..ent to Vi'l:inia.

Patient's dad jll,t got lIim back from .'oster Care."

In her sworn statement, Ms. Mae Alderson, the children's caregiver during this time

makes it clear that Mr. Vassell is lying. The boys were in Emergency Respite throughthe Regional Center, not foster ure:. This is all part of Mr. Vassell's abandonment lie,

attempting to curry sympathy at my expense. What else could be the purpose of thisstatement?

Only after Mr. Vassell started receiving the boys Social Security cheds, which totaledabout $1 ,500/month, did he take them out of emergency respite. Considering that

Mr. Vassell was financially indigent at the time, the boys' money was a windfall.

This following commentary by Mr. Vassell !lies in the face of his statement that ~l

have never said anything bad about Angelica!" Defaming me has been his career.

: 2.

LGahCa01S

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PhysIcal Examlnallon

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EXHIBIT F

IfPHYSICAL ABUSE OF TAYLOR BY THE FATHER AI\JD RISK OF PHYSICAL ABUSE OF CHRISTIAN BY THE FATHER WERE SU BSTANTIATE DJ}

Detention Report - May 3, 2001

Within the last 10 years

Statement used by Sharon Levitt, Child Welfare Investigator in Alameda County, justifying the removal of sons Christian Vassel! and Taylor Vassel! from Mr. Vassell's home.

EXHIBITG

"BAD PARENTING"

November 7,2011

Term used by Commissioner Oleon to describe Lloyd J. Vassell's character

OSC RE: CONTEMPT AGAINST LLOYD J. VASSELL

ALAMEDA COUNTY SUPERIOR COURT

CASE C-845298

Case dismissed WITHOUT PREDJUDICE