SAVE MARY SAVANNAH from
THE CHILD MOLESTER
Yes, this woman sexually molested her daughter, Elizabeth Kerley. So, Elizabeth adapted that lifestyle and now takes Mary Savannah Kerley to have her molested with the BLESSINGS of the court of
Judge R. A. Ferguson
In a court trial on July 22, 2009, in which Raymond Vaughan was the Defendant, Judge Sandra Ross Storm of Jefferson County Family Court admonished Elizabeth Kerley for refusing visitation for 5 1/2 months with her father, Marc Kerley. Judge Storm told Elizabeth Kerley that "if this matter were in my jurisdiction, I would have Patrick (her bailiff) escort you to the County Jail where you would spend 5 days for every occasion that you withheld visitation." Judge Storm further advised Elizabeth Kerley to not leave Mary Savannah with Ann and Ray Vaughan.
On the very next day, Elizabeth Kerley called Marc Kerley's father and told him, "I made a mistake withholding visitation and for allowing my mother and Ray to babysit Mary Savannah. I assure you that it will NEVER happen again." Later that day, Mary Savannah went to Ann and Ray Vaughan's house. They are, again, babysitting Mary Savannah.
In his court testimony, Ray Vaughan stated that
MARY SAVANNAH KERLEY IS NOW SLEEPING WITH ANN VAUGHAN.
Please contact me at:
205-218-5666
Judge R.A. "Sonny" Ferguson and attorney, Denise Pomeroy are advocates of sexual abuse. They selfishly put an innocent child, Mary Savannah Kerley, in the dangerous hands of a known child molester. Page 986, 19-987,4 Q. You talked earlier about having custody of Libby; isn’t that right?
A. Right.
Q. That’s not actually true, Libby was taken out of your custody; wasn’t she?
A. Yes.
Q. The Child Services officials over in EXCERPTS FROM THE DEFENDANT’S MOTION TO ALTER, AMEND OR VACATE:
Ray and Ann Vaughan live in the quiet little town of Gardendale, Alabama. Their quaint home on North Road, hides a multitude of sins. This "beloved" granny prostituted her daughter, Elizabeth Kerley. Mrs. Vaughan had many husbands (eight) and numerous live-ins. She relished in hearing the bones crack and break in her little innocent daughters. (Reference to Home page: what the judge saw when he read Elizabeth's medical records). The severe abuse occurred in a time when mothers were rarely arrested for their indiscretions. Instead, in the 70's, it was more common to "institutionalize" the insane. So, that is precisely what happened. You may ask, "Was she ever convicted?" I have been asked that hundreds of times. She would be on the Dru Sjodin National Sex Offender Registry should that happen today. Unfortunately, this was before Megan's Law was enacted.
http://www.nsopr.gov/
Ann Vaughan is the maternal grandmother of Mary Savannah Kerley. Mrs. Vaughan lied in court saying that she had no memory of many critical life-changing events. She is an admitted drug addict (court testimony). She didn't recall losing custody of her children until she was forced into telling the truth when confronted with the facts. Husband number EIGHT is to be present when Ann Vaughan babysits this little girl.
"...and should the Plaintiff use her mother, Ann Vaughn, as a babysitter, Mr. Ray Vaughn shall be present on each and every occasion to help supervise."
FOLKS....WHAT'S WRONG WITH THIS PICTURE?
Court testimony from Ann Vaughan:
A. Yes.
The judge made provisions for this woman to babysit my daughter, who is currently three-years-old. A family tradition flourishes as the mother of Mary Savannah gave away one of her other daughters almost 4 years ago...you know, kind of like a puppy. Fortunately, the child now lives with her father in another state and is not subjected to the admitted drug and alcohol abuse of the mother, Elizabeth Kerley.
In January, 2008, Elizabeth Kerley and her attorney, Denise Pomeroy, filed a motion to restrain me from posting this website and disclosing Elizabeth Kerley's psychiatric instability. The judge ruled that this would have to be resolved in a federal court. The courtroom was crowded to overflow capacity in protest of the judge's inept decision to subject a child to a child molester and to a mother that has admitted to following in her mother's footsteps.
Why have Ann Vaughan and Elizabeth Kerley not pursued this in federal court? Because this is factual information!
WHY DID JUDGE R.A. "SONNY" FERGUSON SENTENCE AN INNOCENT CHILD TO A LIFESTYLE AMONG DRUG ADDICTS, STRIPPING, PROSTITUTION, ALCOHOLISM AND WORST OF ALL, CHILD MOLESTATION?
WHY WOULD HE ADVOCATE THIS BEHAVIOR AND CONSIDER THIS TO BE IN THE BEST INTEREST OF A MINOR?
This is unacceptable. Individuals have come forward from the community in protest of this inhumane treatment of a citizen. Judge Ferguson has had the opportunity to amend this horrific decision.
Judge R.A. Ferguson has placed my daughter in imminent danger. Would he allow one of his own children or a grandchild to be placed in the care of Ann Vaughan? Mary Savannah stays with her perverted, child-molesting grandmother several days and nights a month.
The plaintiff, Elizabeth Kerley, is an alcoholic and drug addict who has in the past served as a prostitute.
The Plaintiff, Elizabeth Kerley, has placed the minor child in danger by allowing the maternal grandmother, Ann Vaughan to have visitation with the minor child. Ann Vaughan took the stand in this case and amazingly testified that she did not know or remember whether she had ever sexually abused, raped, beat or stuck a gun to her daughter’s head. Ann Vaughan’s, “I don’t remember” testimony about the abuse of her own daughter cannot be accepted as anything but an outright lie.
Ann Vaughan, the Plaintiff, Elizabeth Kerley’s mother, is a known child molester and child abuser and should not be allowed by this court to have any contact with the minor child. Recent case law from the
The Plaintiff, Elizabeth Kerley, should not be allowed to have custody based on the single act alone of exposing a child to unsupervised visitation with Ann Vaughan who she contended in the past had sexually abused, molested and physical abused her.
The Plaintiff, Elizabeth Kerley, has proven to be an unfit parent to such an extent that she gave up custody of her daughter, Jillian Henkel, to her former husband in Georgia.
The minor child had burn injuries that were shown to this Court that took place when the minor child was in the care and custody of the Plaintiff, Elizabeth Kerley. Obviously, the Plaintiff burned the child with a cigarette just as she was burned by her mother when she was a child. It is well known that the abused repeat abuse on their own children.
The Plaintiff, Elizabeth Kerley, exposes the minor child to her smoking cigarettes and the child suffered medical problems as a result and will continue to suffer. IN THE FRANK MARCUS KERLEY ELIZABETH ANN KERLEY The Circuit Court of
DR 05-2868 RAF
APPELLANT’S REPLY BRIEF
Medical Records Standard of Review
Appellant
Vs.
Appellee
APPEAL FROM
(R. 241 and 242) (R. 253-258)
THE COURT: Again, I will remind you lawyers, yes, there are medical records in. Yes, I will read those medical records. Do I know what is in them right now? No.
(R. 1095, 3-11)
Elizabeth Kerley, a.k.a., Elizabeth Hill, has Borderline Personality Disorder. (Dr. Warren Jackson,
Elizabeth Kerley has Borderline Personality Disorder traits and Borderline Personality Disorder features and thrives on chaos. (Sandra L. Frazier, MD,
Elizabeth was “in and out of multiple foster homes after her mother lost custody of her and her sister.” Her Mother, Ann Vaughan, was “sadistic and horribly abusive” and the patient states that she "was beaten daily.”
Elizabeth, a.k.a., June Taylor, was raped. She was “sexually molested by Mother before the age of 12”; she has been molested and sexually abused while in the care of her mother, Ann Vaughan. (She named one of the perpetrators as Tommy M.) (
Elizabeth, a.k.a. June Taylor, “has been battling depression and suicidal thoughts since childhood.” She began drinking alcohol at age 12—would drink 6-8 beers and a bottle of of wine. She began “smoking marijuana constantly at age 12, ‘joint after joint.’" Cigarettes, age 12, Flexaril, age 32 (2 to 3 times weekly). (
Elizabeth, a.k.a., June Taylor, is “impulsive, self-destructive and drives dangerously.” She has done “cocaine, ecstasy, and on several occasions LSD.” (UAB Addiction Recovery Programs,
Elizabeth, a.k.a., June Taylor, has self-mutilated; (she denied this in her testimony); she has “fears of abandonment, stalking and powerless over her world and drugs”. (UAB Addiction Recovery Programs June 27, 2003, UAB Med. Rec. No. 01109780)
Elizabeth, a.k.a., June Taylor, has been on Disability for clinical depression. She has “suicidal ideation” and “numerous attempts to kill herself,” (the first attempt was at the age of 18, which she denied in her testimony). “Patient did have a gun on one occasion, but it was taken away by her husband.” (UAB Addiction Recovery Programs, May 29 and
On
Elizabeth, a.k.a., June Taylor, had sex for money a “few times.” She denied this in her testimony, saying that she had only done this once. She was raped during the time that she was a stripper. (UAB Addiction Recovery Programs, May 28 and 29, 2003, UAB Med. Rec. No. 01109780)
Elizabeth, a.k.a., June Taylor, was prostituting and stripping during her first marriage; while she was the mother of her two older children, she smoked marijuana, did cocaine and LSD. She has also done Ecstasy. (
Marc Kerley was always “supportive and reassuring” to the patient’s treatment and never exhibited any violence towards her. (
mad/drinking.” (UAB Addiction Recovery Programs, May 28 and 29 2003, UAB Med. Rec. No. 01109780)
Elizabeth Kerley, a.k.a., June Taylor, has had a long history of drug addiction, alcohol abuse, multiple suicide attempts and her personality disorder has caused many consequences, including her inability to get along with others. (
In sharp contrast, Marc Kerley comes from a very stable background. He is non-violent, does not drink
alcohol, does not do drugs, has never given up custody of a child, is not promiscuous, has never sold sex for money, does not self-mutilate, gets along well with others, would not drink alcohol or do drugs, then drive, especially with a child in the vehicle. Finally,he would never subject his daughter to a child molester. Smith v. Smith, 48 So.2d 381, 383 (Ala.Civ.App.19
In addition to the medical records that the Court saw, the Judge heard extensive testimony of more suicide threats. On
was 5 months pregnant). She was abusing the minor child, Mary Savannah, before she was born. (C. 135)
On From the divorce order: (C. 292)
While it is most unfortunate that Elizabeth Kerley has been subjected to the wrath and torture of her Mother’s sexual addiction and abuse, it is imperative to note that she is very dangerous to the children living under her roof.
“…and should the Plaintiff use her mother, Ann Vaughan, as a babysitter, Mr. Ray Vaughan shall be present on every occasion to help supervise."
Throughout the trial, Elizabeth and her Mother, Ann Vaughan, maintained their inability to remember the events of cruel behavior that occurred during Elizabeth’s childhood, where just four years earlier, she had vivid recall. The Court saw that medical professionals have had grave concerns of the continuing instability and danger of these two.
It should be noted that Ann Vaughan was not convicted; she was institutionalized. Her victims and the Courts have made it possible for her to continue with her behavior, without consequences. Mary Savannah Kerley should not be allowed to live in such petulance.
After a public outcry, and supporters of Mary Savannah crowding the courtroom (standing room only)and on January 28, 2008,
Marc Kerley did create a website defending Mary Savannah’s rights, and directing attention to the injustice that has been bestowed
upon her. A Father should protect his child, and the Court has made it impossible for Marc to do so, forcing him to deliver Mary
Savannah to sexual predators.
NO CHILD SHOULD BE SUBJECTED TO THIS KIND OF ABUSE. PLEASE HELP HER!!!
FOR MORE INFORMATION PLEASE CALL:
MARC KERLEY 205-218-5666
--------------------------------------------------------------------------------------------------------------------
IN THE CIRCUIT COURT OF
TENTH JUDICIAL CIRCUIT OF
DOMESTIC RELATIONS DIVISION
ELIZABETH ANN KERLEY, Plaintiff, CIVIL ACTION NO.: DR05-2868RAF
FRANK MARCUS KERLEY, Defendant
DEFENDANT, FRANK MARCUS KERLEY'S, SUPPLEMENTAL MOTION TO ALTER, AMEND OR VACATE
COMES NOW, the Defendant, Frank Marcus Kerley, and moves this Court for an Order granting the Defendant's Motion To Alter, Amend Or Vacate and Supplemental Motion To Alter, Amend Or Vacate in support of said motion states as follows:
ELIZABETH KERLEY'S ALCOHOLISM AND ILLEGAL DRUG USE:
1. The Plaintiff, Elizabeth Ann Kerley, admitted being an alcoholic and in the past a binge drinker in court testimony and her medical records. Ms. Kerley's medical records include admissions of using cocaine, marijuana, ecstacy, etc. Ms. Kerley has proven that she cannot keep off of drugs even when in drug treatment as she admitted to failing a drug test in September of 2005. Ms. Kerley even admits to being in drug treatment up until January 2006. The child was born on
See the record at Page 302-18
Q. You are not an alcoholic, are you? A. I am a recovering alcoholic.
See the record at Page 328-6
Q. Then in November 2004 you reached the understanding you were a binge drinker by
then?
A. Yes, sir.
Page 340-7
Q. And Marc Kerley, he made you an alcoholic?
A. No, sir.
Q. Marc Kerley made you drink?
A. No, sir.
Page 95-11
Q. All right. So in terms of the drug screens that you have had since August 2003, has there, at any time, been one that you got a positive result on?
A. Yes, ma'am. In September 2005.
Page 96-4
Q. Tell us about the one time in September of 05, what was the positive drug screen was on that occasion and what was it positive for? A. Benzodiazepines.
Page 199-22
A. I volunteered to go back in for a refresher course for 6 weeks at U.A.B. outpatient.
Q. Okay. When did you do that?
A. I did that in November—the last part of November 2005 until, I believe, it was January 2006.
MARC KERLEY HAS NO HISTORY OF ALCOHOL OR DRUG USE:
2. The Defendant, Marc Kerley, is not an alcoholic and never has been an alcoholic
and has no history of using or abusing drugs of any kind. The fact that Ms. Kerley is an
alcoholic alone should dictate that this court protect the child by placing her in Marc Kerley's
custody. A chance cannot be taken on an admitted alcoholic having custody of a two year
old child.
ELIZABETH KERLEY'S SUICIDE ATTEMPTS AND MENTAL BREAKDOWNS:
3. The Plaintiff, Elizabeth Kerley, admitted to a history of thoughts of suicide and suicide attempts that began when she was eighteen years old and continued including two suicide attempts in 2002 and 2003. One year and ten months before the minor child Mary Savannah was born Ms. Kerley was so mentally unstable and suffering under such psychosis that she tried to kill herself. The medical records admitted into evidence are replete with the details. It is note worthy that Ms. Kerley had custody of two other children when she tried to kill herself. Ms. Kerley even admitted that she was a bad mother for trying to kill herself while her daughter was at home.
Page 86-6
Q. Okay. So November of 2002 you had an overdose attempt, is that right, Ms. Kerley'? A. Yes, ma'am.
Q. Okay. Now, tell us exactly what your overdose attempt was in November 2002?
A. It was Flexiril and beer.
Q. Okay. Now, how many beers did you have on that occasion, Ms. Kerley?
A. Four or five.
Page 87-8
Q. So on that occasion, did you go to the hospital? Did something occur like that, Ms.
Kerley?
A. Yes. I went to the hospital.
Q. Okay. Where did you go to the hospital?
A. I went to
Q. Did you go to some other hospital after that?
A. I went to U.A. B.
Page 89-23
Q. Okay. So you said, I guess this was some time earlier in May of '03 before you called
the Nursing Board, there was a bad argument and you went to the emergency room, is that
right?
A. Yes, ma'am.
Q. Okay. And so on this occasion, Ms. Kerley, you went to the emergency voluntarily when the ambulance came, is that what happened?
A. Yes, ma'am...I was there for the evening.
Page 92-14
Q. Okay. So you called the Nursing Board and then at that point did you enter into some kind of plan of treatment of some such, Ms. Kerley?
A. Yes, ma'am.
Q. Okay. Tell us what you did. A. I went into treatment at U.A.B.
Q. Okay. And was that inpatient or outpatient A. It was inpatient for 30 days.
Page 93
Q. All Right.
A. And outpatient for like 6 more weeks.
Page 239-10
Q. Ms. Kerley, isn't it true that overdose that you had with Flexoril, and Ambien, and
alcohol almost killed you?
A. That is not accurate information.
Q. It is not an—it would not be described as a nearly fatal overdose? Would you disagree with these medical records that call it a near fatal overdose?
A. No, sir, but Ambien wasn't involved.
Q. Well, these records say it is. So you are saying it was just alcohol and Flexoril, is that
right?
A. Yes, sir.
Q. You don't disagree it was a nearly fatal overdose that almost killed you? You were almost successful in killing yourself, right?
A. That is what I've been told, yes.
Page 241-13
Q. I will go over a lot more places in here where it says that you tried to kill yourself at 18, so I want to know before I go over those places in your records where it says you tried to kill yourself at 18, would you disagree with every entry in this about a foot stack of medical records, that says you tried to kill yourself at age 18?
A. Yes, sir.
Page 243-20
Q. Isn't it true that you were locked down in the psychiatric unit, you were in a locked down unit, do you deny that?
A. On which occasion?Q. On your '03 psychiatric admission?
A. For one day, yes, sir, I was.
Q. Okay. So whoever it was felt that you needed to be locked down in the locked down psychiatric unit, right?
A. Yes, sir.
Page 245-19
Q. So a year and 10 months before you had this child, you were in the psyche unit, right?
A. Yes, sir.
Page 246-6
Q. Where were they when you attempted to commit suicide; where was Melinda? A. She was asleep in her bedroom.
Page 247-3
Q. No ma'am. What happened in 2003, May 2003, before you got to the hospital, tell us what happened.
A. I called his sister after a very serious argument with Marc and stated that he was threatening me with some issues and that we were having severe problems again and I just couldn't take it any more.
Page 258
Q. Ms. Kerley, there was an attempt on November 2002 for you to kill yourself, right?
A. Yes, sir.
Q. And tell us where the children were when you tried - where your children, the Henkel children, were when you tried to kill yourself in November 2002? A. They were at home.
Page 260-1
Q. Okay. Did you think about your children's emotions and feelings if they came into your room after you tried to kill yourself and found their mother dead on the floor?
A. At that present time, no, I didn't.
Page 261-4
Q. Don't you agree with me that that was very bad mothering on your part?
A. Yes, sir, I do.
Page 263-22
Q. Okay. Well, do you think that the Court should consider your November 2002 suicide attempt as to whether you should get custody of Mary Savannah?
A. Yes, sir. Page 336-16
Q. Okay. This record right here that has been admitted into evidence says, patient said she had a bad day and was having thoughts of suicide. Patient states that she drank—remember the five beers? A. Yes, sir.
Q. Patient states she drank five beers, took Flexoril, patient COA times three, PMS times four; do you see that?
A. When was that report?
Q. Okay. It is up there at the top. Today's date
that was a suicide attempt? A. Suicide thoughts and suicide attempts are not the same thing.
Q. Okay. So you were just studying on that suicide when you were talking to Marc's sister---what is her name? A. Marlene
Page 338-8
A. I told her that Marc and I had been fighting and that I couldn't take it anymore, and I didn't know what to do with my kids. And I mean, I did make several comments to her that showed that I extremely emotionally distraught, yes.
Page 340-15
Q. Marc Kerley made you try to kill yourself, because you were so mad at him?
A. No, sir, I am accountable for my actions.
4. The Plaintiff, Elizabeth Kerley, has a long and significant history of depression. The depression that Ms. Kerley has labored under her entire life did not go away right before the trial of this case or immediately thereafter. The depression that Ms. Kerley suffers will effect and damage the minor child. Ms. Kerley's long history of depression makes her an unfit parent.
Page 251-5
Q. All right. Have you had problems with depression?
A. Yes, sir.
Q. And you blame all those on Mr. Kerley?
A. No, sir.
Q. You had problems with depression long before you ever got in this marriage? A. Yes, sir.
Q. Many years before you got in this marriage?
A. Yes, sir.ELIZABETH KERLEY'S PROSTITUTION (ALSO KNOWN AS SELLING SEX FOR MONEY):
5. The Plaintiff, Elizabeth Ann Kerley, admitted to acting as a prostitute in the past. Ms. Kerley admitted that she did not tell Mr. Kerley she had acted as a prostitute prior to the marriage. This demonstrates she is less than forthcoming and dishonest about significant matters. This case would not exists if Ms. Kerley had simply bothered to share her past history of prostitution with Mr. Kerley as he would not have married her. A woman like Ms. Kerley with a past history of prostitution is not morally fit to have the sole care, control and custody of a two year old little girl.
Page 1145-17
Q. And in terms of what you testified to was selling sex for money one time, did Mr. Kerley know about that at the time you guys got married?
A. No ma'am.
ELIZABETH KERLEY'S NUDE STRIPPING:
6. The Plaintiff, Elizabeth Ann Kerley, admitted to acting as a stripper in the past in court testimony. This means that Ms, Kerley was not a "stripper" like the kind of person that takes varnish off of wood but the kind that takes her clothes off and gets naked for pleasure or money. A woman like Ms. Kerley with a past history of acting as a stripper is not morally fit to have the sole care, control and custody of a two year old child.
Page 1112-20
Q. You have done stripping; haven't you?
A. Yes, sir.
ELIZABETH KERLEY COMMITTED ADULTERY DURING THE MARRIAGE:
7. The Plaintiff, Elizabeth Ann Kerley, admitted to committing adultery while married to Mr. Kerley in court testimony. The admission is only a partial admission in that she admits to having sexual relations only one time. Who has an affair and only has sex with the person one time? It is simply another lie that Ms. Kerley knew she must admit to because it was already in her medical records. Of course, adultery from a person with a history of alcohol, drugs, prostitution and naked stripping is no surprise. Marc Kerley never committed adultery during the. marriage.
Page 115-4
Q. Okay. Was there an occasion during the course of your marriage to Mr. Kerley that you had a relationship with someone?
A. Yes, ma'am
Q. Okay. And did you have sexual activity with that individual on any occassion.
A. Yes. One time.
ELIZABETH KERLEY'S FORGERY:
8. The Plaintiff, Elizabeth Ann Kerley, admitted to forging documents that were require as part of her alcohol and drug treatment by the
Nursing Board in court testimony.Page 119-10
A. I told the Nursing Board—Marc called the Nursing Board and I told the Nursing Board that I forged signatures.
ELIZABETH KERLEY'S DOMESTIC VIOLENCE AND PHYSICAL ABUSE DIRECTED AT MARCKERLEY:
9. The Plaintiff, Elizabeth Kerley, admitted that she was physically abusive to the Defendant, Marc Kerley in court testimony.
Page 54-22
A. ...so I called Vestavia police. They arrived. Marc's ears were bleeding and I tried to tell them. That he had cut his ears.
Page 355-21
Q. Okay. Well, you grabbed both of his ears?
A. I sure did.
Page 1119-11
Q. Sometimes you grab him by the ears so hard that you make his bleed; don't you, ma'am? A. I did grab his ears, yes, I did.
Page 322-2
A. I was mad. When I grabbed his ears I was mad.
Page 355-21
A. I grabbed the crap out of his ears.
MARC KERLEY HAS NO HISTORY OF DOMESTIC VIOLENCE OR PHYSICAL ABUSE TOWARD ELIZABETH KERLEY:
10. The Defendant, Marc Kerley, has never physically abused the Plaintiff. In fact, Elizabeth Kerley had Marc Kerley arrested for domestic violence to gain an advantage in the divorce case with no corroboration or supporting evidence other than merely what she said. Marc Kerley was found NOT GUILTY after a full blown trial in Hoover Municipal Court. The case was presided over by the most respected municipal court judge in the State of
Page 276-14
Q. Answer my question, ma'am, was there any entry of physical abuse in these medical records anywhere about Mr. Kerley?
Page 277-13
A. From the time I looked at the records, no.
Page 347-4
Q. You have been taught by these safe house women and these domestic violence people, any touching unwanted is physical abuse?
A. Yes, sir, it is.
ELIZABETH KERLEY'S ABUSE BY HER MOTHER ANN VAUGHN
11. The Plaintiff, Elizabeth Kerley, was physically and mentally abused by her own mother and she admitted such in her medical records and court testimony. The medical records themselves include more extensive details regarding how she was abused by her mother. The medical records even include entries about how her mother put a gun to her head. Ms. Kerley admitted to hating her mother for abusing her, but now she allows her mother to keep her child. Ms. Kerley admitted that it was her mother with this history of physical and mental abuse that taught her how to be a mother. Ms. Kerley is the product of childhood physical and mental abuse and as such now has all types of mental problems and addictions and is susceptible to being an abuser of her own child.
Page 1038-23
A. I did mention I told him about that one time that I vaguely remember my mom on the telephone with my dad saying something about threatening to throw us in the fireplace if he didn't get there.
Page 1038-15
A. I told him that my mom had a prescription drug issue at one time. I told him that at times that she was harsh and probably physically punished us more than she should have. I told him that my mom was on her sixth marriage.
Q. Okay. Tell the court what you told Mr. Kerley about what occurred when you were a child with regard to your mom.
A. I told him that one of my mom's boyfriends had messed with me. I told him that one of my sister's boyfriends had messed with me.
Page 1095-10
Q. You said that she threatened to kill you?
A. She told my dad—I was real young. I vaguely remember them fighting on the phone,
saying something about if he didn't get there, she was going to harm us.
Page 1096-2
Q. Did you ever tell anyone that your mother was abusive?
A. Yes, sir.
