Superior Court of Washington, County of King :

In re:
Petitioner/s (person/s who started this case): | No. 25-2-11308-6

 

Mathew Ralidak
Declaration of

And Respondent's (other party/parties): (name): Veronika Goodnight

Veronika Goodnight (DCLR)

 

1.

Declaration of (name): Veronika Goodnight
lam (age): 43 years old and | am the (check one): [ ] Petitioner [ X] Respondent
[ ] Other (relationship to the people in this case):
| declare: 1. | am the mother of Elora, Aidan and Raina, and | have been their primary
consistent caregiver since birth. | am responding to the Protection Order filed by Mathew
Ralidak, which | believe is not only unfounded but harmful to the emotional well-being of
our children.
2. Mathew has submitted a declaration containing references to sealed therapy notes from
our children’s sessions. | was deeply shocked and heartbroken to see statements
allegedly made by my children—statements | had never heard before and which do not
reflect the relationships I’ve consistently nurtured with them. I’ve only spanked Raina
twice, the first time was for her safety and | immediately held and rocked her and said, “I
love you, I’m sorry.” Raina was regulated within Smin and it calmed her down to where she

was safe again. The 2™ time | spanked Raina was April 3° and | immediately wrote
ig y

 

Optional Form (05/2016) Declaration
FL All Family 135 p. 1 of __

Raina’s therapist an email. Please see email attached dated 4/3/25. We do use a food
app called Yuka. This is NOT to cut calories or food from our diets. As our children are not
babies anymore | have encouraged them to be independent and feed themselves when
they are hungry, with respect to our family sit down meals, they have the ability to eat
avocados, oranges, apples, string cheese, salami, popcorn. The Yuka app is a free mobile
app that analyzes the health impact of food and personal care products by scanning their
barcodes. | was advised by Dr. Bowker, our children’s primary care physician, to remove
high fructose corn syrup and dyes for it was proposed that her stomach was hurting from
the foods she eats at her father’s house. | was also advised to limit dairy during school.
Please see emails to Robin Budig and Principal Frank requesting consistency with
children’s lunch and response to CPS report.

3. These therapy records were never shared with me nor coordinated through our joint
custody plan. Including them in litigation—despite being sealed—violates our children’s
privacy and undermines their trust in the therapeutic process. This action alone raises
serious concerns about Mathew’s willingness to protect their emotional health.

4. | ask the court to take judicial notice of previous findings in our parenting plans. Judge
Ponomarchuk and Judge Rampersad both found that | am a safe, loving, and attentive
parent. | have no history of drug use, alcohol abuse, or mental illness. These findings are
further supported by the full mental health evaluation from Dr. Oreskovich and medical
letters from Dr. Bowker, our children’s long-standing primary care provider. Please see
provided Dr. Oreskovich mental health assessment and Dr. Bowker’s declaration.

5. | have obtained recent medical intake records from my children’s provider portal that
clearly show the father, Mathew Ralidak, provided the information listed. In his own words,
he disclosed:

* That he uses spanking as a disciplinary method for all three children.

 

Optional Form (05/2016) Declaration
FL All Family 135 p. 2 of __

* That there is a gun present in the home, described as “locked in safe” and | know he has
never gone through a gun safety course and the history of what | have known of Mat
Ralidak is that he’s known nothing about guns.
* That the children experience “chronic stress at home” HIS home.
| also want to add that our youngest has said in these therapy notes that she lies and in
the attached exhibits her father has also stated “lying frequently”
Please see attached “History Provided by Father”.
6. These are not my words, nor the children’s voices—these are Mat's own admissions,
recorded in formal medical documentation. These disclosures raise serious concerns for
the emotional and physical safety of our children. The use of corporal punishment,
especially when paired with access to a firearm, violates both Washington parenting plan
standards and common-sense parenting safety guidelines. I've been honest about my
spanking, even communicated to the therapist that evening. | am disappointed to read that
the good | am implementing is not stated within these therapy notes. | use essential oils,
EFT Tapping, calm down bracelets, | was the one to organize therapy for our children.
Please see attached emails with Dan Claussen of Larch Counseling organizing
children’s therapy.
7. Additionally, Mat made these medical decisions and disclosures unilaterally, without
notifying me or coordinating as required by our parenting plan. Mat has also documented
false family history, numerous times, further undermining continuity of care. His behavior
is part of a long-standing pattern of medical interference and controlling access to the
children’s health and emotional support.
8. It is deeply alarming that the father would present a declaration accusing me of being
unsafe while simultaneously disclosing—under his own authority—that he spanks the
children and keeps a gun in his home. These contradictions call into question the

credibility and intent behind his filing of the Protection Order.

 

Optional Form (05/2016) Declaration
FL All Family 135 p. 3 of __

 

 

 

 

 

 

 

 

 

 

(Number any pages you attach to this Declaration. Page limits may apply.)

| declare under penalty of perjury under the laws of the state of Washington that the facts | have
provided on this form (and any attachments) are true. | have attached (number): 2Z pages.

Signed at (city and state): Duadd lA Date: Y/r4lrs

Sign a ; at name ag

Warning! Documents filed with the court are available for anyone to see unless they are sealed. Financial,
medical, and confidential reports, as described in General Rule 22, must be sealed so they can only be seen by
the court, the other party, and the lawyers in your case. Seal those documents by filing them separately, using a
Sealed cover sheet (form FL All Family 011, 012, or 013). You may ask for an order to seal other documents.

 

 

 

 

Optional Form (05/2016) Declaration
FL All Family 135 p.4of__

 

From: KIT Spins kit@kitspins.com
Subject: Raina's Bedtime Behavior & Concerns Around Transition
Date: Apr 3, 2025 at 11:24:13 PM
To: Danielle Smith danielle@larchcounseling.com

Hi Danielle,

I wanted to share some recent challenges I’m experiencing with Raina,
particularly around bedtime and emotional regulation, especially after time with

her dad.

This week, I allowed Raina to spend two nights with her dad and Monica
during what would normally be my parenting time. I made that choice to
support their relationship and hoped it would be positive for her. However, at
Elora’s softball game, yesterday, I watched Raina use her connection with
Monica in a way that felt emotionally manipulative. She was upset with me for
not following her timeline, and she responded by sitting directly on Monica’s
lap in front of me. It really hurt, and I ended up going to my van to hide crying.

Tonight was my first night back with Raina. It was a great day. | picked her up
early from school and surprised her with a tour of our new home and then we
went to my aerial class with other kids. She played. Danced. It was a beautiful
day. At home Colin and | let the kids stay up since it’s my last night. We played
Uno with the kids—it was fun and went well. I clearly explained that playing a
game meant they’d need to go to bed right after. I followed our usual bedtime
routine: sang their songs, rubbed Raina’s back, cuddled with her and tried to be
present and soothing. But Raina kept coming out of the room, escalating each
time. Eventually, I went downstairs because I felt I couldn’t keep giving

attention to the behavior.

Colin allowed her to rest next to him on the couch briefly, but once he said it
was time for bed (around 10:43), she began screaming—nonstop, intense
“Mom! Mom! Mom!” shrieks. It’s still going. Elora and Aidan can’t sleep. I’m
concerned the neighbors can hear. It’s overwhelming.

I don’t know if there’s a direct connection to her sleeping at her dad’s, but I’ve
noticed that when the kids transition from his house, their behavior shifts
significantly. Raina has always struggled at bedtime, but this is on a whole new
level. It feels extreme, and I’m unsure how to help her through this in a way
that’s loving but also protective of the rest of the family’s peace and emotional
well-being. I’ve done everything. Spanks. Bedtime charts. Stickers. Taking
away. Tapping. Essential oils. Snuggles. Songs. Reading. Stories. Tonight was

traumatizing. And now tomorrow they leave for a week on their father’s spring
break time.

I’d appreciate any insights or suggestions you may have.

-Veronika

From: KiT Spins kit@kitspins.com
Subject: Re: Special Dietary Accommodations
Date: Jan 4, 2023 at 6:03:30 PM
To: Robin Budig budigr@rsd407.org
Cc: Andrea Kosters kostersa@rsd40/.org, Kristina Schmoll
schmollk@rsd407.org, Mat Ralidak mralidak@gmail.com, Erika Dix
dixe@rsd407.org, Kelsey Bohl bohlk@rsd407.org

This is wonderful news!
Thank you so much for caring for our children!

Elora and Aidan have loved hot lunch and that's what they prefer. I'll let their
teachers know that they'll be on hot lunches unless otherwise desired and I'll be
sure to give notice if they want to bring lunch.

Thank you again for your care and respect to these dietary accommodations.
Mathew, I have added you onto this thread so you can have this information as well.

Thank you!
Veronika Goodnight

Sent from my iPhone

On Jan 4, 2023, at 9:07 AM, Robin Budig <budigr@rsd407.org> wrote:

Thank you for your request. | have forwarded this to the Carnation Kitchen. Kristina Schmoll is
our cook at CE. She is ready to start serving your students as of today. Your students will need to
let their teacher know on days they will be eating hot lunch. The meals are prepared specifically
for your student's therefore advanced notice is required.

If you have any questions, please contact me.

   

Thank you,
Robin Budig
yy Vi ~ Program Assistant - Food Services
/ \ A A as 15510 15* Avenue NE, PO Box 519
a Duvall, WA 98019

      

425.844.4523

aia sah and
budigr@rsd407.org

SCHOOL DISTRICT
Building Bridges w the Puture

 

\: KIT Spins kit@kitspins.com
Subject: Request for Consistency with Children’s Special Lunch.
Date: Dec 13, 2024 at 2:02:00PM
To: Robin Budig budigr@rsd407.org
Ce: ND Stacy Bowker DrBowker@snovalleyholistic.com, Michelle Frank

frankm@rsd407.org

Hi Robin,

I hope this message finds you well.

It’s come to my attention that there may be some conflicting
information regarding my children’s lunch arrangements,
specifically from their father, Mathew Ralidak. Today, I
noticed Raina had milk and an Uncrustable, both of which her
doctor has recommended avoiding due to their inflammatory
effects.

As you know, it’s important for our children’s health and well-
being to maintain consistency with their “special lunch.” Dr.
Bowker’s recommendations—which I believe I sent over last
year—are designed to prevent inflammatory responses that can
impact their emotional and cognitive functioning. You’ve
always been incredibly supportive of these guidelines, and I
truly appreciate your understanding.

However, the lunch staff mentioned there is an email from Mat
stating that the kids can have “special lunch” when they’re with
me but can eat anything they want when they’re with him. I
understand this may cause confusion, but it isn’t your
responsibility to track which household they’re at. I apologize
for the trouble this situation has caused and would like to

clarify this for the sake of our children’s health.

Could you please share a copy of the email Mat sent regarding
the different food guidelines for each household? Additionally,
moving forward, I would like to request that all of my children
remain on “special lunch” throughout the school year,
regardless of whose care they are in. I will speak with Mat
directly to remind him of Dr. Bowker’s recommendations and
reinforce the importance of consistency in their diet.

Thank you so much for your continued care and support with
this matter. Your help ensures that my children (and their
teachers) have the best possible days at school.

Warm regards,
Veronika Goodnight

From: KiT Spins kit@kitspins.com
Subject: Response to CPS Report & Reinforcement of My Commitment to
Children's Dietary Needs

Date: Feb 7, 2025 at 5:06:55 PM
To: Michelle Frank frankm@rsd407.0rg
Ce: Stacy Bowker ND DrBowker@snovalleyholistic.com
Dear Principal Frank,

1 am writing to express my outrage and deep concern regarding the CPS report
made against me, suggesting that my children “go hungry during mother’s
care.”

This accusation is not only false but also incredibly harmful and insulting given
the extensive steps I have taken to ensure my children receive safe, doctor-
approved nutrition- steps I have clearly communicated to the school.

To be absolutely clear:

* T have always followed Dr. Bowker’s medical orders regarding my children’s
dietary needs.

* | have consistently communicated with the school, including my email dated
December 13, 2024, to you, Robin, and Dr. Bowker regarding the need for
consistency with my children’s special lunches, which you never responded to

* I was proactive in ensuring my children were placed on a special lunch plan at
school, aligned with their medical needs.

* The other parent has a documented history of disregarding these medical
orders, feeding our children unsafe foods.

This morning, after a week off due to snow and even dealing with a frozen
door, I still made sure my children had a nutritious, balanced breakfast:
The girls had two pieces of sourdough toast with avocado

My son had gluten-free, dairy-free cereal (per medical necessity)

On the way to school, they had organic applesauce pouches

I would like to know who at the school made this CPS report and on what basis

they determined that my children were “going hungry.” If there were actual
concerns, why was I not consulted first? I have always been transparent and
communicative with the school to ensure my children’s well-being.

I expect an immediate response clarifying why this report was made and what
steps the school intends to take to prevent baseless, damaging accusations like
this in the future. As an educational institution responsible for my children’s

care during school hours, I would expect more diligence and fact-based
decision-making before making such harmful claims.

Sincerely,

Veronika Goodnight

Elora
Switch ¥

| Family History:

| Problem: Alcohol abuse

| Relation: Mother
| Name: Veronika Goodnight
| Comments:

| Relation: Maternal Grandfather
| Name: Tom Petra
Comments:

| Problem: Diabetes

Relation: Paternal Grandmother
| Name: Karen Passman
Comments:

| Problem: Drug abuse

Relation: Mother
| Name: Veronika Goodnight
| Comments:

Relation: Maternal Grandfather
Name: Tom Petra
Comments:

Problem: Mental illness

Relation: Mother

@ mychart.et1270.epichosted.com

 

 

 

Tr)
Selling

Relation: Maternal Grandfather
| Name: Tom Petra
| Comments:

|
| Problem: Mental illness

| Relation: Mother
| Name: Veronika Goodnight

| Comments:

| Relation: Maternal Grandfather
| Name: Tom Petra
Comments:

|
| Tobacco History:

| Question: Tobacco Use
Response: Never
uestion: Smokeless Tobacco Use
| Response: Never
| Comments:

| Substance and Sexual Activity
Histo!

Question: Alcohol Use
Response: Never

Onuactian: Druin boa

& mychart.et1270.epichosted.com
es

 

 

Well Child Assessment:

History was provided by the father. Elora lives with
her mother, father and stepparent (50/50 Custody).
Interval problems include chronic stress at home.
Nutrition

Types of intake include cereals, cow's milk, eggs,
fish, fruits, juices, junk food, meats and
vegetables. Junk food includes candy, chips,
desserts, fast food, soda and sugary drinks.
Dental

The patient has a dental home. The patient
brushes teeth regularly. The patient does not floss
regularly. Last dental exam was 6-12 months ago.
Elimination

There is no bed wetting.

Behavioral

Behavioral issues include lying frequently and
performing poorly at school. Disciplinary methods
include ignoring tantrums, praising good behavior,
scolding, spanking, taking away privileges and
time outs.

Sleep

Average sleep duration is 10 hours. The patient
does not snore. There are no sleep problems.
Safety

There is no smoking in the home. Home has
working smoke alarms? yes. Home has working
carbon monoxide alarms? yes. There is a gun in
home (Locked in safe). OO
School

Current grade level is 4th. Current school district is
Riverview. There are signs of learning disabilities.
Child is performing acceptably in school.
Screening

Immunizations are not up-to-date. There are no
risk factors for hearing loss. There are no risk

@ mychart.et1270.epichosted.com

 

Well Child Assessment:

History was provided by the father. Aidan lives with
his mother, father and stepparent (50/50 custody).

Interval problems include chronic stress at home.
Nutrition

Types of intake include cereals, cow's milk, eggs,
fish, fruits, juices, junk food, meats and
vegetables. Junk food includes candy, chips,
desserts, fast food, soda and sugary drinks.
Dental

The patient has a dental home. The patient
brushes teeth regularly. The patient does not floss
regularly. Last dental exam was 6-12 months ago.
Elimination

Toilet training is complete. There is no bed wetting.
Behavioral

Behavioral issues include misbehaving with peers.
Disciplinary methods include ignoring tantrums,
praising good behavior, scolding, spanking, taking
away privileges and time outs. ~

Sleep

Average sleep duration is 10 hours. The patient
does not snore. There are sleep problems (Sleep
walking).

Safety

There is no smoking in the home. Home has

working smoke alarms? yes. Home has working
carbon monoxide alarms? yes. There is a gun in
home (Locked in safe). To
School

Current grade level is 3rd. Current school district is
Riverview. There are signs of learning disabilities.
Child is performing acceptably in school.
Screening

Immunizations are not up-to-date. There are no
risk factors for hearing loss. There are no risk

@ mychart.et1270.epichosted.com

 

Well Child Assessment:

History was provided by the father. Raina lives
with her mother, father and stepparent (50/50
custody). Interval problems include chronic stress
at home.

Nutrition

Types of intake include cereals, cow's milk, eggs,
fish, fruits, juices, meats, vegetables and junk
food. Junk food includes candy, chips, desserts,
fast food, soda and sugary drinks.

Dental

The patient has a dental home. The patient
brushes teeth regularly. The patient does not floss
regularly. Last dental exam was 6-12 months ago.
Elimination

Toilet training is complete. There is no bed wetting.
Behavioral

Behavioral issues include lying frequently and
performing poorly at school. Disciplinary methods
include time outs, praising good behavior, ignoring
tantrums, taking away privileges, spanking and
scolding. ee
Sleep

Average sleep duration is 10 (Waking up about 2-3
times a night) hours. The patient does not snore.
There are no sleep problems.

Safety

There is no smoking in the home. Home has
working smoke alarms? yes. Home has working
carbon monoxide alarms? yes. There is a gun in
home (locked in safe).

School

Current grade level is 1st. Current school district is
Riverview. There are signs of learning disabilities.
Child is performing acceptably in school.
Screening

& mychart.et1270.epichosted.com

10:03 w) LTE @)

12 Messages

€ Inbox Parenting plan NM

ay Dan Claussen 10/2/24
To: Veronika KiT~ Goodnight >

| forgot to ask, are you looking for a North
Bend Therapist, or a Duvall one? Markus
worked in both for a period:)

Dan Claussen, M.S LMFT. Founder and Director
P: 425.200.0130 | F: 425.209.0766

larchcounseling.com

Confidentiality Notice:

Since email is not a totally confidential means of communication, please
consider this as you communicate with me. While 1 make a reasonable effort to
keep what is written private, it is suggested that very personal information be
communicated by phone. on paper, or in person.

The information in this email, including attachments, may be confidential and/or
privileged and may contain confidential health information. If you have received
this email in error please notify me immediately - by return message to the
sender and destroy all copies of this message and any attachments. Confidential
health information is protected by state and federal law, including, but not
limited to, the Health Insurance Portability and Accountability Act of 1996 and

related regulations.
See More A
+, Veronika KiT~ Goodnight 10/2/24

> | would love Duvall please. But if north b...

5 5 A 4

 

 

10:03 o) LTE @>

12 Messages

€ Inbox Parenting plan NM

If you would like to go forward with every
other week on your time, we can see your
two kids at $45 per session. You would
qualify under being the sol payer. We do not
often bill insurance on these scholarships as
taking away the admin process helps balance
out the cost of the reduced fee. If the kids
father does want to participate and bring
them on his weeks, we would renegotiate
and look at billing insurance.

If that happens, we would do our normal rate
and bill insurance.

| am looping you back in with Alex, our intake
coordinator to find a time that works with one
of our therapist that can work with this
dynamic. Alex, just keep me apprised of who
they land with so | can keep them in the loop
and get a scholarship form sent out for each
child.

Alex, can you connect with Veronica to
schedule the children (different therapist
would be best) with one of the following
therapist:

a 5 Aa Bg

 

10:04 »!) LTE @)

12 Messages

€ Inbox Parenting plan NM

x Alexandria Packard 10/8/24
To: Dan Cc: Veronika KiT~ >

 

Hi Veronika,

Happy to help! To start with our Duvall
location, I've listed Mario, Danielle, and
Elliott's availability below:

- Mario

e Weekly Wednesdays at 12pm
e Biweekly Mondays at 1pm

- Danielle

e Weekly Wednesday at 1pm or 1:30pm
e Weekly Thursdays at 12pm or 1pm
e Biweekly Mondays at 1pm or 3pm

- Elliott
e Weekly Tuesdays at 12pm and 1pm

Would any of these work? We can also
schedule a call to discuss options if that's
easier.

Warmly,

a om) Aa Zh

 

10:04 oo «LTE @)

12 Messages

€ Inbox Parenting plan NV

& R ‘Veronika KiT~ Goodnight — 10/9/24
<@> 6To: Alexandria Cc: Dan >

Good morning Alex,

Thank you Dan, so much for coordinating
and thank you for prioritizing my children's
health.

| see Mario and Danielle have biweekly
Mondays which would be excellent if they
land on my weeks. Mario stood out for me for
Aidan and Danielle for Raina. By chance are
they in the office this Monday the 14th?

All the best,
Veronika
Sent from my iPhone
On Oct 8, 2024, at 5:11PM, Alexandria

Packard <alexandria@larchcounseling.com>
wrote:

See More A

Alexandria Packard 10/9/24
Great news! It looks like Mario and Danie...

a 5 A 4

 

 

10:04 ow «LTE @)

12 Messages

& Inbox Parenting plan vA

Alexandria Packard 10/9/24
To: Veronika KiT~ Goodnight >

 

Great news! It looks like Mario and Danielle's
every-other week slots both line up at 1pm
starting Monday, 10/14. I'm happy to get
Aidan and Raina scheduled with them for that
time slot. If you could send me their ages, I'll
get the paperwork sent over to you shortly.
It's all via adobe so no need to print

anything.

Warmly,

On Wed, Oct 9, 2024 at 4:10 AM KiT Spins
<kit@kitspins.com> wrote:

: Show Quoted Content

attachments. Confidential health information is protected by state and
federal law, including, but not limited to, the Health Insurance Portability
and Accountability Act of 1996 and related regulations.

 

 

 

Alexandna Packard, M.S., LMFTA
P: 206.518.2849 | F: 425.209.0766
Jarchcounseling.com

Confidentiality Notice:

a 5 A 4

 

10:05 wl) LTE @)

12 Messages

€ Inbox Parenting plan ws WS

Found in Gmail Sent Mailbox qG

%& Veronika KiT~ Goodnight 10/9/24
To: Alexandria Packard >

This is so divine! ./\,

Aidan is 8
Raina is 6

Thank you,
Veronika
Sent from my iPhone

On Oct 9, 2024, at 5:27PM, Alexandria

Packard <alexandria@larchcounseling.com>
wrote:

See More A

a 3 Alexandria Packard 10/10/24
“ig” Fantastic! | just sent over the intake pack...

Veronika KiT~ Goodnight 10/10/24
af Are we confirming 10/14 at 1pm for both...

B 5 A 4

 

