Opinion

Speedie

Court: District Court, W.D. Washington
Filed: May 29, 2026
Cited by: 0 cases
Authority: More cited than 41.4%

The opinion

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

AT SEATTLE

The Honorable John H. Chun

13 DAVE NEIL SPEEDIE,

No. 2:26-cv-00345-JHC

14 Petitioner,

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15 v.

16 ALEXI DAWN SPEEDIE,

17 Respondent.

JURISDICTION

Jurisdiction is vested in this court by virtue of:

22 The Court has federal jurisdiction under the International Child Abduction Remedies Act

23 (“ICARA”) § 9003 because this case involves the alleged retention of two children under the age of

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sixteen (16) in the United States from their alleged habitual residence of Canada. Congress has

specifically granted concurrent original jurisdiction to the federal court of actions arising under the

3 Hague Convention. ICARA § 9003. Neither party disputes jurisdiction.

4 CLAIMS AND DEFENSES

5 PETITIONER

The Petitioner will pursue at trial the following claims:

Father brings the following claims: (A) a claim for return of the parties’ children to Canada

under the 1980 Hague Convention on the Civil Aspects of International Child Abduction (the “Hague

Convention”) and ICARA, 22 U.S.C. § 9001 et seq.; and (B) a claim under ICARA § 9007 for necessary

expenses relating to the return of the children.

12 Father seeks an order for return of the children to Canada. Thereafter, and in accordance with the

13 schedule and procedure set forth in this Court’s Local Rule 54, Father will seek an order and judgment

14 against Mother for an award of necessary expenses, including court costs and transportation costs,

relating to return of the children in accordance with ICARA § 9007, Federal Rule of Civil Procedure 54,

and Local Rule 54.

RESPONDENT

Respondent will pursue the following defenses and affirmative defenses at trial:

20 Respondent denies that Petitioner is entitled to the requested relief and denies that Petitioner can

21 establish the elements necessary to prove his prima facie case under the Hague Convention. Respondent

22 further asserts the affirmative defense under Article 13(b) of the Hague Convention that return of the

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children to Canada would expose the children to a grave risk of physical or psychological harm or

otherwise place the children in an intolerable situation.

3 Respondent additionally asserts that separation of the joint minor children from their older

4 siblings, K.N. and A.N., in the event the Court finds grave risk as to A.N. or the non-joint older children,

5 would itself create a grave risk of emotional and psychological harm to the joint minor children.

Respondent requests that the Petition for Return of Children be denied.

ADMITTED FACTS

The following facts are admitted by the parties:

1. The parties were married on February 20, 2017, in Fort Langley, British

Columbia. Dkt. #26, ¶ 11, Dkt. #32, ¶ 11.

12 2. The parties are the parents of two children, LS (boy, born in 2018) and IS (girl,

13 born in 2024) (collectively the “children”). Dkt. #26, ¶ 12, Dkt. #32, ¶ 12.

14 3. LS and IS are both under the age of sixteen (16). Dkt. #26, ¶ 49, Dkt. #32, ¶ 49.

4. The children are currently located within the Western District of Washington.

Dkt. #26, ¶ 8, Dkt. #32, ¶ 8.

5. Father is a Canadian citizen. Dkt. #26, ¶ 14, Dkt. #32, ¶ 14.

6. Mother is a homemaker. Dkt. #26, ¶ 18, Dkt. #32, ¶ 18.

20 7. On or about October 9, 2025, Mother filed a Domestic Violence Protection Order

21 (“DVRO”) in state court in Whatcom County, Washington, Case Number 25-2-02128-37. Dkt. #26, ¶

22 25, Dkt. #32, ¶ 25.

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8. On or about December 8, 2025, the Whatcom County court stated that it would

assume permanent jurisdiction unless British Columbia established communication with it; and that any

3 foreign order would have to be approved by a Whatcom County judge. Dkt. #26, ¶ 27, Dkt. #32, ¶ 27.

4 ISSUES OF LAW

5 The following are the issues of law to be determined by the court:

PETITIONER

1. Petitioner’s Prima Facie Case

To meet his prima facie burden, Father must establish by a preponderance of the evidence: (1)

that the children’s habitual residence immediately prior to the date of retention was Canada; (2) that

Father had rights of custody to the children under Canadian at the time of the retention that were

12 breached by the retention; and (3) that Father was exercising his rights of custody to the children at the

13 time of the retention, or would have been exercising his rights of custody but for the retention. Mother

14 disputes every element of Father’s prima facie case.

Father may rely upon the authority listed below in support of his prima facie case.

Treaties, Statutes and Rules

i. Hague Convention, preamble and articles 1, 3, 5, 12, 14, 16, 17

ii. ICARA § 9001 et seq.

20 iii. Fed. R. Civ. P. 44.1

21 Cases

22 iv. Abbott v. Abbott, 560 U.S. 1 (2010)

23 v. Abou-Haidar v. Sanin Vazquez, 945 F.3d 1208 (D.C. Cir. 2019)

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vi. Asvesta v. Petroutsas, 580 F.3d 1000 (9th Cir. 2009)

vii. Colchester v. Lazaro, 16 F.4th 712 (9th Cir. 2021)

3 viii. Cuellar v. Joyce, 596 F.3d 505 (9th Cir. 2010)

4 ix. E. Sussex Children Servs. v. Morris, 919 F. Supp. 2d 721 (N.D. W. Va. 2013)

5 x. Feder v. Evans-Feder, 63 F.3d 217 (1995)

xi. Gaudin v. Remis, 282 F.3d 1178 (9th Cir. 2002)

xii. Gomez v. Gonzalez, 771 F. Supp. 3d 1150 (W.D. Wash. 2025)

xiii. Holder v. Holder, 305 F.3d 854 (9th Cir. 2002)

xiv. In re ICJ, 13 F.4th 753 (9th Cir. 2021)

xv. Lozano v. Montoya Alvarez, 572 U.S. 1 (2014)

12 xvi. Monasky v. Taglieri, 589 U.S. 68 (2020)

13 xvii. Nisbet v. Bridger, 124 F.4th 577 (9th Cir. 2024)

14 xviii. Nelson v. Petterle, 782 F. Supp. 2d 1081 (E.D. Cal. 2011)

xix. Palencia v. Perez, 921 F.3d 1333 (11th Cir. 2019).

xx. Papakosmas v. Papakosmas, 483 F.3d 617 (9th Cir. 2007)

xxi. Radu v. Shon, 62 F.4th 1165 (9th Cir. 2023) (“Radu III”)

xxii. Redmond v. Redmond, 724 F.3d 729 (7th Cir. 2013)

20 xxiii. Sealed Appellant v. Sealed Appellee, 394 F.3d 338 (5th Cir. 2004)

21 xxiv. Walker v. Walker, 701 F.3d 1110 (7th Cir. 2012)

22 xxv. Whallon v. Lynn, 230 F.3d 450 (1st Cir. 2000)

23 Other Authority

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xxvi. Eliza Perez-Vera, Explanatory Report: Hague Convention on Private International Law, in 3

Acts and Documents of the Fourteenth Session (1980)

3 xxvii. Hon. James D. Garbolino, The 1980 Hague Convention on the Civil Aspects of International

4 Child Abduction – A Guide for Judges (3d. ed. 2023)

5 xxviii. United States Department of State Legal Analysis, 51 Fed. Reg. 10494 (1986)

2. Respondent’s Discretionary Exceptions

There are certain narrow discretionary exceptions to return under the Convention which, if

asserted and established by a respondent might allow a court in its discretion to decline to return a child.

See Convention arts. 13 and 20. Mother here asserts one exception: the article 13b grave risk exception

to return. The article 13b exception must be established by clear and convincing evidence. ICARA at §

12 9003(e)(2).

13 Father may rely upon the following authority in opposition to Mother’s asserted exception:

14 Treaties, Statutes and Rules

i. Hague Convention, article 13

ii. ICARA § 9001 et seq.

Cases

iii. Aubert v. Poast, No. 24-cv-926-jdp (W.D. Wis. Sept. 18, 2025), appeal docketed, No. 25-

20 2732 (6th Cir., Oct. 1, 2025)

21 iv. Colchester v. Lazaro, 16 F.4th 712 (9th Cir. 2021)

22 v. Cuellar v. Joyce, 596 F.3d 505 (9th Cir. 2010)

23 vi. Golan v. Saada, 596 U.S. 666 (2022)

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vii. Gomez v. Fuenmayor, 812 F.3d 1005 (11th Cir. 2016)

viii. Nowlan v. Nowlan, 543 F. Supp. 3d 324 (W.D. Va. 2021)

3 ix. Radu v. Shon, 62 F.4th 1165 (9th Cir. 2023) (“Radu III”)

4 x. Wertz v. Wertz, 2018 WL 1575830 (No. 7:18-cv-00061. W.D.Va., Mar. 30, 2018)

5 Other Authority

xi. Eliza Perez-Vera, Explanatory Report: Hague Convention on Private International Law, in 3

Acts and Documents of the Fourteenth Session (1980)

xii. Hon. James D. Garbolino, The 1980 Hague Convention on the Civil Aspects of International

Child Abduction – A Guide for Judges (3d. ed. 2023)

xiii. United States Department of State Legal Analysis, 51 Fed. Reg. 10494 (1986)

12 3. Ameliorative Measures

13 Courts may consider imposing ameliorative measures (also known as protective measures), in

14 Hague Convention cases in which the article 13b exception to return is asserted by a respondent. The

concept of ameliorative measures is meant to reconcile the competing interests of preventing wrongful

removals and retentions and protecting the safety of children by considering the inclusion of

ameliorative measures in return orders, to mitigate the potential risk of harm occasioned by the child’s

repatriation.

20 Father may rely upon the following authority with respect to ameliorative measures:

21 i. Golan v. Saada, 142 S. Ct. 1880 (2022)

22 ii. Radu v. Shon, 11 F.4th 1080, 1089 (9th Cir. 2021) (“Radu I”)

23 iii. Radu III

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iv. Simcox v. Simcox, 511 F.3d 594, 605 (6th Cir. 2007)

3 4. Washington State Court Orders

4 Article 17 of the Hague Convention expressly provides that “[t]he sole fact that a decision

5 relating to custody has been given or is entitled to recognition in the Requested State (here the United

States of America) shall not be a ground for refusing to return a child under this Convention.

Convention, art. 17 (emphasis added).

The Hague Convention is a treaty and is the supreme law of the land. Under well-settled

principles of law, this Court is therefore strictly bound by article 17 of the Hague Convention.

Accordingly, this Court cannot deny the Father’s Hague Convention case on the sole basis that an order

12 relating to custody exists in the Washington State Court. Id. Under article 17 of the Convention, a parent

13 who wrongfully removes or retains a child cannot insulate the child from the Convention’s return

14 provisions by obtaining a state court custody order. United States Department of State Legal Analysis,

51 Fed. Reg. 10494, 10504-05.

The Seventh Circuit decided the leading case on exactly this legal issue. Walker v. Walker, 701

F.3d 1110, 1116 (7th Cir. 2012). The Seventh Circuit instructs in Walker that article 17 of the Hague

Convention “qualifies the finality of any state-court custody judgment and thus ensures that there is still

20 a live controversy before the federal court.” Id. It further instructs that when habitual residence is

21 disputed in a Hague Convention case:

22 Until that question is resolved, we cannot say which country’s courts have

the power to resolve the issue of custody. As Article 17 of the Convention

23 implies, the antecedent question must be answered before we know what

weight to give to the judgment of the Illinois court.

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Id.

The Seventh Circuit explains that this approach “makes sense, given the purpose of the

3 Convention.” Id. It explains that accepting a position whereby an abducting parent could “render a

4 petition for return moot by racing to a courthouse in her chosen country to obtain a custody judgment

5 would turn the Convention on its head.” Id. The Seventh Circuit recognizes that “[t]he entire purpose of

the Convention is to deter parents from absconding with their children and crossing international borders

in the hopes of obtaining a favorable custody determination in a friendlier jurisdiction.” Id. (citations

omitted). Considering a Hague Convention case moot based on the existence of any state court custody

judgments would “encourage the very sort of jurisdictional gerrymandering the Convention was

designed to prevent.” Id. The Washington State Court orders in this case therefore have no bearing on

12 this Court’s habitual residence analysis.

13 5. Authority for Independent Sexual Abuse Investigation

14 In Mother’s Expert Disclosures, she alleged for the first time in this litigation that Father has

sexually abused Mother’s older daughter, (Father’s step-daughter; age 17; not the subject of this case).

Mother did not allege sexual abuse in her Answer (Dkt. # 32), or in her Initial Disclosures served on

May 5, 2026, or in her Answers to Interrogatories served on May 14, 2026.

Father seeks to exclude Mother’s two proposed experts from testifying—Dr. Landon Poppleton

20 for not meeting Daubert standards, and Dr. Jeffrey L. Edelson for failure to produce a report. See

21 Section G infra. Mother has not proposed offering any forensic evidence through either of her experts in

22 support of her position that sexual abuse has occurred. She proposes only that her older daughter,

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A.M.N., be interviewed by the Court in chambers. (Dkt. #48). Father opposes Mother’s motion for in-

chambers only testimony. (Dkt. #51).

3 In the event the Court requires a forensic investigation in this circumstance, the Court has

4 authority to appoint an independent investigator. In Nowlan v. Nowlan, a Hague Convention case in the

5 Western District of Virginia, the respondent-mother alleged the petitioner-father had committed sexual

abuse against the child at issue but did not present any forensic evidence relating to the allegations of

child sexual abuse. 543 F. Supp. 3d 324, 330 (W.D. Va. 2021). At the conclusion of the evidentiary

hearing, the court therefore appointed two independent experts to conduct a neutral forensic evaluation

of the child under Fed. R. Civ. P. 706. Order of Appointment at 2, Feb. 5, 2021, ECF No. 74. The same

mechanism is available here, if after the evidentiary hearing the court concludes that a forensic

12 evaluation is necessary for the Court to evaluate Mother’s allegations and her article 13b alleged

13 exception.

14 6. Article 30 Self-Authentication and Admissibility of Documents

Article 30 of the Hague Convention provides that:

[a]ny application submitted to the Central Authorities or directly to the

17 judicial or administrative authorities of a Contracting State in accordance

with the terms of the Convention, along with documents and other

18 information appended thereto or provided by a Central Authority, shall be

admissible in the courts or other administrative authorities of the

Contracting States.

Convention, art. 30 (emphasis added).

ICARA further provides that no authentication of any such documents moved into evidence by

the Father is required. ICARA § 9005; see also Ngassa v. Mpafe, 488 F. Supp. 2d 514, 518, n.3 (D.

Md. 2007). “ICARA bypasses the authentication requirement ‘[w]ith respect to any application to the

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United States Central Authority, or any petition to a court.’ 22 U.S.C. § 9005.” Nowlan v. Nowlan,

543 F. Supp. 3d 324, 356 (W.D. Va. 2021) (emphasis in original).

3 7. Other Evidentiary Points of Law

4 Father incorporates by reference herein the pending and forthcoming motions in limine, and the

5 oppositions thereto:

i. Father’s Motion in Limine (Daubert motion regarding Mother’s proposed expert

Dr. Landon Poppleton), Dkt. # 47; Mother’s opposition not yet filed.

ii. Father’s forthcoming Motion in Limine (exclusion of Mother’s proposed expert

Dr. Jeffrey L. Edelson for failure to produce a report).

11 RESPONDENT

12 1. Petitioner’s Prima Face Case

13 Respondent disputes whether Petitioner can establish the elements necessary to prove a prima

14 facie case under the Hague Convention, including disputed issues regarding the children’s alleged

habitual residence, the existence and exercise of custody rights, and whether any alleged retention was

wrongful within the meaning of the Convention. Petitioner bears the burden of proving the elements of

his prima facie case by a preponderance of the evidence. See 22 U.S.C. § 9003(e)(1)(A); Cuellar v.

Joyce, 596 F.3d 505, 508 (9th Cir. 2010).

20 Respondent disputes Petitioner’s prima facie case under the Hague Convention, including

21 allegations regarding habitual residence, wrongful retention, custody rights, and the exercise of custody

22 rights.

23 Treaties, Statutes and Rules

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i. Hague Convention, preamble and articles 1, 3, 5, 12, 14, 16, 17

ii. ICARA § 9001 et seq.

3 iii. Fed. R. Civ. P. 44.1

4 Cases

5 iv. Abbott v. Abbott, 560 U.S. 1 (2010)

v. Abou-Haidar v. Sanin Vazquez, 945 F.3d 1208 (D.C. Cir. 2019)

vi. Asvesta v. Petroutsas, 580 F.3d 1000 (9th Cir. 2009)

vii. Colchester v. Lazaro, 16 F.4th 712 (9th Cir. 2021)

viii. Cuellar v. Joyce, 596 F.3d 505 (9th Cir. 2010)

11 2. Respondent’s Article 13(b) Grave Risk Defense

12 Under Article 13(b) of the Hague Convention, the Court is not required to order return of a child

13 where the respondent establishes, by clear and convincing evidence, that returning the child would

14 expose the child to a grave risk of physical or psychological harm or otherwise place the child in an

intolerable situation. Hague Convention, art. 13(b); ICARA § 9003(e)(2).

Respondent asserts that the evidence will establish that return of the children to Canada would

expose the children to a grave risk of physical and psychological harm arising from coercive control,

emotional, physical, and sexual abuse, intimidation, unsafe living conditions, alcohol abuse, firearm-

20 related safety concerns, and ongoing fear-based family dynamics within the family home.

21 Respondent further asserts that, in the event the Court determines that grave risk exists as to A.N.

22 or the non-joint older children, separating the joint minor children from their older siblings would itself

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create a grave risk of emotional and psychological harm to the joint minor children. See Aubert v. Poast,

No. 24-cv-926-jdp (W.D. Wis. Sept. 18, 2025), appeal docketed, No. 25-2732 (6th Cir., Oct. 1, 2025).

3 Respondent may rely upon the following authorities:

Treaties, Statutes and Rules

5 i. Hague Convention, article 13(b)

6 ii. ICARA § 9003(e)(2)

Cases

iii. Golan v. Saada, 596 U.S. 666 (2022)

iv. Cuellar v. Joyce, 596 F.3d 505, 508 (9th Cir. 2010)

v. Van De Sande v. Van De Sande, 431 F.3d 567 (7th Cir. 2005)

vi. Khan v. Fatima, 680 F.3d 781 (7th Cir. 2012)

13 vii. Gil-Leyva v. Leslie, 780 F. App’x 580 (10th Cir. 2019)

14 viii. Blondin v. Dubois, 238 F.3d 153 (2d Cir. 2001)

15 ix. Aubert v. Poast, No. 24-cv-926-jdp (W.D. Wis. Sept. 18, 2025), appeal docketed, No. 25-

2732 (6th Cir., Oct. 1, 2025)

3. Ameliorative Measures

In Hague Convention proceedings involving an asserted Article 13(b) grave-risk defense, courts

may consider whether adequate ameliorative or protective measures exist that would sufficiently

mitigate any grave risk associated with return. See Golan v. Saada, 142 S. Ct. 1880 (2022). Respondent

22 disputes that adequate ameliorative measures exist under the facts and circumstances presented in this

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case and contends that no proposed measures would sufficiently protect the children from the risk of

physical or psychological harm upon return to Canada.

3 Respondent may rely upon the following authorities:

4 i. Hague Convention, article 13(b)

5 ii. Golan v. Saada, 142 S. Ct. 1880 (2022)

iii. Radu v. Shon, 62 F.4th 1165 (9th Cir. 2023)

iv. Simcox v. Simcox, 511 F.3d 594 (6th Cir. 2007)

v. Valentina Shaknes & Jeffrey L. Edleson, Protective Measures and their Inability to Protect

Against Domestic Violence (2024).

vi. Merle H. Weiner, How Judges Can Apply the Hague Abduction Convention to Protect

12 Victims of Domestic Violence, 28 UCLA Women’s L.J. 223 (2021).

13 4. Washington State Court Orders

14 Mother agrees with Father’s analysis regarding the Washington State Court orders as to the

Order being used to prove habitual residence in the Hague Convention. However, that is not the

purpose of offering the Order. Mother offers the Order, Respondent’s Exhibit no. 545, not for the

purposes of defending Father’s arguments as to habitual residence, but for the purposes of the Court’s

findings under section 5, Basis and Type of Protection Order, subsection (B), that:

20 Based upon the petition, testimony, case record, and response, if any, the

court finds by a preponderance of evidence that the protected person (or

21 petitioner on their behalf) has proved the required criteria for the

following protection order under chapter 7.105 RCW…Domestic Violence

22 Protection Order- The restrained person has subjected the protected person

to domestic violence: physical harm, bodily injury, assault, or the

23 infliction of fear of physical harm, bodily injury, or assault; nonconsensual

sexual conduct or nonconsensual sexual penetration; coercive control;

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unlawful harassment; or stalking. (For intimate partners or family or

household members only).”

[Protection Order at 4.] In Exhibit 545, found at page one (1), Petitioner in the Whatcom County Order

is Alexi Speedie, and Respondent is David Speedie, who is therefore the “restrained person.” This

finding, when combined with the additional evidence Mother will set forth in trial, supports Mother’s

defense of grave risk pursuant to Article 13b. Additionally, Father stipulates to the authenticity and the

7 admission of Mother’s Exhibit no. 545, Order for Protection – in Whatcom County Court Case No. 25-

8 2-02128-37, dated November 24, 2025.

9 Further, in a Hague Convention case, Staggers v. Timmerman, heard in the Southern District of

Iowa, regarding the return of a minor child to Mexico, the District Court referenced, in its ultimate

denial of Petitioner’s Petition to return the children, the use of an Iowa state court protective order for

domestic abuse issued the same month as Staggers’ (“Petitioner’s”) filing in the Hague case. 746 F.

Supp. 3d 635, 640 (S.D. Iowa 2024). In this case, Timmerman (“Respondent”), alleged defenses under

Article 13b of both acquiescence and grave risk. Id. at 640. The Court in Staggers used the state court

16 order to help in its analysis of Respondent’s acquiescence defense. While the Court’s analysis of the

17 grave risk defense did not explicitly mention the Iowa state court Order, that Court stated, “[t]he record

18 in this case paints a disturbing picture of an unstable and violent relationship between the parties and

as such, a volatile environment for [the child].” Id. at 643.

The Court in Staggers continued to conclude that the child “was not, nor could she have been,

effectively shielded from the psychological and physical violence occurring between the parties. At a

minimum, it is evident that returning [the child] to Mexico would subject her to an intolerable

situation. The Court agrees with the finding in the Report and Recommendation. Even if the evidence

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did not establish direct physical abuse of [the child] by Staggers, the surrounding circumstances and

magnitude of the potential harm constitute grave risk. Notwithstanding her habitual residence, the

3 Hague Convention would not require [the child’s] return.” Id.

4 As stated in Staggers, and as is true here, under a grave risk defense, a court should not return a

5 child to a situation in cases “involving serious abuse or neglect.” Vasquez v. Colores, 648 F.3d 648

(8th Cir. 2011) (citing Silverman v. Silverman, 338 F.3d 886, 900 (8th Cir. 2003)). “The key inquiry is

‘the gravity of risk’ facing the child. Babcock v. Babcock, 503 F. Supp. 3d 862, 882 (S.D. Iowa 2020)

(quoting Acosta v. Acosta, 725 F.3d 868, 876 (8th Cir. 2013)). This analysis focuses on ‘the probability

of harm, but also the magnitude of the harm if the probability materializes.’ Id.” Staggers, 746 F. Supp

3d at 643. The Court states in its analysis, “[c]onsidering the impact of domestic violence in the home

12 on [the child], the Report and Recommendation supports a finding of grave risk.” Id. Therefore,

13 Mother is utilizing the Washington state court order for purposes of supporting her grave risk defense.

14 5. Authority for Independent Sexual Abuse Investigation

In Nowlan v. Nowlan, the West Virginia District Court Hague Convention case cited by

Petitioner as support for an “Independent Sexual Abuse Investigation,” the child was age five (5) at the

time of the case. The child’s allegations were suspected based on physical evidence and statements

from the child. The child was not a 17-year-old, as we have in our case. AKN, the 17 year old daughter

20 of Respondent (Petitioner’s step-daughter), is able to articulate facts on her own and testify

21 competently. Additionally, the Court in Nowlan found the Respondent to not be credible. There are no

22 allegations as to the credibility in the instant case as to Respondent, nor her daughter.

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Under Article 13b, the defense of grave risk, exists when “his or her return would expose the

child to physical or psychological harm or otherwise place the child in an intolerable situation.” In

3 Mother’s response to Father’s interrogatories, sent on May 14, 2026, Mother wrote:

4 Respondent has documented at length Petitioner’s abusive behavior

towards the children and herself, as well as to her oldest daughter, AN.

5 Respondent kept records of Petitioner’s physical, emotional, and

psychological abuse, including in past journal entries, text messages, and

emails. Additionally, there are numerous people who can report their own

7 observations, having witnessed Petitioner’s physical aggression, threats,

intimidation and assaults. Police interviews with the children contain facts

8 that support these claims. There is also a current Washington State

Domestic Violence Protection Order protecting the children and

9 Respondent from Petitioner.

[Respondent’s Response to Petitioner’s Interrogatories to Respondent, at 7, (emphasis added).] So,

Petitioner has been on notice of these allegations since well before this Hague litigation began, and

also throughout this litigation, as there have been numerous references to the Protective Order in the

Washington Case. [ECF 54, Respondent’s Exhibit no. 545]. Respondent’s Declaration in the parties’

Washington State case, Declaration of Respondent in Whatcom County Court Case No. 25-2-02128-

16 37, dated October 9, 2025, very clearly stated allegations of sexual abuse by Petitioner to AKN

17 [Respondent’s Exhibit no. 506.] Also, not only did Respondent send the Declaration in discovery for

18 this case on May 18, 2026, but Petitioner was made aware of the Declaration back in October 2025. Id.

Additionally, Petitioner’s (“Father’s”) own Pretrial Statement, filed May 26, 2026, acknowledged that

the Whatcom County Case, number 25-2-021287-37, was filed on October 9, 2025. [54 at 3]. So, when

Mother mentions “abusive behavior towards…her oldest daughter, AN,” in her responses to the

interrogatories, Father is well aware of the specific nature of the abuse reported.

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Sexual abuse of a minor child in the care of the Father is absolutely relevant as to a defense of

grave risk of harm for the parties’ joint, minor children. AKN began to live with Father when she and

3 her mother moved in with him, when she was approximately eight (8) years old. The Court will hear

4 testimony that the family moved into a home that was approximately 380 square feet, with little to no

5 privacy, and Father had access to AKN daily, while she was both a child, adolescent and teenager.

These behaviors by Father are extremely dangerous to any child.

Additionally, Dr. Poppleton’s report, disclosed to Father within Mother’s Expert Witness

Disclosures on May 15, 2026, mentioned that AKN “reported emotional experiences consistent with

posttraumatic stress disorder, citing further (and consistent with her Mother’s reports of the same) that

her stepfather sexually molested her for many years.” [47-1 at 12.] Dr. Poppleton’s report continued

12 with AKN’s description in explicit detail about the sexual molestation that she underwent by Father

13 from the age of 8 to the age of 16. Id. AKN was also interviewed and disclosed allegations of a sexual

14 nature at the Brigid Collins Children’s Advocacy Center, by Forensic Interviewer Liliana Mendoza, as

documented in the Whatcom County Sheriff’s Office Police Report, Respondent’s Exhibit no. 535,

authored by Detective Sergeant Ken Gates, that was discovered to Father on May 18, 2026. Mother’s

minor child has now been interviewed numerous times in excruciatingly specific details about the

nature of the sexual abuse at the hands of Father. The statements have all remained consistent. Further,

20 there has been no determination by the Court as to the credibility of either AKN, Mother, or Mother’s

21 experts and therefore a neutral evaluator is not necessary.

22 Again, in contrast to Nowlan, the victim here, AN, is of an age and competency in which she

23 can testify to these egregious acts committed by Father over the span of almost a decade. Respondent’s

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(2:26-cv-00345-JHC)

counsel made the simple request that she not be forced to be subjected to the inevitable stare of

Petitioner during her testimony, by seeking in chambers questioning. There is no allegation as to AN’s

3 competency or credibility. Finally, there is no motion pending as to a request for a court-appointed

4 expert witness, as outlined in Fed. R. Civ. P. 706, and therefore, no neutral evaluator need be

5 appointed.

6. Admissibility of Documents

22 U.S.C. § 9005 provides:

With respect to any application to the United States Central Authority, or

9 any petition to a court under section 9003 of this title, which seeks relief

under the Convention, or any other documents or information included

with such application or petition or provided after such submission which

relates to the application or petition, no authentication of such application,

petition, document, or information shall be required in order for the

12 application, petition, document, or information to be admissible in court.

13 The statute addresses authentication requirements for documents submitted in connection with

14 a Hague Convention petition. It does not eliminate hearsay objections or otherwise permit the

automatic admission of affidavits, declarations, or unsworn statements at a contested evidentiary

hearing or trial. Although Hague Convention proceedings may, in some circumstances, proceed in a

summary manner, courts have recognized that the Federal Rules of Evidence continue to apply,

especially an evidentiary hearing is held. Respondent therefore reserves all evidentiary objections

20 under the Federal Rules of Evidence, including objections based on hearsay, relevance, foundation,

21 prejudice, and reliability.

22 Respondent may rely upon the following authorities:

PRETRIAL ORDER

(2:26-cv-00345-JHC)

i. Amsalem v. Amsalem, No. 1:19-cv-119-RP, 2019 U.S. Dist. LEXIS 218812, at *11 (W.D.

Tex. Dec. 20, 2019).

3 ii. Danaipour v. McLarey, 386 F.3d 289, 301 (1st Cir. 2004); Jacquety v. Baptista, 538 F. Supp.

4 3d 325, 339 n.8 (S.D.N.Y. 2021).

5 iii. Luedtke v. Luedtke-Thomsen, No. 1:12-CV-750, 2012 U.S. Dist. LEXIS 90584 at *2 (S.D.

Ind. June 29, 2012).

iv. Karkkainen v. Kovalchuk, 445 F.3d 280, 285 (3d Cir. 2006).

EXPERT WITNESSES

(a) No limitation is requested as to the number of expert witnesses, except as already provided by

virtue of the Court’s Scheduling order setting expert witness disclosure deadlines.

Father has filed a Motion in Limine (Daubert motion) regarding Mother’s proposed expert Dr.

12 Landon Poppleton, Dkt. # 47; Mother’s opposition has not yet been filed.

13 Father intends to timely file a Motion in Limine seeking the exclusion of Mother’s proposed

expert Dr. Jeffrey L. Edelson for failure to produce a report.

(b) The name(s) and addresses of the expert witness(es) to be used by each party at the trial and

the issue upon which each will testify is:

(1) On behalf of Petitioner:

Peter J. Favaro, Ph.D. – Rebuttal Expert

18 617 Port Washington Boulevard

Port Washington, NY 11050

20 Subject Matter: Dr. Favaro may testify in rebuttal to Respondent’s designated experts,

Dr. Landon Poppleton and Dr. Jeffrey L. Edelson. Petitioner has filed a Daubert motion

21 as to Dr. Poppleton. Petitioner will file a timely an objection and motion in limine

as to Dr. Edelson under Rules 26(a) and 37 for failure to produce a report

22 containing Dr. Edelson’s opinions.

23 (2) On behalf of Respondent:

PRETRIAL ORDER

(2:26-cv-00345-JHC)

Landon Poppleton, Ph.D., JD

814 NE 87th Ave,

Vancouver, WA 98664

3 Subject Matter: Dr. Poppleton is expected to testify regarding the opinions and

conclusions set forth in his expert report, including trauma, coercive control, family

4 dynamics, domestic violence-related harm, and the emotional and psychological impact

of the children’s exposure to the home environment at issue in this matter.

Jeffrey L. Edelson, Ph.D.

University of California,

7 120 Haviland Hall,

Berkeley CA 94720

Subject Matter: Dr. Edelson is expected to testify regarding research and professional

9 opinions concerning children’s exposure to domestic violence, coercive control, trauma,

family violence dynamics, and the resulting risk of physical and psychological harm to

children. Dr. Edelson is further expected to testify regarding whether return of the

children to Canada would expose the children to a grave risk of physical or psychological

harm or otherwise place the children in an intolerable situation within the meaning of

12 Article 13(b) of the Hague Convention.

13 OTHER WITNESSES

14 The names and addresses of witnesses, other than experts, to be used by each party at the time of trial

and the general nature of the testimony of each are:

16 PETITIONER

17 Father intends to call the following witnesses to testify during his case-in-chief:

18 A. Petitioner Dave Neil Speedie

Status: Will testify remotely

Subject Matter: Father will testify with regard to all facts set forth in his Verified

21 Amended Petition for Return of Children to Canada & For Expedited Relief and all

relevant averments made in Mother’s Answer. Father will testify with regard to all facts

22 to establish that: (1) the children’s habitual residence is Canada and was so on the date

that Mother retained the children in the United States; (2) Mother’s retention of the

23 children in the United States was in breach of Father’s rights of custody under Canadian

PRETRIAL ORDER

(2:26-cv-00345-JHC)

law at the time of the retention; and (3) Father had been exercising his rights of custody

at the time of Mother’s retention of the children.

B. Petitioner’s Mother, Lorri Sawatsky

3 398 Duclie Road Gambier Island BC V0N 1V0, Canada

4 Status: May testify remotely

5 Subject Matter: Ms. Sawatsky will testify with regard to facts set forth in Father’s

Verified Amended Petition for Return of Children to Canada & For Expedited Relief and

relevant averments made in Mother’s Answer. Ms. Sawatsky will testify with regard to

7 facts to establish that: (1) the children’s habitual residence is Canada and was so on the

date that Mother retained the children in the United States; (2) Mother’s retention of the

8 children in the United States was in breach of Father’s rights of custody under Canadian

law at the time of the retention; and (3) Father had been exercising his rights of custody

9 at the time of Mother’s retention of the children.

C. Petitioner’s Son, Oliver Speedie

6454 Lost Dog Forest Road TaTa Creek BC V0B 2H0 Box 136, Canada

12 Status: Will testify in person

13 Subject Matter: Mr. Speedie will testify with regard to facts set forth in Father’s Verified

Amended Petition for Return of Children to Canada & For Expedited Relief and relevant

14 averments made in Mother’s Answer. Mr. Speedie will testify with regard to facts to

establish that: (1) the children’s habitual residence is Canada and was so on the date that

Mother retained the children in the United States; (2) Mother’s retention of the children

16 in the United States was in breach of Father’s rights of custody under Canadian law at the

time of the retention; and (3) Father had been exercising his rights of custody at the time

17 of Mother’s retention of the children.

18 D. Fraser MacLean – Affiant of Canadian Law

MacLean Law

2900-1021 West Hastings Street

20 Vancouver, British Columbia

V6E 0C3

21 Canada

22 Status: Affidavit Only. The Petitioner will present Mr. MacLean’s Affidavit of Canadian

Law, which was electronically filed on May 15, 2026 (Dkt. #46), in accordance with this

23 Court’s Scheduling Order, article 14 of the Hague Convention, paragraph 101 of the

Perez Vera Report, Federal Rule of Civil Procedure 44.1, Whallon v. Lynn, 230 F.3d 450,

PRETRIAL ORDER

(2:26-cv-00345-JHC)

458 (1st Cir. 2000), Radu v. Shon, 62 F.4th 1165, 1173 (9th Cir. 2023), and this Court’s

Order Denying Mother’s Motion to Compel (Dkt. #52).

Subject Matter: Father’s rights of custody under Canadian law; ameliorative measures.

RESPONDENT

Respondent intends to call the following witnesses:

a. Respondent, Alexi Dawn Speedie

5957 Longdin Road, Ferndale,

7 Washington 98248

Estimated Testimony Time: 2 hours

Subject Matter: May testify regarding all matters before the Court relating to the

9 Petition and Answer, and associated claims and defenses.

Will testify regarding the children’s living conditions in Canada, family dynamics,

Petitioner’s conduct, and matters relevant to Respondent’s Article 13(b) grave-risk

defense.

12 b. Petitioner, Dave Neil Speedie

6454 Lost Dog Forest Road,

13 TaTa Creek, B.C. V0B 2H0,

Canada

14 Estimated Testimony Time: 1.5 hours

Subject Matter: May testify regarding all matters before the Court relating to the

16 Petition and Answer, and associated claims and defenses.

17 c. Non-party minor child, A.N.

5957 Longdin Road, Ferndale, Washington 98248

18 Estimated testimony time: 30 minutes

Subject Matter: Will testify regarding the children’s experiences, wellbeing, and

20 matters relevant to the grave-risk defense.

21 d. Respondent’s Father, Carl Johnson

5957 Longdin Road, Ferndale,

22 Washington 98248

Estimated testimony time: 30 minutes

PRETRIAL ORDER

(2:26-cv-00345-JHC)

Subject Matter: Will testify regarding family dynamics, the children’s wellbeing, and

observations relevant to the grave-risk defense.

e. Respondent’s Mother, Nancy Johnson

3 5957 Longdin Road, Ferndale,

Washington 98248

4 Estimated testimony time: 15 minutes

5 Subject Matter: Will testify regarding the children’s living conditions in Canada,

family dynamics, and matters relevant to the grave-risk defense.

7 f. Petitioner’s former spouse’s current spouse, Sergio Velez

1660 Lacle Jeure Road, Kamloops,

8 B.C. V1S 172, Canada

Estimated testimony time: 15 minutes

Subject Matter: Will testify regarding personal observations of Petitioner’s conduct

and family dynamics.

g. Friend of Respondent, Det Harasuik

12 Address: PO Box 769, Wasa, B.C. V0B2K0

Estimated testimony time: 15 minutes

Subject matter: Will testify regarding observations of the property, living conditions in

14 Canada, and matters relevant to the grave-risk defense.

h. Friend of Respondent, Audrene Harasuik

16 Address: PO Box 769, Wasa, B.C. V0B2K0

Estimated testimony time: 15 minutes

Subject Matter: Will testify regarding observations of the children, family dynamics,

18 and matters relevant to the grave-risk defense.

i. Treating Psychologist, Jayme D. Fergoda, Ph.D., LICSW

20 1313 E Maple St UNIT 224, Bellingham, WA 98225

Estimated testimony time: 30 minutes

Subject Matter: Treating psychologist for the minor children; expected to testify

22 regarding the children’s emotional wellbeing, trauma-related symptoms, and

psychological functioning.

PRETRIAL ORDER

(2:26-cv-00345-JHC)

5 EXHIBITS

® || PETITIONER

Admissibili

8 1 Birth Certificate— | Stipulated Stipulated

LS.

9 (born in June 2018)

10 [Bates No.

DS000264

11 2 Birth Certificate— | Stipulated Stipulated

LS.

12 (born in September

2024)

13 [Bates No.

4 DS000263

3 Photographs of Stipulated Stipulated

[Bates No.

16 DS000082:

DS001608-001609

17 4 Parties’ Loan Stipulated Disputed 802

Request and Home

18 Construction Plan

19 for First Family

Home — May 2018

20 [Bates No.

DS000741

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

I 5 Loan Agreement Stipulated Disputed 802

2 with Respondent’s

Grandmother for

3 Construction of

First Family Home

4 May 2018

[Bates No.

5 DS000739

6 Loan Agreement Stipulated Disputed 802

Modification

7 November 18, 2018

[Bates No.

8 DS000738

7 Registration of Stipulated Disputed 802

9 Parties’ Land

10 Purchase in Ta Ta

Creek, British

11 Columbia for New

Family Home

12 November 2, 2020

[Bates Nos.

13 DS000745-000746

4 Provincial Court of | Stipulated Disputed 401

British Columbia

15 Consent Order —

Petitioner’s Two

16 Older Children

C.B.S. (bom in

17 2010) and Oliver

D.S. Speedie (age

18 19: born in 2006)

19 Entered June 28,

2021

20 [Bates Nos.

DS001597-001599

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

I Respondent’s Stipulated Disputed 401; 802

2 Family Newsletter

with Photographs

3 of Family Reunion

in TaTa Lake to

4 Build Parties’

Home

5 June 2023

6 [Bates Nos.

DS000755-000789

7 10 Father’s Day Card | Stipulated Stipulated

from Respondent to

8 Petitioner — June

16, 2024

9 [Bates Nos.

10 DS000265-000266

11 Canadian Revenue | Disputed Disputed 802

11 Agency Canada

Child benefit and

12 BC Family Benefit

Notice — Issued

13 September 20,

2024 [Bates Nos.

M4 DS001603-001607

15 12 Respondent’s Stipulated Stipulated

Renewed Canadian

16 Driver’s License —

October 14, 2024

17 [Bates No.

DS000734

18 13 Photographs of Stipulated Stipulated

19 Children and

Family in Canada —

20 2018-2025

[Bates Nos.

21 DS000790-000799

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

I 14 Certificate of Disputed Disputed 802

2 Insurance —

Canadian

3 Automobile

Insurance Policy

4 Covering

Respondent — April

5 2026 Policy

6 Renewal

[Bates No.

7 DS000733

15 Text Messages Stipulated Stipulated

8 Between Petitioner

and Respondent

9 July 21, 2024-May

10 6, 2025

[Bates Nos.

DS001277-001343

16 Emails Between Stipulated Stipulated

12 Petitioner and

Respondent

13 June 13, 2025-

August 15, 2025

14 [Bates Nos.

15 DS000875-000904

17 Demand Letter Disputed Disputed 802; 401

16 From Respondent’s

Mother for

17 Payment of 2018

Loan Balance in

18 Full

19 August 5, 2025

[Bates Nos.

0 DS000735-000737

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

I 18 Psychologist, Stipulated Stipulated

2 Michael

Sobocinski, Ph.D.

3 Treatment

Confirmation for

4 2025 and Invoice

Confirming

5 Ongoing Treatment

6 in 2026

[Bates Nos.

7 DS000086;

001347

8 19 Hague Convention | Stipulated Disputed 1002

Application

9 Submitted to the

10 Delegated Central

Authority of British

11 Columbia, Canada

(without

12 attachments)

November 24, 2025

13 [Bates Nos.

DS00003 1-000037

14 20 United States Disputed Disputed 802

15 Department of

State Letter to

16 Whatcom County

Superior Court

17 December 5, 2025

1g [Bates Nos.

DS000077-000079

19 21 Kimberly Royal Disputed Disputed 802

Canadian Mounted

20 Police Information

Check

21 October 22, 2025

(Submitted with

22 Hague Application)

3 [Bates Nos.

DS000083-000085

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

I 22 Petitioner’s Pro Se | Stipulated Stipulated

2 Petition for Return

of Children to

3 Canada

Dkt. #1

4 January 26, 2026

23 Petitioner’s Motion | Stipulated Stipulated

5 for Leave to File

6 Amended Petition

for Return

7 Dkt. #20

March 28, 2026

8 24 Petitioner’s Stipulated Stipulated

Amended Petition

9 for Return

10 Dkt. # 26

April 21, 2026

11 25 Respondent’s Stipulated Stipulated

Answer to

12 Amended Petition

for Return

13 Dkt. #32

4 April 24, 2026

26 Respondent’s Stipulated Stipulated

[Bates Nos.

16 DS000802-000839;

DS001600-001602

17 27 Respondent’s Stipulated Stipulated

Letters to Petitioner

18 [Bates Nos.

19 DS000800-000801;

0008 16-000821

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

I 28 Text Messages Stipulated Disputed 802

2 Between Petitioner,

Respondent, and

3 A.M.N.

(Respondent’s 17-

4 year-old daughter)

[Bates Nos.

5 DS001353-001368

fegmtic, | isee]

Canadian Law — comply with

7 Fraser MacLean FRCP 26

Dkt. # 46

8 30 Curriculum Vitae Disputed Disputed 802; Failure to

of Dr. Peter J. comply with

9 Favaro FRCP 26

11 || RESPONDENT

501 Whatcom County | Stipulated Disputed 802 (except

13 Court Case No. 25- for

14 2-0128-37 — Petitioner’s

Transcript of statements)

15 Proceedings

11/24/2025

16 502 | Text messages Stipulated Stipulated

between Petitioner

17 and Petitioner’s

ig mother, June 12,

2025

19 || |503__| AN’s drawings (2) □ Disputed __| Disputed [802

|504_| KN’s drawings (2) | Disputed | Disputed [802

20 || | 505__| LS’s drawings (2) | Disputed ___| Disputed | 802,

506 | Declaration of Stipulated Disputed 802

21 Respondent in

Whatcom County

Court Case No. 25-

23 2-02128-37, dated

October 9, 2025

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

I 507 | Text Message from | Stipulated Stipulated

2 Petitioner to

Respondent’s

3 parents, dated

October 8, 2025

4 508 | Petitioner’s Stipulated Stipulated

5 to AN

JE pee ee

to Respondent,

7 August 6, 2025

lesen

8 handwritten letter

to famil

9 511 Photo — axe Stipulated Stipulated

10 damage to kitchen

counter

Canada (3

12 513 Photo — Petitioner, | Stipulated Stipulated

13 children in Canada

Plage ff

images from

15 Respondent and

family (7

16 515 | Photos of Stipulated Disputed 401

Respondent and

7 children in

18 Washington (10

516 | Photo — exposed Stipulated Stipulated

jo fitstason [ESE [Siete

□□□□□□□□□□□□□□□□□□□□□ Stipulated _| Stipulated |

| ease fee fee

hole in outhouse

|e fame [Ses [Sees

» dishes

520 | Photo — Stipulated Stipulated

Pe. =

mother with IS

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

I 521 Photo — Stipulated Stipulated

2 Respondent’s father

with IS

(ESSE

(aE = =

IS and LS (2

JS SP

6 — Respondent

525 Declaration of Stipulated Disputed 802

7 Respondent’s

8 October 9, 2025

526 | Email between Stipulated Disputed 802

Respondent and

10 KN’s father, dated

November 3, 2024

11 527 | Email from AN to | Stipulated Disputed 802

Respondent, dated

12 June 19, 2025

528 | Emails from Stipulated Stipulated

13 Petitioner to

14 Respondent, dated

June 26, 2025

15 529 Emails from Stipulated Stipulated

Petitioner to

16 Respondent, dated

July 16-17, 2025

17 530 | Emails from Stipulated Stipulated

18 Petitioner to

Respondent, dated

19 August 5, 2026

20 531 Email from Stipulated Stipulated

Petitioner to

21 Respondent, dated

August 6, 2025

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

I 532 | Email from Stipulated Stipulated

2 Petitioner to

Respondent, dated

3 August 8, 2025

Email from Stipulated Stipulated

4 Petitioner to

Respondent, dated

> August 14, 2025

Petitioner to

7 Respondent, dated

August 15, 2025

8 535 Police report Disputed Disputed 802

interviews of

9 Respondent and

10 children —

Whatcom County

11 Sheriff’s Office

[ome eet [Pome

12 entries (2

537 | Text messages Stipulated Stipulated

13 from Petitioner to

14 Respondent’s

mother

15 538 | Text Messages Stipulated Stipulated

16 and Respondent’s

father

17 539 | Treatment Stipulated Disputed 802

ig summaries of

children by Dr.

19 Jayme Fergoda

20 Curriculum Vitae

541 Dr. Poppleton Stipulated Disputed 802 & MIL

21 report dated May

15, 2026

542 | Dr. Poppleton Stipulated Disputed

==="

May 15, 2026

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

Admissibili

543 | Dr. Edleson Stipulated Disputed

2 Curriculum Vitae

544 | Respondent’s Stipulated Disputed 802

3 College Acceptance

and 1098

4 545 Order for Stipulated Stipulated

5 Protection — in

Whatcom County

6 Court Case No. 25-

2-02128-37, dated

7 November 24, 2025

8 || The Parties’ Objection Code:

9 IE Exhibit is objectionable because it constitutes

10 attempted expert testimony from a person who was

not designated as an expert (Fed. R. Civ. P. 26

WFO Lack of foundation

[MIL Subject of Motion in Limine

13 Signature Page Follows

15 ACTION BY THE COURT

16 || (a) This case is scheduled for trial without a jury on June 2, 3, and 4, 2026 at 9:00 a.m.

17 (b) Trial briefs shall be submitted to the court on or before May 28, 2026 at 5:00 p.m. PDT.

18 This order has been approved by the parties as evidenced by the signatures of their counsel. This order

19 || Shall control the subsequent course of the action unless modified by a subsequent order. This order shall

not be amended except by order of the court pursuant to agreement of the parties or to prevent manifest

20 || injustice.

25 |) pRETRIAL ORDER

36 (2:26-cv-00345-JHC)

1 DATED this 29th day of May, 2026.

John H. Chun

4 || United States District Judge

5 || FORM APPROVED

7 /s/ Kelly A. Powers /s/ Molly Becker

Stephen J. Cullen Katrina Seipel, OSB No. 164793

8 Kelly A. Powers Katelyn D. Skinner, OSB No. 105055

Miles & Stockbridge P.C. Molly Becker, OSB No. 211511

9 1201 Pennsylvania Avenue, N.W. Buckley Law, P.C.

10 Suite 900 5300 Meadows Road, Suite 200

Washington, D.C. 20004 Lake Oswego, Oregon 97035

1 (202) 465-8374 (503) 620-8900

(410) 773-9100 (e-fax) (503) 620-4878 (fax)

12 scullen@milesstockbridge.com kas@buckley-law.com

kpowers@milesstockbridge.com kds@buckley-law.com

13 MB@buckley-law.com

/s/ Katherine E. Coyle

14 Katherine E. Coyle Pro Hac Vice Attorneys for Respondent,

15 Miles & Stockbridge P.C. Alexi Dawn Speedie

100 Light Street

16 Baltimore, Maryland 21202

(410) 385-3487

17 (410) 385-3700 (e-fax)

kcoyle@milesstockbridge.com

19 Pro Hac Vice Attorneys for Petitioner

25 || RETRIAL ORDER

(2:26-cv-00345-JHC)

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.