Parents don't trust Highland Hall teachers

Highland Hall, after another bout with abuse in 2004, tried to send our kids on an "all-teacher" supervised camping trip.  The parents would have nothing of it.  As it turned out, the poorly-supervised trip yielded the hitchhiking incident I refer to elsewhere in this blog.

 

Letters to Minor's Counsel - 8

Attorney at Law

            JUNE ADLER                                                                                   

                CERTIFIED SPECIALIST - FAMILY LAW                                                                                                        

                        CALIFORNIA BOARD OF LEGAL SPECIALIZATION                                                                                                   

                        OF THE STATE BAR OF CALIFORNIA                                                                                                                                      

                                                                                                                                                           

                                                                         May 6, 2005

Bruce Abramson, Attorney at Law

Lenske and Abramson

Lawrence A Sobel

            Re:            Marriage of Karaiskos

Dear Counsel:

This is intended to address letters from Mr. Abramson dated May 19, 2005 and Mr. Sobel dated the same date.  I apologize in advance for the amount of history and detail that this response will require, but it seems my client has already answered some of these concerns and has not been heard.  With regard to Mr. Abramson's letter:

My client is troubled by Mr. Abramson's response regarding the children's school.  There is no doubt in my client's mind that any attempt to remove the children from Highland Hall will result in a trial.  From his first meeting with Mr. Abramson, Mr. Karaiskos described Highland Hall school as a cult environment - something that is common to many if not all Waldorf schools.  His opinion in this regard has only strengthened since then and has the support of many people who have encountered Waldorf education around the world.  That Highland Hall's curriculum introduces Anthroposophy to the students is something Mr. Karaiskos has suspected for some time, but clear and decisive evidence of the extent to which this happens has come to his attention only recently.  Neither Highland Hall, nor Ms. Karaiskos has ever indicated to Mr. Karaiskos in any way that Anthroposophy and the strange ideas of Rudolf Steiner (the founder of Anthroposophy and Waldorf schools) would be part of the curriculum.  In fact, this has been repeatedly denied by both the school and by Ms. Karaiskos, and yet the facts show otherwise.  This true intent of Waldorf education is not easily discernable at first glance or even after much involvement - especially in a cult environment where deception and denial is part of the process.

It is Mr. Karaiskos' foremost concern to protect his children from this environment - to remove them from this school.  Which school they attend outside of Highland Hall and other Waldorf schools is not nearly as important to Mr. Karaiskos as removing them from this environment.  Certainly, an entire summer is available before a decision as to exactly which school they attend has to be made.  This is not a matter of selecting one school over another, it is a matter of removing the children from an inappropriate and harmful environment. 

Mr. Karaiskos is extremely concerned that Mr. Abramson has not investigated his claims against the school despite many, many complaints to Mr. Abramson.  In light of this apparent fact, my client believes that the case supporting his claims can only be presented in open court and he is prepared to support these claims with a substantial mass of evidence. 

A recent first communication between my client and a total stranger, Dr. David R. Stronck, PhD, Professor, Science Education, Department of Teacher Education, California State University, Hayward, CA. yielded the following response:

I am a Professor of Teacher Education at the California State

University, East Bay.  My Ph.D. is in Science Education.  I have

reviewed some of the Waldorf materials for teaching science and have

found them silly and wrong.  I strongly agree with you that children in

a Waldorf School are being cheated out of a reasonable education.  Our

society tolerates religious schools.  Unfortunately Waldorf Schools

pretend that they are not religious while in practice they are 

promoting their strange religious philosophy.  You may quote me and I want to 

help you.  I do not want to accept money from you and would prefer to remain

simply as a reference without any need for travel.  I could be 

contacted for an interview (perhaps by phone) or could write a letter.

My client would like to invite Mr. Abramson to call Professor Stronck to assess the extent of the problems with Waldorf education curriculum and the deception they promote before suggesting that Mr. Karaiskos complaints are frivolous.  Perhaps a more evenhanded treatment of my client's position in this matter would yield a settlement possibility.  If Mr. Abramson would like the work and home phone numbers for Professor Stronck, either Mr. Karaiskos or I can provide them.

In the case that Mr. Abramson insists that the children remain at Highland Hall school where there is a cult environment, and where they are brainwashed on a daily basis to curriculum that is, in Professor Stronck's words, "silly and wrong" my client would insist on absolutely equal access to his children so that he has ample opportunity to present them with a balanced world view and address their daily concerns about what they are learning in school.  This is absolutely essential to maintain balance in their lives and it is what all three children want and have expressed to Mr. Abramson repeatedly.  Despite Mr. Abramson's opinion that Mr. Karaiskos has influenced their decision, the children truly want an equal balance between parents.  Children believe in fairness and sharing both parents equally is what ALL children of divorce want in their hearts.

It is unconscionable to Mr. Karaiskos that his children were inducted into Highland Hall deceitfully, and that Ms. Karaiskos threatened divorce when Mr. Karaiskos protested, but at this point Mr. Karaiskos wants to move forward.  He would, of course, prefer the children's removal from Highland Hall.  Any public or private school environment would be better than the wacky, religious, cult-like environment of Highland Hall.  Mr. and Ms. Karaiskos chose a completely different area to raise their family.  During this divorce, Mr. Karaiskos and the children were forced out of the family home in Newbury Park, an area where the schools the finest in the state, and an area that all three children miss.  Returning to this area would be ideal for the children as it is one of the safest cities in the U.S.  This is Mr. Karaiskos' true desire for the children, but he does not hold out hope for such cooperation from Ms. Karaiskos.  As a local alternative, Mr. Karaiskos would prefer Lawrence middle school in Chatsworth, and Chatsworth high school, also in Chatsworth.  These schools are within 5 miles of both current residences.  Despite this exercise, it remains a fact that any school suggestion by Mr. Karaiskos other than Highland Hall is sure to result in a court trial. 

It is my client's opinion that Mr. Abramson's refusal to listen to his clients, and to research Mr. Karaiskos' claims regarding Waldorf education is causing attorney's fees to be increased in this case.  A reasonable attempt by Mr. Abramson to listen to both sides of this issue, and to the repeated requests of his clients would move things toward a settlement.  Mr. Karaiskos is working toward a reasonable goal of equally shared custody, equally shared responsibility and equal division of property.  That Ms. Karaiskos has exasperated his attempts by insisting on a one-sided settlement, and that she now apparently has Mr. Abramson's support over the wishes of his own clients is unfortunate but it only strengthens my client's resolve to bring the lopsidedness of this case to the eyes of the court. 

With regard to Mr. Sobel's letter dated May 19, 2005, many of Mr. Sobel's questions have been answered above.  Custodial time is directly tied to school placement IF such placement is at Highland Hall school because Highland Hall school represents a cult-like environment where the Karaiskos children are being bombarded with "information" that is simply not true.  Highland Hall has repeatedly put the Karaiskos children in harms way.  Mr. Karaiskos has expressed in the past and again feels compelled to express that equal access to his children during the school year is essential to counteract their indoctrination into Anthroposophy which is provided by the school they currently attend and to allow them the opportunity to process this in a non-Anthroposophical environment.  Highland Hall does not make clear that it is a religious school, yet it clearly is immersed in strange religious philosophy and has religious underpinnings that are not only wacky but are spattered with racist philosophy.  Mr. Karaiskos has been very generous in his request for equal custody.  To be truly fair, Mr. Karaiskos would need to ask for an hour with the children for every hour they are in school in addition to every hour they are with their mother.

With regard to Nicholas attending Highland Hall for his senior year, Mr. Karaiskos has had to weigh the benefits of removing him against the harm of keeping him in Highland Hall.  The senior year for Waldorf students is the year most filled with indoctrination into Steiner's philosophy.  It is the year that students are asked to discard conventional science and accept Goethean science.  Nicholas has already expressed to Mr. Karaiskos that he understands the science he is learning at Highland Hall isn't real science.  Mr. Karaiskos intends to monitor Nicholas' assignments to ensure that an equal compliment of accepted science accompanies his learning experience.

A change of school for {son} and {daughter} is, indeed, necessary.  Their time at Highland Hall has been difficult to be sure.  {Son} has already been kept a year behind.  Mr. Karaiskos feels that if the children test at their grade levels, something he is not confident about, then Highland Hall could be considered for them - again, as long as equal time is given to Mr. Karaiskos for the purpose of monitoring their daily experiences.  Mr. Karaiskos would prefer to remove {son} and {daughter} from Highland Hall.  Many of their friends have been removed from this school and are thriving in the schools they currently attend.  {Son} and {daughter}, while perhaps initially opposing this change, will also thrive in a new school environment.

The bottom line is that Highland Hall is a potentially harmful environment that is not providing the children with anything that resembles a good education.  The children should be removed.  Where they are placed is of secondary importance as any public school will have state standards, testing, actual text books and safeguards that Highland Hall does not have.  Ms. Karaiskos, because of her religious convictions to Anthroposophy and Waldorf education, will fight this in court.  There will be no settlement possible in this case as long as Ms. Karaiskos insists on keeping the children in Highland Hall AND denies Mr. Karaiskos equal access to the children.  Mr. Karaiskos has discovered that Highland Hall is a cult environment and he will not willingly submit his children into it any longer without safeguards.

Addressing the issue of funds for Ms. Karaiskos' car, I believed my letter was sufficiently clear in this regard without going into great detail.  It now seems necessary to provide additional background.  Ms. Karaiskos drained the family equity line of credit of $20,000 at the beginning of these proceedings.  In doing so, she left my client without the resources to hire an attorney.  My client ended up having to represent himself in court.  Meanwhile he asked for and received Ms. Karaiskos' cooperation in applying for a $10,000 extension to the equity line of credit (the maximum allowable at the time and payments on which Mr. Karaiskos alone was making) so that he could borrow the money against it to secure an attorney.  Ms. Karaiskos later withdrew her cooperation on Mr. Sobel's advice and Mr. Karaiskos was compelled to ask the court for permission to allow this transaction.  When he did, Mr. Sobel insisted on an equal amount to be disbursed to himself.  This undermined Mr. Karaiskos' attempts to hire an attorney as the requested amount would have been cut in half.  This put my client at a huge disadvantage throughout the first year of these proceedings and led to the lopsided stipulated order that Mr. Karaiskos has been fighting ever since.  Mr. Sobel and his client have already reached or exceeded their half of the equity of the home.  Cooperation is one thing, simply handing over 16 years of equity in the family home is another.

With regard to the discovery responses, I have explained to Mr. Sobel that I was out of the office when his demands were made.  My client only received them a week ago and is having his accountant prepare two years of income tax returns.  Mr. Sobel has already threatened to bring in a forensic accountant and my client wants to be sure there are not errors or discrepancies that will suggest to Mr. Sobel that this is necessary.  Again, Mr. Sobel has set a precedent in this.  When Mr. Karaiskos was acting pro per in this case, he delivered his discovery documents to Mr. Sobel's office.  When it was requested that Mr. Karaiskos leave the documents for Mr. Sobel's staff to copy, Mr. Karaiskos did so.  After several requests for the return of his original documents (over a week had dragged on) Mr. Karaiskos' was told that his documents had finally been copied and again, Mr. Karaiskos came to Mr. Sobel's office to pick them up.  However, when Mr. Karaiskos made his request for discovery, Mr. Sobel completely ignored Mr. Karaiskos' request and only provided him with discovery documents not only weeks late but, in fact, as they were entering the courtroom.  Mr. Karaiskos has a witness that will verify this if necessary.  As if that weren't enough, Mr. Karaiskos realized after looking at the documents that most of the relevant information was obscured because Mr. Sobel's staff had placed the cancelled check for each expense over the document - and a second discovery request had to be made to recover the information on the documents.  Mr. Sobel is in no position to complain about Mr. Karaiskos' timely response having already set a precedent of disregard for proper procedure.  Mr. Karaiskos is preparing the discovery documents in a timely manner and will have them ready as soon as possible - hopefully by Monday.

On another note, Mr. Karaiskos is extremely disappointed in Mr. Abramson for divulging to {son} that one parent (obviously Mr. Karaiskos) wanted to keep him from going on the school camping trip.  There was absolutely NO reason for Mr. Abramson to express this to {son} except in an attempt to undermine Mr. Karaiskos as a parent.  Furthermore, Mr. Abramson asked {son} if Mr. Karaiskos had been asking him about attending other schools - again, there is no reason to ask this question.  Now {son} is needlessly worrying about having to be removed from his school when, in fact, no such action is currently being taken.  Mr. Karaiskos feels that a line has been crossed here and that the attention of the judge in this matter needs to be directed to Mr. Abramson's performance as the children's attorney.  Furthermore, because Mr. Abramson has been unwilling to accept the repeated requests from his clients for a fair custody schedule, Mr. Karaiskos feels Mr. Abramson is dragging this case into court and should be held accountable for this.  Mr. Karaiskos feels Mr. Abramson is neither representing the Karaiskos children nor acting in their best interests when he undermines one parent with unnecessary comments and Mr. Karaiskos intends to ask that Mr. Abramson be removed as children's counsel. 

Letters to Minor's Counsel - 7

Attorney at Law

            JUNE ADLER                                                                                   

                CERTIFIED SPECIALIST - FAMILY LAW                                                                                                        

                        CALIFORNIA BOARD OF LEGAL SPECIALIZATION                                                                                                   

                        OF THE STATE BAR OF CALIFORNIA                                                                                                                                      

                                                                                                                                                                                                  

                                                                                                                                       

                                                                         April 14, 2005


Bruce Abramson, Attorney at Law
Lenske and Abramson


            Re:            Marriage of Karaiskos

Dear Mr. Abramson:

I am in receipt of your letter dated March 30, 2005 and a response from Mr. Sobel dated March 31, 2005. 

Neither Mr. Karaiskos nor I am aware of any or order that suggest he may not contact you directly about matters concerning the children in this matter.  If you would like me to instruct him not to contact you directly about these types of issues, please indicate so.  Mr. Karaiskos is concerned, however, that because of the very little contact you have had with your clients, the children are reluctant to call you when problems arise in their lives.  Mr. Karaiskos feels he has been put in the position of having to be an advocate for what the children feel their best interests are, even when their outlook is in conflict with his own concerns for their best interests (their desire to remain in their current school for example).  Mr. Karaiskos is hoping you will take the time to find out what the children feel their own needs and best interests are soon, because it is far more likely that a reasonable settlement might be achieved if the children's desires and best interests were more accurately taken into account.  You have indicated that you will interview the children when they have had two therapy sessions each.  At this time, {Daughter} has had two recent therapy sessions and {Son} and {Son} have each had one.

Mr. Karaiskos is also concerned about {Son}' grades.  He has collected but not passed on to you, more recent failure notices from the school.  While Mr. Karaiskos appreciates your suggestion that an educational therapist might be helpful for {Son}, Mr. Karaiskos feels he has demonstrated repeatedly that {Son} will do his homework when he is in Mr. Karaiskos' home.  It doesn't seem reasonable to assume this is a psychological problem when it only occurs at one parent's home.  This appears to be a parenting problem - of one parent letting {Son} get away with no homework and the other insisting that it be done.  

Mr. Karaiskos will not be teaching the 4 week class at Highland Hall as expected.  The teacher of the 7th grade, Mrs. Knight, who asked him to step in and teach the class has taken ill and will be out for the remainder of the year.  This left the final decision in the hands of the school administrators.  A substitute teacher will teach the class for the remainder of the year.  Mr. Karaiskos experience has come to the attention of another teacher.  Mr. Karaiskos has been asked by the physics teacher, Mr. Mellett, to supply teaching materials, input and possibly to lecture to the 10th grade students on mechanics.

With regard to the children continuing their education at Highland Hall, Mr. Karaiskos suggests you may have read too much into his willingness to help the children.  Mr. Karaiskos' commitment was to the students, not to the school.  Mr. Karaiskos is involved in the community and has the support of many parents, teachers and staff, despite his open criticism of the school administrators and the underlying philosophy.  As long as the Karaiskos children go to this school, Mr. Karaiskos supports the school community in many ways as an example to his children.  Mr. Karaiskos has not changed his mind about the institution itself - as it is mired in a religious philosophy that is problematic.  The idea that the children would attend this school must be predicated on equally divided custody - and that would have to include the school year.  Mr. Karaiskos' requirement to monitor the children's education at this challenging school is the cornerstone of this compromise and without fulfillment of this custody requirement, Mr. Karaiskos will not accept this school for the children in any settlement. 
 
So, to answer your question, the trial issues still pertaining to your clients are custody and school.  Mr. Karaiskos feels a reasonable compromise can be achieved only when the custody issue is examined in conjunction with the school.  Please note that equally shared custody was in place for three years before formal divorce proceedings were initiated.

I would also like to respond to Mr. Sobel's March 31, 2005 letter here.  Again, I have to wonder if I have been told to tell my client not to contact you.  I suggested he call you directly about the vaccination issue because no response had been given to his reasonable request to vaccinate his children. 

There is no official document that suggests that Mr. Karaiskos would be teaching at Highland Hall.  This was done as a person-to-person agreement between Janet Knight, the 7th grade teacher, and Mr. Karaiskos.  At this school, things are done informally.  Mr. Karaiskos prepared an outline of the mechanics class and submitted it to the leadership team of  Lori Gardner and Laura Ferris, per their request so the school might decide whether or not Mr. Karaiskos might teach the class in Mrs. Knight's absence.  That is the only written documentation.  Mrs. Knight told Ms. Gardner and Ms. Ferris that Mr. Karaiskos would be teaching this lesson block and they contacted him by phone to ask for his outline.  Mr. Karaiskos has subsequently been invited by the physics teacher, Mr. Tom Mellett, to lecture and provide support on Mechanics in April for his 10th grade science classes.  Mr. Karaiskos has accepted this invitation.

Mr. Sobel seems confused that appointments were made at Kaiser for the children.  I don't know the basis for his confusion.  It was clear in correspondences that Kaiser was available for the children and that the availability of therapy there should be exhausted before other therapists were utilized.  Furthermore, you prepared a stipulation dated approximately February 11, 2005 that stated in paragraph 2:

"Initially, all three (3) minor children shall utilize the counseling services afforded through their Kaiser Health Insurance coverage.  These services shall continue until such time as to each minor child, when such child's therapist/counselor deems that further counseling is not necessary, if such services are no longer available through Kaiser (having been exhausted), or if the counselor recommends that a different counselor be utilized.  Issues to be addressed in {Son}'s counseling shall include his attitude toward school and his failure/refusal to complete the schoolwork assigned to him."

While the stipulation was not signed by all parties for other reasons, it bears the signatures of both Mr. Sobel and Ms. Karaiskos.  When Mr. Sobel pretends to be surprised that "Mr. Karaiskos apparently took it upon himself to unilaterally schedule appointments for the children with mental health professionals at Kaiser.  This came to my client's attention when she received a letter from Kaiser indicating that appointments had been set for each of the three children." - I would suggest he would not be as surprised if he and his client actually paid attention to the documents they signed.  Mr. Karaiskos interpreted your stipulation, signed or not, as expressing a directive - that the children should be placed in counseling immediately.  That is exactly what Mr. Karaiskos took upon himself to do.  Ms. Karaiskos was immediately made aware of the appointments and agreed to them.  Both parents participated equally in the process.

{Daughter} went to therapy on Tuesday, March 16th.  Mr. Karaiskos took her to the therapy and my client has expressed that the therapist, Ms. Flynn, suggested he stay in the session for some period of time - certainly not half the session.  It was upon Mr. Karaiskos' own suggestion that he left the room.  At Ms. Karaiskos' suggestion, and an email will confirm this, Mr. Karaiskos also took {Son} to his therapy session on March 30th (during Ms. Karaiskos' custody).  Mr. Karaiskos has described to me that again he was invited into the therapy by Mr. Perrin and {Son} asked that Mr. Karaiskos stay.  Mr. Karaiskos describes it as a very positive session.  Toward the end of the session, Mr. Karaiskos excused himself so that {Son} might have some opportunity to talk with Mr. Perrin one-on-one.  Mr. Karaiskos also informed Mr. Perrin that {Son)  would be in to see him the following day and that he should perhaps look at school and homework issues when he works with {Son} - again based on your directive in the unsigned stipulation.  Both {Daughter} and {Son} had appointments on March 31st.  Mrs. Karaiskos took them.

With regard to Mr. Sobel's claim of Mr. Karaiskos' "unilateral submission" of the children to therapy, this type of characterization is simply a waste of everyone's time.  In fact, Mr. Sobel himself indicated specifically that Mr. Karaiskos could make the children's appointments but that they would have to be agreed to by Ms. Karaiskos (and they were).  The claim that Mr. Karaiskos took this initiative unilaterally while it was in accordance with your instructions, Mr. Sobel's conditions and the knowledge, approval and participation of Ms. Karaiskos is absolutely without merit.  Mr. Karaiskos has, however, left it up to Ms. Karaiskos to make the next appointments.  So far, two weeks have passed and no effort has been made by Ms. Karaiskos to continue the children's therapy.  It seems Mr. Karaiskos will, again, be taking the initiative to schedule appointments for the children.


June Adler

Letters to Minor's Counsel - 6

*The following two letters to minor's counsel were written by my attorney regarding obtaining therapy for {Daughter}:

Re: Counseling at Kaiser

It has never been my client's impression or suggestion that counseling afforded through Kaiser is ineffective.  It can hardly be expected that substantive progress would take only a few weeks.  Yet, {Daughter}, specifically, showed steady improvement during the short time she had counseling at Kaiser.  My client went to considerable efforts to meet personally with the counselors at Kaiser and to take his children to their therapy.  He was pleased and impressed with both counselors who, within a few short sessions, had a good grasp of the problems the children were facing.  In meeting with Mr. Perrin, the counselor for both boys, it became apparent that Ms. Karaiskos had painted a very untruthful picture of Mr. Karaiskos.  This information was offered by Mr. Perrin to my client without having been asked - and after meeting with Mr. Karaiskos, Mr. Perrin even commented that he thought something "smelled fishy" in Ms. Karaiskos' story.  Mr. Perrin indicated that he would contact {Daughter}'s counselor to let her know his impressions of Mr. Karaiskos.  When Mr. Karaiskos met with Ms. Flynn, {Daughter}'s counselor, she too seemed surprised at how different Mr. Karaiskos was compared to the picture painted by Ms. Karaiskos.  Ms. Karaiskos' constant criticism of Mr. Karaiskos in front of the children and to others is in large part the reason the children are in therapy in the first place.  Short of removing the children from her custody, providing counselors who are in a position to understand the nature of the problem fully would benefit these children most.  Both of the counselors at Kaiser are now aware of how Ms. Karaiskos distorts the truth and disparages the children's father.  I would suggest that these are the "other reasons" Ms. Karaiskos has elected to pursue other counseling at great expense despite the availability of counselors who the children are comfortable with and that are familiar with the children and the situation.  Nonetheless, this valuable insight that the counselors at Kaiser are now privy to puts them in a far better position to help the Karaiskos children.  My client has seen progress in even the short time the children were in counseling and would be in favor of keeping the children in counseling at Kaiser as long as it is available to them.

My client was also never under the impression that therapy through Kaiser was no longer available.  At his last meeting with her, Ms. Flynn indicated that, while the group sessions had ended, she would be willing to treat {Daughter} on an individual basis even though {Daughter} had not attained the age requirement at the time - as of Friday, {Daughter} will have attained that age anyway.  Mr. Perrin left it up to {Son} as to whether he would like to continue and suggested that {Son} might be brought back after a month.  None of the three children had their benefits terminated.  My client was under the impression that Mr. Abramson had contacted both therapists and had arrived at a different understanding about the availability of services through Kaiser.

With regard to {Son}'s counseling, Mr. Karaiskos feels that there are many deep-seated issues affecting {Son}'s outward attitude to his school assignments.  While choosing not to do his homework is certainly an important symptom of his problems, there are issues of lack of self-esteem and self-worth that need to be addressed in counseling and elsewhere.  Mr. Karaiskos has tried to address these issues independently to some degree by offering {Son} work and by paying him handsomely for the work he does.  {Son}'s rebellion is directed toward the school he is in.  His lack of respect for his teachers and lack of respect for the assignments he is given all underlies the main problem which is that {Son} is an extremely intelligent young man who has had to endure a sub-standard education his whole life.  And he knows it.  He is rebelling because he feels he has been denied the benefits of an education that would have recognized his intelligence and rewarded it instead of making every attempt to subdue it - as Waldorf schools do.  {Son} feels that it is too late for him to get the education he has deserved his whole life.  He doesn't really want a change at this point - he wants to finish this year and next and be done with it.  Mr. Karaiskos does not agree that it is too late and feels that any counseling for {Son} should explore issues with the overall education {Son} has received at his school and his attitude toward his teachers and his education in general as much as his attitude toward doing homework.

 ***

Attorney at Law

            JUNE ADLER                                                                                   

                CERTIFIED SPECIALIST - FAMILY LAW                                                                                                      

                        CALIFORNIA BOARD OF LEGAL SPECIALIZATION                                                                                                    

                        OF THE STATE BAR OF CALIFORNIA                                                                                                                                                                                                                                                            

                                                                         February 2, 2005


Bruce Abramson, Attorney at Law
Lenske and Abramson


            Re:            Marriage of Karaiskos

Dear Mr. Abramson:

            This is intended as a response to the January 26, 2005 letter from Mr. Sobel.  I regret that he is so concerned about the fact that the issue of therapy is taking so much time.  My client, Mr. Karaiskos, has authorized me to take whatever time necessary to represent his position.  It may seem like a waste of time to Mr. Sobel, but simply stating that my client does not reverse his position on counseling for the children and not explaining why would not fully relate what my client has asked me to convey.

            Nobody is more concerned about the expenses involved in this case than my client, especially as it appears Ms. Karaiskos has exhausted for the most part her share of the proceeds from the sale of the home, through payment of attorney fees and other costs as ordered by the court.  My client is concerned that he will be saddled with the cost of therapy for the children in addition to his regular child support payments, while at the same time therapy through Kaiser is available immediately and should be exhausted before other therapists are sought.

            Ms. Karaiskos has apparently reversed her decision to allow the children to continue therapy at Kaiser because she now believes the counselors have been “poisoned” by having experienced her true nature.  I would suggest the following:

            1.            If Ms. Karaiskos did not make the statements Mr. Karaiskos claims she made to the therapist, then no “poisoning” has occurred and she should have no objection to allowing the same counselors to see the children.

            2.            If Ms. Karaiskos did, indeed, make statements disparaging Mr. Karaiskos as described in my previous letter, it is unlikely she will make the same mistake with a new therapist.  Therefore the Kaiser therapists are better suited to know the situation the children live under when at their mother’s home.  It is my client’s position that Ms. Karaiskos’ abhorrence toward my client and her constant representation to the children that she is fearful of Mr. Karaiskos represent the bulk of reason the children require treatment in the first place.

            3.            In the event that you believe the therapists at Kaiser that the children are familiar with are unsuitable, it is unlikely that Kaiser does not employ other therapists that may be utilized.

            In summary, Kaiser is available and should be utilized immediately.  Mr. Karaiskos related to me that he has noticed, especially in {Daughter}, serious despair.  She has become withdrawn for the most part and while Mr. Karaiskos has been able to work with her to help her, he feels she requires professional attention immediately.  He feels that she has already established a trust relationship with Ms. Flynn at Kaiser and that Ms. Flynn would be able to help her immediately.  My client feels there is no reason to delay this process and Ms. Flynn could be utilized while Mr. Sobel and his client pursue court intervention and whatever delays that would entail.

            It is my opinion that this matter is of utmost importance.  If you, as minors’ counsel, feel that this issue needs court intervention, please inform me immediately so that no further time can be lost in arranging for therapy for the Karaiskos children.

                                                                        Sincerely,



                                                                        June Adler

Letters to Minor's Counsel - 5

Attorney at Law

JUNE ADLER                                                                                

CERTIFIED SPECIALIST - FAMILY LAW                                                                                                

CALIFORNIA BOARD OF LEGAL SPECIALIZATION                                                                                                     (

OF THE STATE BAR OF CALIFORNIA                                                                                                                                     

                                  

                                                                        

December 22, 2004

Bruce Abramson
Lenske, Lenske and Abramson
Attorneys at Law

Re:          Marriage of Karaiskos

Dear Mr. Abramson:

It has become very uncomfortable for me having to reply to the multitude of letters which are being sent to you regarding the parenting skills and/or alleged problems with the two parents.  Nevertheless, it was somewhat of a relief to have Mr. Sobel address the last episode which he considers the problem, to‑wit, Mr. Karaiskos’ emails to Ms. Karaiskos.  Even though I would rather not, I feel it is only proper for me to respond to try to get across the frustration and helplessness which Mr. Karaiskos is feeling because of the irresponsible way the children are being treated by their mother.

I think we all have to sit back and consider just what Mr. Karaiskos has been through in these proceedings, having equal custody suddenly wrested from him despite a three year equal-custody precedent, being forced out of his home despite it not being in foreclosure and moving close to the children's school only to discover that closer proximity does not make custody more available to him, the children's own wishes notwithstanding.  He has had to stand up against emotional abuse of his daughter at the hands of her teacher, and because of his efforts he had to endure verbal abuse and threats of expulsion of his children from the children's school.  Still, he was able to take charge of his son's education and work productively with teachers at the very same school to ensure that his brilliant child doesn't fail high school.  And yet, having endured all this without anger, something has made him so angry that he criticizes Ms. Karaiskos’ judgment in emails which he very well knows that Mr. Sobel will take every opportunity possible to present to the court.  Mr. Karaiskos believes that some of the actions which Ms. Karaiskos has taken toward the children border on child endangerment and as he detailed in the emails intended for Ms. Karaiskos, many incidents have occurred in the past that display Ms. Karaiskos' poor judgment and irresponsibility toward their children.  Let us consider some of the following facts starting with the most recent and most critical:

1.          As you know, we have recently experienced a period of extremely cold weather.  During that period of time, Ms. Karaiskos repeatedly sent the children to school underdressed.  Their son, {Son}, was sent to school regularly wearing shorts during a period of time when it was near freezing in the morning.  A telephone call to {Son}'s teacher will verify this.  Mr. Karaiskos asked his son why he was wearing short pants only to be told that he did not have long ones.  After this had gone on for several weeks and despite several requests to Ms. Karaiskos and the fact that Ms. Karaiskos has received all child support payments up to date, including a very large lump sum, she has not seen fit to buy {Son} the clothing that he needs and Mr. Karaiskos was forced to provide long pants for {Son}.  {Son} is not the only one about whom Mr. Karaiskos was concerned.  None of the children have proper winter jackets.  He has seen {Daughter} sent to school in short dresses in the bitter cold.  He has received the children underdressed for several weekends in a row and Mr. Karaiskos had to send {Son} to school on a Monday morning wearing his own jackets on two occasions so that he would not be cold.  Now, of course, the jackets have ended up at Ms. Karaiskos’ home and have never been returned. 

When Mr. Karaiskos tries to address these legitimate concerns, Ms. Karaiskos and her attorney characterize his concerns as “psychobabble.”  I am certain that you can realize just how frustrating it is for Mr. Karaiskos who is under an outlandish order for paying child support, seeing it paid current, and then, out of sheer frustration and concern for the health of his children, ending up purchasing {Son} long pants.  In fact, the children need lots of clothing and Ms. Karaiskos had purchased almost NO clothing for them in several months.  Mr. Karaiskos still purchases all their shoes for them.  The children need winter clothing and the weather has been cold.  Just how long should Mr. Karaiskos allow Ms. Karaiskos’ poor parenting to endanger their children without bringing it to her attention and failing to get a reasonable response from her, to the attention of the court?

2.          It is not only clothes of which Ms. Karaiskos deprives her children.  The children frequently complain to their father of not having food in their mother's home and always complain about not having milk.  On a typical weekend at Mr. Karaiskos' home, the children drink between four and five gallons of milk.  Ms. Karaiskos denies the children other products they need.  On one weekend alone, Mr. Karaiskos found it necessary to spend over $50.00 on  personal and hygienic products that {Daughter} needed, most of which she ended up taking back to Ms. Karaiskos’ home and which probably will never be seen again by Mr. Karaiskos.  Given the financial situation in this case, I am certain you can understand just how upsetting it is for Mr. Karaiskos to supplement the children's needs only to watch Ms. Karaiskos spend the child support money she receives on herself and on expensive trips while she denies them milk and food.

3.          All of the children want to exchange Christmas presents with their friends.  Mr. Karaiskos supports this because he knows that their friends will buy them presents and it would be embarrassing for the children not to reciprocate.  They should not be put into position where they could not purchase gifts for their friends.  Ms. Karaiskos has made no effort to purchase any such presents except that she made and subsequently broke a promise to {Daughter} to LOAN her $100 for Christmas gifts - a promise that Mr. Karaiskos fulfilled for his daughter.  Ms. Karaiskos relies on the children using the money which Mr. Karaiskos gives to them, forcing them to use that money to purchase presents - and in fact expected {Daughter} to repay the "loan" in this way.  While Ms. Karaiskos refuses to contribute to the welfare of the children financially, Mr. Karaiskos in contrast is trying to build character by having them do small jobs around the house for which they are paid handsomely.  As an example, {Daughter} swept the porch and Mr. Karaiskos gave her $10.00, she got $20.00 for cleaning her room and $20.00 for decorating the Christmas tree.  

4.          Mr. Karaiskos attempted to discuss the issue of Christmas presents with Ms. Karaiskos by email.  He was first ignored, then informed that instead of Christmas presents, she was taking the children on a trip to Colorado to visit her sister - a trip that {Son} has expressed he would prefer not to go on.  This was a decision made by Ms. Karaiskos which was very difficult for Mr. Karaiskos to accept.  He knows how important it is for the children to give and receive Christmas presents as it is a representation of the Christmas spirit.  What Ms. Karaiskos has done is put Mr. Karaiskos in a position of having to buy the children extra presents because she has made her choice that they should not have presents, other than a trip to Colorado. 

5.          The children are going to Colorado which has created another frustrating episode for Mr. Karaiskos and another dangerous situation for the children.  As the children have been underdressed for school all year, his concern is, and the children confirm, that the mother will not buy them jackets before they go to Denver.  Has she read the weather reports from Denver lately?  A look at the National Weather Bureau web site will confirm that the HIGH temperature on December 23, 2004 will be 7 degrees. Does she realize that when the children get off the plane that they are likely to be met with sub-freezing weather and possibly snow flurries and that they need jackets at the very least.  It is quite likely they will be wearing canvas tennis shoes in the show.  It would seem reasonable to expect that Ms. Karaiskos should at least buy the children jackets in advance of the trip to protect their health instead of exposing them to physical harm from the cold which they are about to experience.  Because of Ms. Karaiskos' history of irresponsible behavior, Mr. Karaiskos would like evidence that this requirement has been met before the trip.  The children inform their father that their mother is intending to buy their jackets in Boulder which is an hour trip from the Denver airport. Exposing the children to freezing weather without proper cold-weather clothing for that period of time is unconscionable and downright neglectful.  This is a situation that requires your intervention for the protection of your clients.

6.          It is most frustrating to Mr. Karaiskos that Ms. Karaiskos does not answer his emails.  Perhaps if she would explain things to him and her way of thinking, this could alleviate the tension between these parties.  Is Mr. Karaiskos angry?  At this point, yes he is.  He is continually frustrated by Ms. Karaiskos’ continued inattentiveness to the needs of their children.  As an example, her lack of attention to {Son}’ grades, to {Daughter}’s personal hygiene and social needs, and to {Son}’s clothing needs, all of which have been documented.  This situation goes back for two years or more.  If you look into some of the evidence which has been submitted, you will find pictures of {Son}’s shoes with holes in them, with the pictures taken mid‑March during the rain.  Is it Ms. Karaiskos’ way of conveying to the court and to the children that she does not get enough child support? How can she justify her actions when she is leaving the State of California on a vacation before Christmas and then flying the children to Colorado after Christmas, apparently with adequate funds to do so?  Unfortunately for Ms. Karaiskos, the father is a very caring father who suffers greatly when he knows that his children are being harmed.  Seeing to the children’s clothes is something that all good parents do.  It does not seem an unreasonable demand to make on the mother, particularly when she receives child support and is in a much better financial position to accommodate the children than the father. 

7.          I am certain that you cannot imagine just how frustrating is becomes for Mr. Karaiskos when the children come to him consistently for their needs, obviously frightened or at the very least reluctant to make the demands on their mother.  Mr. Karaiskos is still supplying the children with their needs, which is aggravated by the fact that he is paying over guideline child support.  When the parties first separated custody was equally shared and child support was not involved, Mr. Karaiskos simply bought the children whatever they needed without complaint, and, knowing Ms. Karaiskos, without expectation that she would contribute - and she did not contribute.  He did this for three years prior to the dissolution proceedings.  Since then, the child custody has been unfairly divided, and the funds that are being paid are not getting to the children at all.  The children need long pants and jackets in winter, not expensive trips out of state that they would rather avoid.  Mr. Karaiskos has found that communicating with Ms. Karaiskos in a nice way does not work.  She does not answer him regardless of the nature of the email.  The only time he gets a response is when she feels that exposure of her behavior to the court would be a real threat.  Then she gets her attorney involved and attempts to throw blame at Mr. Karaiskos. 

8.          In addition, her lack of consideration for Mr. Karaiskos and his life is unbelievable.  Ms. Karaiskos scheduled a vacation out of state without the children during her custodial time.  She simply assumed that Mr. Karaiskos would want to take the children (always a safe assumption for this particular parent) but did not make any arrangements or even inform him of her decision until only a couple of days beforehand.  Mr. Karaiskos has had to reschedule an out of town business trip which he had planned for Friday and Saturday in order to accommodate the children during her custodial time.  Not only has this been inconvenient, but it makes him look bad to his clients.  Can’t there be any simple communication on the part of Ms. Karaiskos - especially when she is infringing on Mr. Karaiskos' time?                                        

Mr. Sobel has brought up the fact that Mr. Karaiskos is paying {Son} to do work for him while at the same time he has issued complaints regarding the amount of child support.  Mr. Sobel likes to accuse me of merely signing my name to Mr. Karaiskos’ letters.  I want you to know at this point that I am using Mr. Karaiskos’ words because he has written an articulate explanation as to why it is financially beneficial for him to hire {Son} while at the same time instilling responsibility and a sense of accomplishment in their son {Son}. I do not understand Mr. Karaiskos’ business and needed his input.   

{Son} has been working with his Dad for a short time and Pete is allowed to pick up {Son} from school at 4:00 and must return him to his mother’s home at 7:30.  Ms. Karaiskos is unwilling to do any of the driving.  Pete feeds {Son} dinner while he is there so he has plenty of time to do his homework at his mother’s home after 7:30.  If it could be arranged, Pete would like to have {Son} overnight on those nights so that he could help him with the homework and be sure that it is done.  In regard to paying {Son}, Pete has been offering him an hourly wage of about $20.00 an hour, dependent on the type of work he does – word processing for example is paid at a lower rate than CAD drafting.  This is far more than he could earn elsewhere and it has only been a couple of nights that they have tried this.  Mr. Karaiskos believes that what Mr. Sobel is suggesting is that if he is able to afford to pay {Son}, then he should give the “extra” money directly to his client for her needs.  Mr. Sobel has no information regarding Mr. Karaiskos’ business and consequently that will need to be clarified.

{Son} is able to do some of the tasks his father does and charges for.  It takes him longer so Pete pays him less than he would bill a client for his own time.  Recently, {Son} researched and put together an outline for a technical manual for a client.  Pete could have done the work in an hour.  {Son} did the work in three.  The work {Son} did was equivalent to the work Pete could have done and Pete billed the client for an hour of his time, thus allowing him to pay {Son} for three hours of work.  Please be alerted that Pete is claiming this as an hour of his income for Mr. Sobel’s calculation of his child support obligation.  Pete feels that it is important enough for {Son} to receive this experience and he is willing to make sacrifices, including driving time and an occasional hour of work, so that he gets it. 

As with any independent contracting business, there are some jobs that just do not have enough money in them or they come at a time when other jobs are already scheduled.  Last year, for example, Pete was contacted by someone who wanted him to draw a plat plan for his property.  While Pete would normally charge more, the client only offered $75.00.  At the time, Pete had another job that was more pressing but rather than turn down the job, he asked {Son} if he wanted to do it.  {Son} agreed and received the $75.00 for about three or four hours work.  Pete feels this is excellent experience for {Son} and, especially since he is not driving yet, it provides him with a way to work, to earn income and to receive technical training, skills and a reference for his resume that he would not be able to acquire in any other way.

Mr. Karaiskos would also like to touch on another issue that needs to be addressed and he believes that you have a direct interest in resolving this issue.  While therapy for the children is still available through Kaiser, Pete would like to exhaust that option before moving to a more expensive therapist.  After all, the children are insured and the therapy is available.  The children know and like the therapist and progress has been made.  It makes sense to Pete that they continue there while this option exists.  Pete would appreciate your opinion on this. 

Both Mr. Karaiskos and I are very sorry that you have had to be dragged in on this.  It all seems so simple.  Children need warm clothing in winter.  One parent should not have to ask the other parent to provide this when funds for exactly that purpose have been made available.  And then when it is questioned, the characterization of that request as “psychobabble” is inflammatory and indicative of the instability of the parent who denies addressing the request.  And still, the children need warm clothing.  It is unfortunate that the parenting skills of these parents are so diverse.  Common sense dictates that money is in place for the children to have what they need, if only the money was prioritized for use by the children.  Please be advised that Mr. Karaiskos will not sit back and let his children’s emotional stability, health and education be placed at risk because of a neglectful parent who is more interested in her personal needs and carrying on a vendetta than she is in her children's well-being.

Sincerely,

June Adler

cc:          Lawrence Sobel

Client

Letters to Minor's Counsel - 3

Bruce D. Abramson

of Lenske, Lenske & Abramson

re: Dissolution of Karaiskos

Dear Mr. Abramson,

I would like to report a very disturbing phone call I received from {Daughter} on Friday, September 3rd.  {Daughter} had been in the custody of her mother for the entire week.  She called me and when I asked her how she was doing she said "Not so good."  She explained that Highland Hall had refused to re-enroll her and that it is due to my emails criticizing the school.  Then she went on to describe the horrible conditions found in the new public school she is supposed to attend and how horrible it would be if she went to a public school - how she now wants to return to Highland Hall.  She asked me to stop emailing as Highland Hall is taking it out on her.  I explained to her that I have not been issuing any emails regarding Highland Hall.  The fact is, I have not issued any emails since Mrs. Leonard left two weeks before Highland Hall first threatened to expel {Daughter} in June.  {Daughter} went on to say that she knew that the court ordered me to stop emailing but that I am trying to start emailing again and that is why they won't re-enroll her in school.

I believe several disturbing things have occurred while {Daughter} was in the care of her mother: 

1)      Angela has fueled {Daughter}'s fears about attending public school, something {Daughter} embraced a few short months ago.  Fear of public schools is something Waldorf schools regularly instill in parents and students.  During the phone call, {Daughter}'s anxiety regarding pubic school was tremendous.

2)      Angela has been, once again, reading directly to {Daughter} from the court orders and from the  confidential proposed settlement agreement offer I made which was issued by Ms. Adler to Mr. Sobel (in which I stated that I felt the court should allow me the freedom to deal with the school as I have in the past).  This would explain {Daughter}'s comment that she knew the court orders to me but that I am trying to start emailing again.  I have documented cases of Angela reading from court orders to the children in the past and despite direction from the court, she continues to do this.

3)      Angela has, again, tried to drive a wedge between me and {Daughter} AND between me and the school.  Both Angela and the school have blamed {Daughter}'s expulsion on me and, in fact, this is not true.  If I were the problem, my other two children's enrollment would be in jeopardy, but this is not the case and no indication has been made that {Son} or {Son} are affected by my participation at the school EXCEPT that {Daughter} has been told by her mother that if I continue emails, {Son} and {Son} may be expelled.  {Daughter} has taken the additional stress upon herself to ensure that I no longer produce emails about Highland Hall in order to protect her brothers from expulsion. 

4)      It is very likely that {Daughter} has been expelled for reasons other than my email campaign exposing Mrs. Leonard.  Most people I have talked to agree that it was {Daughter}'s own defiance of Mrs. Leonard and the school that have caused her to be expelled.  I am also told that because of Angela's own inappropriate activities at the school, she has made enough enemies that she may have caused this decision or, at least has been unable to reverse this decision. 

5)      I believe Angela has shared the contents of the confidential proposed settlement agreement (mentioned above) with the school.  This would explain the school's reluctance to accept as binding the stipulation that I would abide by the communications protocol. 

After spending only a day with me, {Daughter} felt much better about attending public school - not through anything I said to her, but just by being away from Angela's influence.  I believe Angela is doing anything she can, regardless of the emotional torment she is causing, to distance me from these children and from their school.  She wants me out of her life and out of the children's lives - this is clear.  She intentionally misrepresented to you my relationship with the school and my participation in the children's extracurricular activities in hopes that she would gain autonomy over their schooling.  I feel the needless anxiety she has put {Daughter} through regarding pubic school is shameful and harmful.  I feel that exposing {Daughter} to court documents or their contents is absolutely inappropriate.

Just to be clear, I have only just found out (from {Daughter}'s telephone call on September 3rd) that {Daughter} will not be allowed to attend Highland Hall.  Up until this time Angela has indicated that {Daughter} will be attending Highland Hall and I have worked under this assumption.  As this new development is now extremely stressful for her, and as you have indicated that she should attend Highland Hall if possible, I have worked behind the scenes and called in favors with a few influential people at Highland Hall to see if this decision can be reversed so that {Daughter} can have the option of attending.  I have been informed tonight (Monday) that this can be accomplished and that the likelihood of her being accepted is very high. 

Bruce, please know that I am absolutely devoted to the children's well-being.  It is difficult for me to continually point out problems with Angela's parenting to the court, but I believe Angela is putting stress on {Daughter} with her actions and with her own fears of public schools.  Your intervention on {Daughter}'s behalf is requested to ensure that Angela discontinues sharing legal and confidential information with {Daughter}.

Thank you.


Sincerely,


Pete Karaiskos

Letters to Minor's Counsel - 2

Bruce D. Abramson

of Lenske, Lenske & Abramson

re: Dissolution of Karaiskos 

Dear Mr. Abramson,

I don't exactly know what happened yesterday in court, but I can only assume that my concerns about Highland Hall are shared or are at least being considered by the court.  I very much took to heart Commissioner Weiss' warning that by going to trial, we may be "playing with fire."  While I am certain that my case against Highland Hall is very strong and the evidence, testimony and witnesses I could provide would ensure the immediate removal of the children from that school, it is not my intention or desire to expose the children to any additional stress as would be expected if a trial were to ensue.  Nor am I interested in hurting their mother's position with them or with her place of employment.  Furthermore, as I have already acknowledged, it is likely there will be some stress on the children if they are removed from this school at this time without preparation for alternative schools.  I am torn between my desire to remove them from what I feel is a dangerous and demoralizing environment and their desire to remain in that same environment (despite its obvious shortcomings).  Looking toward a compromise, I am hoping we could avoid trial by adoption of the following recommendations that I am proposing at this time:

1. That the children remain in their current school for the time being and that primary authority for the children's schooling be granted to me.  I will monitor their progress and their overall experience with the school and, should their continuation at Highland Hall become problematic, I would like to be able to exercise the right of any other parent at that school, (and the assumption by which this and all private schools operate) to withdraw the children.  I would absolutely consult you before taking any such action so that you might intervene on behalf of the children.
2. I feel it is important to maintain my position as an advocate for reform of the school during my children's school experience.  This is consistent with what I have done since the year 2000 and my "watchdog" attitude serves to protect my children and indeed all the children at the school while they are there.  I cannot control what Highland Hall does with regard to the children's enrollment.  They have expelled children in the past for any number of reasons - often without explanation and frequently through no fault of the child.  They could expel my children on a whim or to make a point as they already have with {Daughter}.  In any case, my interaction with the school has been longstanding and, until these divorce proceedings, my children have never been expelled.  The court should not serve orders regulating my interaction with the school but instead, allow me the freedom to interact with the school as I have always done and as other parents are free to do. 
3. Highland Hall school is primarily a religious school based on Anthroposophy, a quasi-religious movement.  The children's mother is an Anthroposophist.  There has never been an agreement between the children's mother and myself to raise the children in this religion and, in fact, the more I learn about Anthroposophy, the more shocked and concerned I am about its basic tenets.  It is not in the children's best interests to be swallowed up in Anthroposophy.  To offset the children's religious experience at Highland Hall and the inflexible influence of their mother, and to provide adequate time and opportunity to supplement their education on subjects not of interest to Highland Hall, I would propose an equally-shared custody arrangement on the one week switch basis.  This custody arrangement is in the children's best interests, has the support of the children and does not presuppose one parent's authority over the other.
4. The children have been seriously impacted by the fighting and inappropriate behavior between their parents.  Therapy is absolutely indicated for them and this would be a requirement of this agreement. 

I feel that each and every one of these points have to be accepted in order to avoid a trial.  A close review of what I have asked for will reveal that my requests are simply returning to what was the status-quo before these divorce proceedings.  The children remain at Highland Hall, I deal directly with the school regarding communications (without court intervention) and custody is shared equally.  The only real issue that I am asking for is the right every other parent at the school has - to make decisions on the children's behalf if the school becomes problematic - this is a right I should have had from the start and even this I am willing to share with you.  I believe these are very reasonable requests and that they are all in the best interests of your clients.  If you feel comfortable making these recommendations, I would encourage you to do so and hopefully we can avoid a costly and difficult trial that would certainly do more harm than good for the children.


Sincerely,



Pete Karaiskos