Citizen Peeper — Legal Defense Fence

Fact spine

• 2026-01-09 · Plaintiff (pro se)

  Requested ADA remote appearance for PTSD, severe anxiety, agoraphobia, executive dysfunction; warned of high risk of anxiety attack if forced to appear in person.

  Written/oral accommodation request in case file · Weight: hard

• 2026-01-09 · Court

  Did not rule on accommodation; hearing proceeded; visible anxiety crisis requiring a break; minutes record only unexplained “break.”

  Hearing video + court minutes · Weight: hard

• 2026-01-09+ · Plaintiff

  Post-hearing disability worsening; agoraphobia / housebound period (~2 months); continued unaddressed ADA needs.

  Medical notes / contemporaneous journal · Weight: testimony

Export draft

On or about January 9, 2026, Plaintiff formally requested a reasonable ADA accommodation (remote appearance via Zoom/WebEx) based on documented disabilities including PTSD, severe anxiety, agoraphobia, and executive dysfunction. The Court did not rule on the request. During the hearing Plaintiff experienced a visible anxiety crisis requiring a break. Court minutes record only an unexplained “break” and do not document the accommodation request or the episode. This denial of interactive process and failure to accommodate violated Title II principles and materially impaired Plaintiff’s ability to participate.

Fact spine

• ongoing · David N. Wolf (public title)

  Holds public AG title as Division Director, Constitutional Defense & Special Litigation; resides adjacent to 1816 S McClelland family property / ADU site.

  State directory + property records · Weight: hard

• ongoing · Carrie Martinez-Wolf (public employment)

  Senior DHHS role with CPS oversight proximity (public employment fact).

  State employment / directory · Weight: hard

• 2024+ · City / neighbor process

  Legally permitted ADU project opposed through city channels; document exact objection dates.

  City building/planning records · Weight: hard

Export draft

Plaintiff’s family residence and ADU project site at 1816 S McClelland St, Salt Lake City, UT, is immediately adjacent to David N. Wolf, Division Director of Constitutional Defense & Special Litigation in the Utah Attorney General’s Office. Mr. Wolf’s spouse holds a senior role in the DHHS / Child Protection Services orbit. Plaintiff’s ADU permit process was opposed through city channels. These are public titles and geographic facts. They establish a structural conflict of interest when AG-office review and CPS process touch Plaintiff’s family case.

Fact spine

• 2025-03 · CPS (Boyd Madsen context)

  Call recording: AG Office reviewed and directed continuation of “non-severe neglect” findings despite earlier plan to drop findings for lack of evidence.

  Audio recording + transcript · Weight: hard

• various · CPS

  Documented child injuries (dog-bite stitches; cheek-pinch black eye; bruises); CPS actions dropped within short windows — keep exact close dates.

  CPS notices + medical/photo exhibits · Weight: hard

Export draft

Plaintiff preserved a recorded conversation with CPS in which the worker acknowledged Attorney General’s Office review and direction regarding findings of “non-severe neglect,” including continuation of findings the worker had previously indicated lacked evidence. Separately, documented child injuries (including facial lacerations requiring stitches and a black eye from a pinch) were the subject of CPS activity that closed on an accelerated timeline. Plaintiff seeks the Court’s attention to the process integrity of those investigations given the documented adjacency of AG and DHHS personnel to Plaintiff’s residence.

Fact spine

• 2026-03-17 · Court (Judge Heather Brereton context)

  Entered fee / support judgments totaling ~$36,712 (attorney fees ~$28,027.50 + child support/GAL ~$8,684.50 + interest).

  Judgment order · Weight: hard

• 2026-05-15 · Plaintiff

  Motion to Set Aside under URCP 60(b) citing excusable neglect and residual grounds: PTSD, heart issues, executive dysfunction, unaddressed ADA, courtroom breakdown.

  Filed motion · Weight: hard

• 2026-06-03 · Plaintiff

  Emergency packet: Rule 60(b)(3), temporary custody/parent-time, TRO blocking sale/encumbrance of 1816, TRO preventing removal of children from Utah, Motion to Remove GAL.

  Court filing · Weight: hard

Export draft

On or about March 17, 2026, the Court entered judgments totaling approximately $36,712 against Plaintiff (including substantial GAL and opposing-attorney fee components). At relevant times Plaintiff was indigent, uninsured, and the children’s primary caretaker pre-separation, while the opposing party earned significantly more. Plaintiff’s ability to defend was impaired by unaccommodated disabilities (see ADA claim). Plaintiff has sought relief under URCP 60(b) and continues to request fee reallocation consistent with ability to pay and primary-caretaker history.

Fact spine

• various · Children / medical

  Injuries documented: dog bite requiring stitches; cheek pinch causing black eye; multiple bruises. Photos and medical records.

  Photos / medical · Weight: hard

• 2025-01-02 · Plaintiff

  Police-escorted belongings retrieval after locks changed; brief contact with grandmother about kids’ iPads from car; arrested. Temporary-order violation theory used to sustain PO.

  Police reports / call logs / PO hearing notes · Weight: hard

• ongoing · Plaintiff

  Seeks vacate/dismiss of protective order: changed circumstances; harm to children’s relationship with father; child-focused language only.

  Utah Respondent’s Request to Vacate / Dismiss forms · Weight: testimony

Export draft

Plaintiff seeks modification or vacatur of the protective order based on changed circumstances and the best interests of the children. The order’s practical effect has been to severely restrict a previously primary-caretaker parent’s relationship with his children. Plaintiff attaches contemporaneous police reports, call logs, and text evidence of co-parenting history, and documented child-safety concerns raised in good faith. Plaintiff does not seek to relitigate unproven character attacks; Plaintiff asks the Court to restore a parent-child relationship consistent with Utah law and the children’s needs.

Fact spine

• ongoing · Joe Guice (public profile)

  Identifies as YogaSix studio owner in the Salt Lake City area; Facebook personal details list married to Kathleen Myhre since April 5, 2026; friends with Kathleen Myhre.

  Public Facebook profile text · Weight: hard (public self-statement)

• ongoing · Kathleen Myhre (public listings)

  Listed as Criminal Analyst / Criminal Information Specialist, SECURE, Investigations Division, Utah Attorney General’s Office; South Jordan/SLC orbit; public USAF service materials and uniform photo with MYHRE name tape (kathi.myhre posts).

  LinkedIn / ZoomInfo / Utah AG salary listings + public Instagram · Weight: hard (public titles)

• 2024-08+ · Petitioner / YogaSix timeline

  Archive notes Petitioner employment/social orbit at Yoga Six Sugar House — still requires paystub, schedule, work email, or staff listing as hard exhibit.

  User timeline + pending employment docs · Weight: partial until docs attached

Export draft

Public records and social profiles show that Joe Guice identifies as a YogaSix studio owner in the Salt Lake City area and is married to Kathleen Myhre. Public professional listings identify Kathleen Myhre as a Criminal Analyst / Criminal Information Specialist in the SECURE / Investigations Division of the Utah Attorney General’s Office, with prior United States Air Force service reflected in public materials. If Petitioner’s employment at YogaSix is documented by employment records, workplace orbit sits adjacent to public AG-office personnel. These are public titles and social-graph facts offered for process-integrity context, not as proof of case orchestration.