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EXHIBIT B

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In the Court of Common Pleas, Juvenile Division, Lake County, Ohio
Complaint of Contempt of Visitation Order
Case Number 97 CV 0314
Judge William W. Weaver
Plaintiff: John Doe, Mentor, Ohio
Defendant: Loretta D. Smith, Avon Lake, Ohio

1. I, John Doe, am the natural and legal father of Little Doe who was born on xx/xx/xx.

2. Paternity of my child was established by administrative order pursuant to R.C. Sections 3111.20 to 3111.29, as provided by R.C. Section 3111.02. A copy of my paternity order is contained in the case file.

3. The defendant, Loretta D. Smith, is the mother and custodial parent of my child, Little Doe.

4. On December 10, 1997, a visitation order was entered into judgment where at the end of paragraph #3, clearly states, "and such other times as the parties agree upon."

5. In May of 1998, after notifying Loretta in writing when I would take Little Doe for my 6 week visitation, Loretta drafted an amended visitation schedule to replace the 6 week summer visits, upon which I agreed to. (A copy of which is attached to this complaint.)

6. Loretta Smith has continually been hostile to any visitation order as indicated in her absence at the visitation hearing. The Avon Lake Police have also had to escort me to the child’s residence in order for Loretta to comply with the visitation order. On a second occasion, Mentor Police had to come to my residence to quell an attempt by Loretta to interfere with the visitation agreement.

7. Part of the amended schedule was her agreement to pick Little Doe up on the Tuesday evenings following Little Doe’s visits with me. The original visitation schedule did not address this matter and we agreed it would be fair and equitable to split the driving in light of the fact it was Loretta’s decision to move so far away after Little Doe’s birth and our break up.

8. On Friday, November 27, 1998, when I arrived in Avon Lake to pick up Little Doe, Ms. Smith informed me she was not going to pick Little Doe up regardless of her written agreement and that it’s her prerogative to annul the amended visitation schedule without my consent. Even going as far as saying that I may keep Little Doe indefinitely and she’ll just continue to collect the child support.

9. Loretta, having given my unlisted number to both her child care worker and a man who only identified himself as "Loretta’s friend", had them call to harass me on 11/29/98 respectively. Loretta also continually calls or fax’s my place of employment to harass me.

10. I am requesting penalties be assessed against Loretta Smith, pursuant to R.C. Section 2705.031 and R.C. Section 2705.05, as she’s continually proven to be hostile towards the visitation agreement.

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ATTACHMENT

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Revised Visitation Terms:

1. Visits overnight no longer than four nights until four years of age. (Within two week increments.)

2. Increase weekend schedule to include one or two days (with notice) beginning May 15, 1998 and continuing indefinitely until Little Doe is four, or occasional arrangements for slightly longer visits. At age of four increase increments up to one week. (No longer than one week in any three week period. School age, conform to school calendar.)

3. Father to pick up child Friday evenings in Avon Lake (or wherever she lives) at 6:00 PM as scheduled. Mother will pick up child Monday or Tuesday evening (depending on length of stay) at 5:15 PM in Willowick. If child returns Sunday evening, father is responsible for bringing her home. If child cannot be in Willowick, father is responsible for returning child by 7:00 PM of given evening.

4. Father will provide childcare information to mother including names, addresses and phone numbers of any caregivers. Father will provide name, address, and phone number of local pediatrician for mother’s interview.

To reiterate:
Effectively, I am doubling your overall visitation from four to eight nights per month. They must align with your existing visitation as alternate weekends. You may keep Little Doe up to four nights. I will pick her up two times a month at your moms. I will not pick her up on Sundays. If you cannot get her back to Willoughby by 5:15 PM, you can bring her home by 7:00 PM.

You now have less childcare to worry about when you are working or at school. I want names and addresses etc. of your hired or volunteer baby-sitters. If Jane wants to be your permanent baby-sitting slave, God bless her. If she has to leave the child with someone (other than an hour meeting), I want to know WHO and WHERE.

These are reasonable terms. I can assure you a judge would agree. Let me know your acceptance or rejection of this in writing by 5/4 or I will hire an attorney.
Thank you,
Loretta

Report continued on page 4