Matthew Hilton (#3655)
LAW OFFICES OF MATTHEW HILTON
2332 Field Stone Way
Layton, UT 84041
Telephone: (801) 529-5360
E-mail: matthilton3@gmail.com
Limited Appearance on Behalf of Petitioner
Brittany Wolferts 10 file petition and accompanying motions
IN THE FOURTH DISTRICT JUVENILE COURT
UTAH COUNTY, STATE OF UTAH
PROVO DEPARTMENT
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Inte: : DECLARATION OF
DR. RANDY HYDE
WOLFERTS, SYDNEY (DOB 5-24-1999) Civil No. 1102018
WOLFERTS, DANIELLE (DOB 10-29-2000): Civil No. 1102019
Judge Brent Bartholomew
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COMES NOW Matthew Hilton, counsel of limited appearance for Petitioner Brittany
Wolferts, (“Petitioner”) and files this Declaration of Dr. Randy Hyde in support of the ex parte
motion seeking emergency orders, appointment of Guardian ad Litem counsel, and expedited
hearings, all for the purpose of providing immediate protection for the identified children that arethe subject of a verified petition filed before this court:
1. Tam 59 years of age, of competent mind and body, and have been a licensed
Psychologist in the State of Utah for 30 years.
Previously, I have provided marital and family counseling with members of the
family of Brian Edgar Wolferts (“Mr. Wolferts,”) and 8. Michelle Wolferts (Ms. Wolferts”)
3. I provided counseling to Brittany Wolferts as part of the events that surrounded
the DCFS supported findings against Mr. Wolferts of domestic abuse in the presence of a child. I
‘was paid for these services by the State of Utah through Crime Victims Reparations.
At the request of Brittany Wolferts, I have reviewed the Petition she filed as a
pleading in the Fourth District Juvenile Court regarding Sydney Wolferts (“S.W.”) and Danielle
Wolferts (“D.W.”).
5. At the request of Brittany Wolferts, I have met with and interviewed both S.W.
and D.W.
Based on my interviews with $.W. and D.W., and their statements to me, I do not
question the veracity of the petition’s representation of statements attributed to them, or the
factual and contextual situations described regarding Mr. Wolferts.
7. Based on the statements made to me by S.W. and D.W,, it is my professional
opinion that they illustrate patterns of conduct by Mr. Wolferts that are widely accepted in
professional literature, as evidence of the following therapeutic needs of Mr. Wolferts: that inorder to have an ongoing and healthy relationship with his children, therapeutic assessment,
assistance and intervention is needed.
8. Based on the statements made to me by S.W. and D.W,, it is my professional
opinion that they emphasize the importance that aforementioned therapeutic needs of Mr.
Wolferts be identified, addressed and resolved before he be allowed to resume contact with $.W.
and D.W., much less be a custodial parent able to exercise all aspects of legal custody as defined
in the Juvenile Court Act, Utah Code § 78A-6-105(22)..
9, Based on the statements made to me by S.W. and D.W.
is my professional
nn that S.W. and D.W. are em¢
opi mally and intellectually competent to meet with the judge
in this case and discuss their wishes regarding separation from their father, Mr. Wolferts.
10. Based on the statements made to me by S.W. and D.W.
is my professional
opinion that S.W. and D.W. would be severely emotionally harmed if they were restored to the
physical custody of their father, Mr. Wolferts, or he was awarded legal custody of these two of
his three daughters, by this court.
11. Based on the statements made to me by S.W. and D.W,, it is my professional
opinion that 8.W. and D.W. would be severely emotionally harmed if they were required to leave
the custody of their natural mother, Ms. Wolferts at this time.
12, Based on the statements made to me by S.W. and D.W., without any equivocation,
it is my professional opinion that regardless of the statutory or equitable criteria used to