Walsh DV-120 Response: "Reasons I Do Not Agree" to DVRO

Tara Walsh's Sworn Response to Russell's Domestic Violence Restraining Order Petition

Filed: July 10, 2018 (Signed August 7, 2018)

Court: Superior Court of California, County of San Francisco

Case Number: FPT-18-377425 (Russell v. Walsh)

Document Type: Form DV-120 Response (Reasons I Do Not Agree with Request for Domestic Violence Restraining Order)

Declarant: Tara Walsh (Respondent)

Evidentiary Confidence Score (ECS): 90 (Walsh's own sworn admission of criminal drugging)

Relates to Blog Post: 17 (Seroquel Drugging Admissions)

Source Document: Walsh - DV-120 Response.pdf

I. DECLARANT STATEMENT

"I, TARA WALSH, am the Respondent in this action. All of the information contained herein is true to the best of my knowledge, and I would offer the same if called to testify."

II. WALSH'S NARRATIVE OF THE RELATIONSHIP

Walsh provides her counter-narrative, alleging abuse by Russell including verbal abuse, control, isolation, threats, intimidation, property destruction, privacy violations, stalking, and creating "reasonable apprehension of fear on a daily basis."

Walsh characterizes Russell as suffering from:

III. THE CRITICAL ADMISSION — SEROQUEL DRUGGING (¶¶ 9-11)

First Incident (May 2018 — Early Afternoon):

"In May 2018, I witnessed Petitioner have what can only be best described as psychotic, drug induced episodes. During these episodes, Petitioner took high dosages of Adderall and did not sleep for over 24 hours. He was up all night at the apartment where I and Evie were staying with him and was tearing the place apart to search for spying devices."

"The first incident occurred in the early afternoon after Petitioner had not slept all night from binging on Adderall. Petitioner was clearly out of touch with reality and believed he had been poisoned from gas coming out of the vent in the shower (which he disassembled). He had also broken the hinge on the window of the apartment (on the 55th floor) in an attempt to view the apartment below, as he believed 'agents' were located there. Petitioner created a dangerous, disturbing situation for Evie and I. I put 100mg of Seroquel in Petitioner's red wine, which is a similar dose he would often take to help him sleep. Seroquel at this dosage has no therapeutic affect and purely used as a sleeping pill."

Second Incident (May 2018 — Early Afternoon):

"The second incident also occurred early in the afternoon after the Petitioner, again, was up all night ingesting Adderall. Petitioner had broken the large coffee table in the living room and put two large holes in the living room wall. Petitioner again believed poisonous gas was leaking from the wall to intentionally poison him. I tried reasoning with Petitioner to get him to calm down, but it was nearly impossible. The nanny, Abrehat Tedla ('Nanny'), and security guard, Bryan Crutcher, watched me as I put Seroquel in Petitioner's wine. The Nanny helped crush the pill into a fine powder and mix it with another cup to dilute the powder into the wine. Thereafter, Bryan Crutcher poured himself a glass of wine. I asked him why he was drinking so early to which he replied: 'I am drinking so he sees me drinking and drinks his faster (referring to wine with Seroquel).' At that time, me, the Nanny and security were desperate to calm Petitioner down, as he was a danger to himself and everyone else."

IV. THE SECOND CONFESSION — TO THERAPIST (¶ 12)

"As Petitioner points out, I willingly told Petitioner's psychiatrist, Dr. Gopal, that I had put Seroquel in Petitioner's wine, because I did not know what else to do: 'sometimes when he is out of his mind on drugs and won't sleep I have put Seroquel in his wine.'"

Critical Context: This statement to Dr. Gopal is particularly damaging because it demonstrates Walsh's admission extended beyond the May 2018 incidents. The phrase "sometimes...I have put Seroquel in his wine" indicates a pattern of repeated drugging, not isolated incidents.

V. WALSH'S ATTEMPTED JUSTIFICATIONS

Claimed Authorization (¶ 13):

"I regularly take prescribed Seroquel to help me fall asleep at night. Petitioner has told me on several occasions that he has taken my Seroquel, in the same dosages, to also help him sleep at night. Moreover, I told Petitioner after I put the Seroquel in his wine that I did it to help him calm down from his psychotic episode. Petitioner understood why I did this and told me it was 'ok.'"

Problems with This Defense:

VI. CORROBORATING EYEWITNESS EVIDENCE

Walsh's own response document establishes multiple eyewitnesses to the drugging:

VII. SIGNIFICANCE OF THIS DOCUMENT

The DV-120 Response is extraordinary evidence because:

VIII. COMPARATIVE ANALYSIS WITH NANNY & SECURITY DECLARATIONS

Walsh's admissions in this DV-120 Response are consistent with (and corroborated by) the separate declarations filed by:

IX. POST-INCIDENT CONDUCT

Walsh's response indicates she departed California on June 9, 2018 and remained in New York, refusing to return Evie to California. This flight from the jurisdiction after committing the druggging incidents demonstrates consciousness of guilt.

X. LEGAL ADMISSIBILITY & WEIGHT

As a party's own sworn statement filed with the court, Walsh's DV-120 Response constitutes:

Document Status: This is Walsh's official response to the DVRO petition, filed under penalty of perjury. The admissions herein represent her best legal strategy when facing a domestic violence restraining order — yet she still chose to admit the Seroquel drugging rather than deny it. This speaks to the strength of the eyewitness evidence that made denial implausible.