Exhibit #16 — Mending Matters Treatment Summary (4/13/2026)
Author: Edgard Watson, LCSW #108586 (Clinical Supervisor), Mending Matters, 1382 Blue Oaks Blvd, Suite 213, Roseville CA 95678 Treating clinician: Jasmine De La Torre Subject: Ellanore Nibley (DOB 07/31/2013) Addressed to: Charles Nibley (per request dated 04/01/2026)
Summary of contents
- 1/22/2026 — Clinician introduced self and Mending Matters services to Ella and her mother at Black Mountain Middle School, including walk-in support as needed.
- 2/3/2026 and 2/4/2026 — Walk-in sessions for emotional regulation; anxiety-related.
- 3/24/2026 — Referral for suicidal ideation. C-SSRS assessment rated Ella high-risk. Ella reported increasing SI tied to “lack of control around custody arrangements,” academic pressure, and a recent peer conflict, with a plan and intent.
- Safety plan completed. School administration coordinated a secondary evaluation by the Mobile Crisis and Response Team (MCRT). MCRT transported Ella to an inpatient program at Aurora Behavioral Healthcare San Diego Hospital.
- Parents notified of risk factors and recommendation of higher level of care; clinician committed to ongoing family collaboration.
Legal significance
- FC §3011(a)(1) — health, safety, and welfare of the child is the primary custody consideration. Direct evidence on the primary factor.
- FC §3020(a) — public policy favors ensuring children have frequent and continuing contact with both parents consistent with health, safety, and welfare. Ella’s own attribution of SI to “lack of control around custody arrangements” is probative of how the current withholding dynamic affects her.
- FC §3027.5 / FC §3011(a)(5) — risk-of-harm framing supports restoration of parenting time; the inpatient hospitalization occurring during the period Ella was being withheld from Charley’s custody is temporal context worth preserving.
- FC §3025(b) — joint legal custodian’s right of access to health records; supports Charley’s standing as named recipient.
- FC §6924 — Ella is 12; if she consented to treatment on her own, she holds the confidentiality. Triggers minor’s-counsel coordination before broader disclosure.
- Evid. Code §1014 — psychotherapist-patient privilege applies.
- Evid. Code §1016 — patient-litigant exception (mental condition placed in issue).
- Evid. Code §1024 — dangerous-patient exception (high-risk C-SSRS, plan/intent, MCRT transport, inpatient hold).
- W&I §5328 — LPS confidentiality governs any Aurora records and should be handled in the same sealing posture.
Handling rules (per standing redaction rule)
- Unredacted version: court + opposing party only.
- Redacted version: public file (minor’s name → initials; address removed; diagnostic/clinical specifics minimized).
- Lodge conditionally under seal per CRC 2.550/2.551 on first filing; file motion to seal with declaration citing §§1014, 1024, 5328 and FC §3011.
- Do not share broadly without minor’s counsel coordination — §6924 contingency. The “guardian consent” language in the provider’s disclaimer is a practical reason to route sensitive use through minor’s counsel once engaged.
Possible uses
- 5/1 FCS mediation — high-value context. Rebuts any suggestion that Charley’s custody position is about parent preference rather than child welfare; Ella’s own attribution ties the clinical picture to the custody dispute.
- 6/1 RFO hearing — potential exhibit in support of restoration / status quo enforcement under FC §3011.
- Minor’s counsel introductory packet — core document.
- Reserve argument (FC §3027.1 sanctions) — if CFWB investigation closes without substantiation and further hearings occur, the clinical record of harm during the withholding period is relevant.
Open items
- Confirm under which consent regime Ella entered treatment (parental consent vs. FC §6924 minor consent).
- Confirm relationship between Mending Matters services and the MCRT referral / Aurora admission for records-request sequencing.
- Flag for minor’s counsel once identified; include in introductory packet.
- Prepare redacted version before any public filing.
Cross-references
- [[EX#|# — Aurora Behavioral Health records]] (pending; records request submitted, 90-day standard / expedited on court-date disclosure)
- Ellanore Nibley (Daughter)
- 2026-05-01 FCS Mediation
- 2026-06-01 RFO Hearing