IN THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT IN AND FOR ESCAMBIA COUNTY, FLORIDA RE: THE MARRIAGE

OF: JACKIE R. CAMERON Petitioner/Husband, CASE NO: 2012-DR-1993 and CHRISTINE S. CAMERON Respondent/Wife. ________________________________ RESPONDENTS RESPONSE TO PETITIONERS MOTION TO COMPEL COUNSELING RECORDS OF PATRICK M. MCCAGHREN COMES NOW, Respondent, by and through Christine Sue Cook, LLC, and files this Response to Petitioners Motion to Compel Counseling Records of Patrick McCaghren, LCSW, and in support thereof states: 1. 2. 3. This is an action for dissolution of marriage filed on May 23, 2012. There is one (1) Minor Child born in this marriage, to wit: SWC DOB 11/12/11. There are allegations of domestic violence, against Respondent AND Minor Child

by Petitioner, as well as allegations of illegal drug (cocaine and illegally-obtained Lortab) addiction and abuse by Petitioner. 4. Respondent did not abscond to Broward County, Florida, rather she left for an

extended vacation from the daily verbal and emotional abuse suffered from Petitioner and from the physical abuse she and Minor Child suffered on February 22, 2012, and April 13, 2012. Petitioner filed this instant action in retaliation and as a form and evidence of his continued abuse while Respondent was visiting her mother in South Florida. 5. Respondent treated with Patrick M. McCaghren to address the issues of

Petitioners physical, emotional and verbal abuse, among other things. 6. Petitioner also treated with Patrick M. McCaghren because of this abuse and in

an attempt to save his relationship with Respondent and later his marriage to her. 7. Petitioner was a patient/client of Mr. McCaghren, and his presence and

attendance in any meeting with Respondent was in that capacity. Respondent did not waive any privilege that exists with Mr. McCaghren. 8. Petitioner is NOT a licensed mental health practitioner, has no experience or

training in psychology and has no entitlement to Respondents records. 9. This issue was before the Court on October 31, 2012, and the Court ordered that

if Dr. Shannon Wright-Johnson, the licensed mental health professional appointed by the Court on October 31, 2012, required the treatment records of the parties, she would request the same. 10. Respondent has already offered the records to Dr. Wright-Johnson, who, at the

time indicated that she did not require them. 11. Respondent has contacted Mr. McCaghren to determine the correct paperwork

required to obtain said records and was told that Petitioner would, in fact, also be required to sign a release for the treatment records, should Mr. McCaghren be required to tender records to anyone. WHEREFORE, Respondent respectfully prays this Court deny Petitioners Motion to Compel Counseling Records for Petitioners own edification and, instead reinstate the Courts order of October 31, 2012, mandating Dr. Shannon Wright-Johnson to receive Mr. McCaghrens records, should she desire.

I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished to Jackie R. Cameron, Petitioner, via email at jrod@jrodcameron.com and liz@jrodcameron.com on this 2 day of January 2013. /s/ Ch r i sti n e S. Cook CHRISTINE S. COOK, ESQ. CHRISTINE SUE COOK, LLC FLA Bar No: 0528439 890 South Palafox Street - Suite 109 Pensacola, FL 32502 (850) 572-7159 / (877) 249-6279 fax christine@christinescook.com Attorney for Respondent
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