⚠️ PC Escalation Protocol

When Issues Arise:

FIRST: Parents attempt to communicate directly via OFW in good faith
IF direct communication fails or talking doesn't work: Issue MUST be raised to the Parent Coordinator
PROHIBITED: Withholding cooperation, retaliating, or taking unilateral action when communication breaks down

PC Retainer Agreement, Section A (PC Scope):

"The primary role of the PC is to assist the two of you to negotiate and/or implement parenting decisions in a way that minimizes conflict and is in your daughter's, Isabella Samir Moukdad (DOB: 09/10/2020), best interests, including with respect to major decisions relating to the child(ren), parental access schedules, holidays, and school breaks, and such other and further issues as deemed appropriate by the PC, consistent with her experience as a PC."

Executed: July 25, 2025

Settlement Article XI, §G, p.17 (PC Escalation to Court):

"If the parents still do not have an agreement after meeting with a Parenting Coordinator and making a good faith effort to reach a mutual resolution, either party shall have the right to make an appropriate application to a court of competent jurisdiction."

So-ordered: October 31, 2022 (Judge Prus, Supreme Court)

The PC is the REQUIRED escalation path — not retaliation, not withholding cooperation, not unilateral decisions. The PC's scope includes "such other and further issues as deemed appropriate" beyond major decisions, and escalation to court is only permitted after good faith PC engagement.

Proposed Solutions Dashboard

This dashboard consolidates proposed PC directives addressing seven documented patterns. Each directive is designed to promote settlement compliance and reduce conflict.

Purpose: These are suggested PC directives based on verified SETTLEMENT VIOLATIONs (Nov 24-26, 2025) and historical patterns (2022-2025). All evidence is sourced from case records and settlement provisions.

Seven Solution Areas:

Admitted Retaliation — "I will reciprocate what is given to me"
No Good Faith Communication — Reactive compliance, not proactive cooperation
Aggressive/Dismissive Attitude — Settlement/PC process called "nonsense"
PC Process Demonization — Refusal/delay/dismissal of PC role
Projection Pattern — Accuses Mr. Moukdad of violations she commits
Settlement Compliance Hypocrisy — Double standards (pickup, medical, TOP, communication)
FaceTime Mutual Flexibility — One-sided time changes, child-readiness standards, quality/safety (1,300+ documented entries 2021-2025)

Solution 1: Unconditional Good Faith Cooperation

Addresses Pattern: Admitted Retaliation

PC Directive: Cooperation is UNCONDITIONAL

Issue: Ms. Attar admitted to tit-for-tat cooperation: "I will reciprocate what is given to me" (Nov 25) and "I give the same courtesy I receive" (Nov 24).

Settlement Requirement: Article XI, Section F, p.17 requires "advise and consult with each other in good faith" — cooperation is unconditional, not conditional on reciprocation.

✅ PC DIRECTIVE:

Both parties are reminded that cooperation is unconditional per Settlement Article XI, Section F, p.17. Cooperation is NOT conditional on the other parent's perceived behavior or "reciprocation."

Required Standards:

Medical information provided "forthwith" (Art. V, p.10) regardless of other parent's recent behavior
FaceTime facilitated per settlement schedule (Art. XI, §T, p.29) regardless of recent disagreements
Exchange times honored (Art. XI, §J, p.19) regardless of perceived violations by other parent
SETTLEMENT VIOLATIONs addressed through PC process (Art. XI, §G, p.17), NOT through withholding cooperation

Any parent who withholds cooperation as "retaliation," "reciprocation," or based on "courtesy received" will be in violation of this directive and the settlement's good faith requirement.

Implementation: Effective immediately. Both parties acknowledge understanding at next PC session.

Solution 2: Proactive Medical Information Sharing

Addresses Pattern: No Good Faith Communication

PC Directive: Complete Medical Information Proactively

Issue: Ms. Attar forces information extraction instead of providing complete medical details proactively (Nov 25 — Mr. Moukdad had to ask for temperature readings, dosages, symptoms 17 minutes after initial incomplete update).

Settlement Requirement: Article XI, §V, p.30 requires "forthwith inform each other of any illness" — this means COMPLETE information provided PROACTIVELY, not reactive compliance after requests.

✅ PC DIRECTIVE:

When either parent notifies the other of Isabella's illness, notification MUST include complete medical information proactively.

Required Information (when applicable):

Temperature readings (actual numbers, not just "fever")
Medication administered (name, dosage, time given)
Symptoms observed (specific descriptions)
Treatment plan (home care, doctor visit, urgent care, etc.)
Any medical appointments scheduled (time, location, provider)

Example Compliant Communication: "Isabella woke with fever. Temperature 101.5°F at 7:00 AM. Gave Tylenol 10ml at 7:15 AM. She's resting, energy level normal. Will monitor and update in 4 hours or sooner if fever spikes."

Non-Compliant Communication: "She has a fever. I gave her medicine. She's fine." (Requires other parent to extract details)

Implementation: Effective immediately. Any incomplete illness notifications requiring information extraction should be flagged.

Solution 3: Professional, Respectful Communication Standard

Addresses Pattern: Aggressive/Dismissive Attitude

PC Directive: No Dismissive Language Toward Settlement/PC Process

Issue: Ms. Attar dismissed settlement compliance and PC process as "nonsense" (Nov 26) and used hostile language ("That is simply not true" 4x, therapy suggestions, conversation shutdowns).

Settlement Requirement: Article XI, Section F, p.17 requires professional, good faith communication.

Prohibited Communication Patterns:

Dismissing settlement provisions as "nonsense" or similar derogatory terms
Gaslighting: Blanket denial of verifiable facts ("That is simply not true")
Conversation shutdown: Refusing to engage on legitimate parenting concerns
Ad hominem attacks: Suggesting other parent needs therapy instead of addressing substance
Hostile rejection: "Stop calling" during medical emergencies or time-sensitive matters

Required Response Standard:

When settlement provisions cited, respond to substance (not dismissal)
When concerns raised, engage in good faith problem-solving
When facts are verifiable, acknowledge them
Address concerns through PC process (Art. XI, §G, p.17), not hostile rejection

Implementation: Effective immediately. Dismissive language toward settlement/PC process should be flagged.

Solution 4: Mandatory PC Engagement with Accountability

Addresses Pattern: PC Process Demonization

PC Directive: PC Engagement is REQUIRED, Not Optional

Issue: Pattern of PC refusal (Sept 17, 2024: stated she would not use PC during argument), retainer delay (March-May 2024: 2+ months), false "no issues" claims (Nov 24: contradicted by 117 OFW messages), dismissal as "nonsense" (Nov 26).

Settlement Requirement: Article XI, Section G, p.18 MANDATES PC engagement for disputes. Judge Prus ordered PC enforcement July 22, 2025.

PC Scope (Per Retainer Section A): "ANY OTHER PARENTING-RELATED ISSUES"

Includes day-to-day coordination (FaceTime, illness management, school communication)
NOT limited to "major decisions"
Either parent may raise ANY parenting concern through PC process

Prohibited Behaviors:

Refusing PC engagement
Delaying retainer/session scheduling
False "no issues" claims when disputes are documented
Dismissing PC process as "nonsense"
Punishing other parent for using settlement-mandated process
Unilateral scope limitation to "major decisions" only

Joint Session Scheduling: When either parent requests joint session and session is paid for, session MUST be scheduled within 14 days unless both parties agree to different timeline.

Implementation: Effective immediately. PC tracks: (1) Session attendance, (2) Retainer compliance, (3) Good faith engagement.

Solution 5: Data-Based Accountability Standard

Addresses Pattern: Projection Pattern

PC Directive: Claims Must Be Evidence-Based

Issue: Ms. Attar accuses Mr. Moukdad of violations she commits (medical info withholding, FaceTime denial, excessive emails). Data disproves claims: 8.9:1 email ratio shows Mr. Moukdad initiates 8.9x MORE communication than Ms. Attar.

Verifiable Evidence REQUIRED:

Message timestamps (proves delay/non-response)
Call logs (proves FaceTime denial/rejection)
OFW message counts (proves communication volume)
Settlement citations (proves violation of specific provision)
Medical records (proves unilateral decisions)

Prohibited Behaviors:

Projection: Accusing other parent of behavior you exhibit
False equivalency: Claiming "both parents do this" when evidence shows otherwise
Deflection: Shifting blame instead of addressing own violations
Unsupported accusations: Claiming violations without timestamps/evidence

When Projection Identified: PC will require accusing parent to provide verifiable evidence. If evidence contradicts accusation (projection), accusing parent must acknowledge error.

Implementation: Both parties acknowledge 8.9:1 email ratio (FACT-062) disproves "excessive email volume" claims. Future complaints must be data-supported.

Solution 6: Mutual Compliance Standard

Addresses Pattern: Settlement Compliance Hypocrisy

PC Directive: Standards Apply Equally to Both Parents

Issue: Ms. Attar demands strict compliance from Mr. Moukdad while violating same provisions. Example: Nov 26 — delayed pickup 20 minutes, then complained about Mr. Moukdad's "10 min" delays SAME DAY.

Settlement Applies Equally: Neither parent may demand compliance while exempting themselves.

Examples of Prohibited Double Standards:

Pickup times: If parent complains about delays, they must comply with same standard
Medical info: If parent demands "forthwith inform," they must provide proactive info
FaceTime: If parent complains about FaceTime denial, they must facilitate other parent's FaceTime
Good faith: If parent demands good faith communication, they must communicate in good faith

When Hypocrisy Identified: PC will point out double standard with specific examples. Complaining parent must acknowledge they commit same violation. Both held to same standard going forward.

Retaliatory Threats PROHIBITED: Using parenting time as leverage ("you will get her back even later") violates settlement.

Implementation: Both parties acknowledge settlement standards apply equally. Future complaints must demonstrate own compliance with same standard.

Solution 7: FaceTime Mutual Flexibility Protocol

Addresses Pattern: Settlement Compliance Hypocrisy (FaceTime double standards)

PC Directive: Mutual Flexibility for FaceTime Scheduling

Issue: Current one-sided flexibility undermines FaceTime effectiveness and creates inconsistency. Ms. Attar unilaterally changes FaceTime times (Nov 11: "she's playing now so in an hour"; Nov 9: play date until 7:15 PM on school night), while citing settlement 5:30 PM time when Mr. Moukdad requests flexibility. This creates confusion for Isabella and leads to poor-quality FaceTimes.

Settlement Requirement: Article XI, Section T, p.29 establishes daily 5:30 PM FaceTime. Article XI, Section F, p.17 requires good faith cooperation — which includes MUTUAL flexibility when child's readiness or circumstances require adjustment.

Pattern Documented:

Rima's unilateral changes (no mutual agreement): Nov 11 (1hr delay for "playing"), Nov 9 (114-min delay for play date), April 29, 2023 (Chuck E. Cheese during FaceTime time, no advance notice)
Sam's child-centered requests rejected: May 21, 2024 (Isabella doesn't want to talk, Sam requests later time — Rima brings up ONE time Sam couldn't do later, ignores multiple documented instances he accommodated)
Impact on Isabella: Nov 9, 2025 — Late play date (7:15+ PM on school night) → exhausted Isabella → hostile FaceTime ("I don't have the feelings to talk," "You're not my dad anymore" — most extreme on record) → missed school Monday (too tired)

Directive: Mutual Agreement Protocol

Either parent may request FaceTime time change via OFW. Other parent accommodates when reasonable (child engaged in activity, tired, needs transition time). Agreement logged on OFW. Both parents held to same standard.

Directive: Child-Readiness Grace Period

Isabella is 5 years old. It is developmentally normal for a child to need 5-10 minutes to transition from an activity to FaceTime. This grace period is acceptable and not a violation. Goal: Isabella should enjoy FaceTime, not resent it.

Directive: Quality and Safety Standards

Phone mounted in car: Safety concern — distracted driving when holding phone. Both parents use phone mount if FaceTime occurs during car ride.
Minimum meaningful duration: FaceTime rushed off at 7-8 minutes ("so?" when duration noted — May 27, 2023) is not good faith facilitation. Minimum 15-20 minutes unless child genuinely uninterested.
Engagement effort: Parent in physical custody makes reasonable effort to engage child (follow with phone, create positive environment, redirect when child distracted). Quality over compliance.

Child-Centered vs. Parent-Centered Standard

Flexibility serves Isabella's enjoyment and readiness, not parent convenience. When Isabella cranky/tired (documented pattern: all FaceTimes Rima initiates with cranky Isabella — April 23, 2024), better to adjust time so call is positive. Forcing FaceTime when child exhausted creates resentment ("I don't want to talk to baba" pattern — May 28, 2023 documented).

Prohibited: Weaponizing Normal Child Behavior

When Ms. Attar delays, "Isabella playing/coloring" is valid excuse. When Mr. Moukdad accommodates Isabella's readiness, passive-aggressive comments during call ("Can you talk to me like I tell you to talk baba when you don't want to talk" — March 21, 2024) are PROHIBITED. Same standard for both parents.

Implementation: Both parents acknowledge mutual flexibility protocol. Future time change requests logged on OFW with response. PC monitors for one-sided enforcement. Child's FaceTime experience prioritized over rigid schedule adherence.

Summary: Seven-Point Action Plan

Immediate Implementation (All Parents):

Unconditional Cooperation: No more "I reciprocate what is given" — cooperation is UNCONDITIONAL per Art. XI, §F, p.17
Proactive Medical Info: Complete details (temp, dosage, symptoms, plan) provided immediately, not after requests
Professional Communication: No dismissive language toward settlement/PC process ("nonsense," gaslighting, therapy suggestions)
Mandatory PC Engagement: PC scope includes day-to-day issues, not just "major decisions" — engagement REQUIRED, not optional
Evidence-Based Claims: Accusations must be supported by timestamps/data, not projection or false equivalency
Mutual Standards: Both parents held to same compliance requirements — no double standards, no retaliatory threats
FaceTime Mutual Flexibility: Either parent can request time change; other accommodates when reasonable. 5-10 min child-readiness grace period. Phone mounted in car. Quality over rigid compliance.

Evidence Base for Solutions

All solutions are based on:

Verified SETTLEMENT VIOLATIONs (Nov 24-26, 2025 documented in case records)
Historical patterns (2022-2025 pickup delays, PC refusal Sept 2024, retainer delay March-May 2024, 1,300+ FaceTime entries 2021-2025)
Settlement provisions (Articles III, V, XI with specific page citations)
Quantifiable data (8.9:1 email ratio, 117 OFW messages Nov 1-24, 19+ medical visits 2021-2025, Nov 9 correlation: late play date → hostile FaceTime → missed school)
Direct admissions (4 explicit retaliation statements Nov 24-26, recorded Nov 24 medical decision quote)

Next Steps: