Direct Examination

Jayla Sierra

I. Establishing Background

1. What is your daughter’s name?

2. Where was she born?

3. Is Mr. Madrid the father?

4. Has Mr. Madrid lived in Colorado the entire time since she was born?

5. Explain Mr. Madrid’s living situation to the court.

6. Has she lived in Colorado since she was born?

7. Has your house been her primary residence?

8. Where do you live?

9. Tell me about Leilani’s living arrangements at your parents’ house?

10. Is it safe?

11. Is there a park nearby?

12. Does your family financially support you or Leiliani whatsoever?

13. Who supports Leilani financially?

14. What do you do for a living?

II. Financials And Child Support

a. Laying Foundation. What is this document? When did you create it? Is it a true

and accurate copy?

16. What is your monthly income?

17. Leliani is 24 months old correct?

18. Has Mr. Madrid paid child support at all for the 24 months that you have had her?

19. To your knowledge, does Mr. Madrid have a job? What does he do?

20. Please flip to Exhibit 2.

a. Laying Foundation. What is this document? When did you create it? Is it a true

and accurate copy?

21. His income is listed as $3680, do you agree with that number? *I want you to say no.

Because his tax returns for 2024 show that his income should be higher at $4231.11 per

month).

22. Do you think he has pay artificially low to evade paying higher child support?

23. Have you asked Mr. Madrid for child support? Have you asked him for awhile?

24. Have you ever told Mr. Madrid he did not have to pay child support? *The answer is NO!

You have always asked.

25. Please flip to Exhibit 5.

a. Laying Foundation: What are these? (texts). When did you obtain these? Did you

edit these in any way? Who are these texts between?

26. You texted Mr. Madrid that you were asking for child support, isn’t that true?

27. And what did Mr. Madrid say?

you child support, correct?

29. Are you asking the court for retroactive child support? (Yes)

30. Please Flip to Exhibit 6.

31. The child support amount is listed as $639.19 is that right?

32. This is based on your income at $3400.74 which is reflected in your sworn financial

statement correct?

33. And the child support worksheet lists Mr. Madrid’s income at $4,231.00 is that right?

34. Are you asking the court to order retroactive child support in the amount of $639.19 per

month?

35. Are you asking the court to begin child support at $639.19 per month starting May 1,

2025?

36. Does this child support also include childcare. Costs? (Yes)

37. Tell me about Leilani’s day care. Where is it? What time does she leave?

38.

III. Custody Factors

1. Ms. Sierra, has Mr. Madrid had any virtual parent time while has lived in Florida?

2. How often? How many days? How many times a day?

3. Are there certain times of the day that it is difficult to conduct virtual parent time?

4. Have you ever prevented Mr. Madrid from speaking to Leilani?

5. Please Flip to Exhibit 12.

a. Lay Foundation: What are these documents? How did you obtain them? When did

you obtain them? Are these a true and accurate copy of your call logs? Did you

edit these in any way?

6. Ms. Sierra, what do you want to tell the court about this Exhibit?

7. Is Leiliani Dad referring to Caleb Madrid?

Respondent’s Parenting Time

1. Has Mr. Madrid exercised any parent time with the minor child?

2. If so, when and for how long?

3. Why did you stop bringing Leilani to Florida? (Mention it was a mistake)

4. Did you notice behavioral change? If so, can you be specific what you observed?

Respondent’s Current Living Situation

1. Please flip to Exhibit 13.

accurate copy?

2. To date, it is your knowledge and belief that Mr. Madrid has lived in Florida, correct?

3. You received this message from Mr. Madrid that he moved to Colorado on the 12th is that

right?

4. Do you know if he has in fact moved? (no)

5. What is the living accommodation that Mr. Madrid stated he will have?

6. If you flip to Page 4, is this the layout that Mr. Madrid sent you?

7. It is a 2 bedroom 2 bath correct?

8. Mr. Madrid has a girlfriend right? How many kids do they have?

9. Mr. Madrid’s girlfriend’s kids are how old? What gender?

10. So there is a total of five people is that right?

11. Are you worried about Leilani not having a space of her own?

12. Does Mr. Madrid work during the day?

13. What time does he usually work?

14. He does apartment maintenance right?

15. If he had Leilani during the day he is working, what are you asking the court to do? (Give

you right of first refusal instead of staying with girlfriend)

16. What is your work schedule?

17. The preschool Leiliani goes to is part of your school right?

18. How far is your residence to Mr. Madrid’s alleged residence?

Colorado? (I am asking the court to adopt day time visitations twice a week after day care

until 7 p.m.)

20. How long do you want that schedule to last? (8 weeks, until Mr. Madrid becomes stable

and Leiliani gets used to seeing everyone regularly. Then after 8 weeks, it can ramp up to

three visits. Then after 8 weeks it can ramp up to 2 weekly visits and one overnight.)

21. Are you aware that Mr. Madrid is requesting a week on week off schedule?

22. Why are you opposing this? (Stability…. 2 year old daughter is too long to be away from

you for a week at a time and you are worried that it would emotionally deregulate her)

Decision Making

1. Have you been all the decisions for Leiliani’s medical care?

2. Has there been issues between you and Mr. Madrid on issues of medical care? (Yes

vaccinations)

3. Does Leliani have established medical care in Colorado?

4. Are you the one that has taken Leilani to most of her medical appointments?

5. Can you flip to Exhibit 7? Let me know when you are there.

a. What is this document? How did you obtain it? When did you obtain it? Is it

accurate?

6. Did you or Mr. Madrid attend this doctor appointment?

7. You are an educator is that correct?

8. Would you like your address to be where Leiliani’s address is scheduled for school?

9. Why?
 10. Tell me about Leilani’s daycare.

11. Do you visit her?

12. What other grades do they teach at your school?

13. Did Mr. Madrid help with the decision for this school?

14. Has he paid you for her child care?

Cross Examination - Sierra Berthelette

These are all calls in the morning, right?

Are you aware Jayla goes to day care?

Do you think it’s wrong that the child cannot talk at any and all points of the day?

GO THROUGH EACH TIME?

Did you guys facetime Leiliani while traveling?

Did you observe virtual parent time in April 2025?

Did you observe virtual parent time in March 2025?

When you say virtual parent time wasn’t consistent, what do you mean?

When you did week on and week off with Leiliani, how old was Leilani?

How long did you know her?

Are you an expert in child psychology?

Or child custody?
You moved here briefly, right?

Then you moved back to Florida after 3 months, right?

Do you plan to move back to Florida?