Red Flags & Data Audit

Executive summary of critical issues, data quality gaps, and verification status · August 13, 2026

Critical

Disclosure & financial misrepresentation

High Priority

Income & disclosure gaps

Capacity Claim

"NO" she can't work

🚨 Critical Disclosure Deficiencies

CRITICAL SSI Account ••5296 — Never Disclosed Nico's Account

Chase Checking ••5296 (SSI representative-payee account) has never been produced. Nico's SSI ($967/mo) flows through here, controlled by Constanza as rep-payee. Evidence of account exists via ~$967/mo flows on disclosed accounts + Aug 2025 backlog sweep of $3,236.77.

Nico SSI:

$967/mo

Status:

Never produced

Risk:

Understate resources

⚠ RED FLAG: Why was Nico's entire SSI account omitted from disclosure? Request: ALL statements, DOS (6/23/2024) → present.

CRITICAL Date-of-Service (6/23/2024) Statements — Complete Gap $1,763,809 Estate

NO statement dated 6/23/2024 has been produced for ANY account. The entire marital estate valuation ($1,763,809.14) rests on BeachFleischman's Findings Letter reconstruction, not underlying bank records. Largest unverified asset: Caterpillar 401(k) ($686,527).

Cat 401(k):

$686,527 (unverified)

All DOS:

Missing

Source:

Findings Letter only

⚠ RED FLAG: All DOS statements missing. Valuations are uncontested claims without originals. Largest single asset ($686K) unverified.

CRITICAL Compulsive Shopping & Financial Misrepresentation $21,813 over 16 mo

Compulsive spending contradicts "NO earning capacity" claim and sworn financial hardship. $1,363/month average ($9,464 clothing + $12,348 Amazon, 583 transactions using multiple cards CC 5013 and CC 4381). Frequent returns pattern. Yet minor children wear same outfit all week to school. Shows unwillingness to work while spending compulsively—fundamental bad faith: refuses work obligation yet spends on discretionary items.

Monthly Avg:

$1,363/mo

Transactions:

583 total

Issue:

Won't work, will spend

⚠ RED FLAG: Pattern shows unwillingness to work (false "NO capacity" claim) paired with compulsive $1,400+/month spending. Despite earning $68K, refuses settlement and compliance. Misplaced priorities: marathon training & shopping >> children's basic clothing.

⚠ High Priority Issues — Disclosure & Income Gaps

HIGH False Earning Capacity Claim; Unwillingness to Work $68K Income

Respondent sworn under oath: "NO earning capacity" / "not looking or able to work." Reality: Works and earns $68,325/yr (Helping Hearts $54,718 + Fleet Feet $13,607). Fleet Feet position is minimal hours (~10/week at minimum wage), yet she simultaneously spends $250/month on marathon training gear at same retailer. Pattern: Claims inability to work while compulsively spending $1,400+/month—fundamental contradiction showing unwillingness to work or expand employment.

Actual Income:

$68,325/yr

Sworn Claim:

"NO capacity"

Status:

Unwilling to work

⚠ RED FLAG: False sworn statement about earning capacity; minimal hours/income despite maintaining employment; compulsive $1,400+/month spending contradicts financial need claims; pattern of unwillingness to work paired with refusal to settle; non-compliance and bad faith.

HIGH Represented as Disclosed But NOT in File 8 Items Missing

Belleau's letters claim these were "disclosed," but they do not appear in what was transmitted. Each should be re-produced or Belleau should identify the transmittal.

••8531:

June 2024 missing

••3063:

Sept 2024-July 2025 missing

••1874:

May-July 2025 missing

⚠ Pattern investigation: Are these gaps selective re-disclosure, account rotation, or processing errors? Request: Belleau re-produce or identify transmittal letter for each item.

HIGH Pay Record Gaps — Income Gaps and Missing Stubs $7,191+ Gap

Fleet Feet: Missing Apr–Dec 2025 (transition from Whitlow to Resourcing Edge); no 2024/2025 W-2s. Helping Hearts: Aug–Dec 2025 missing; $7,191 gap between 1099-NEC ($41,961) and produced stubs ($23,797.50).

Fleet Feet:

Apr-Dec 2025 missing

HH Gap:

$7,191 unexplained

Impact:

$25K+ material

⚠ RED FLAG: Was there a 9-month employment gap for Fleet Feet, or disclosure issue? Is $7,191 missing income or 1099-issued payments? Request: Complete stubs + W-2s. Estimates only temporary.

HIGH Chase CD ••2285 — Screenshot Only, No Statement $268,400.36

Only a screenshot (8/6/2025) was produced. CD balance ~$268,400, claimed as Coni's half of home-sale proceeds. Actual CD periodic statement never produced.

Amount:

$268,400

Rate:

3.92%

Proof:

Screenshot only

⚠ Request: Actual CD statements (opening 4/29/2025 → present) + account-opening & source-of-funds documentation. When was home sale closed? Do ••8531 withdrawals match 4/29/2025?

HIGH Bank Statements Current Through Nov 2025 Only All of 2026 Missing

Chase ••8531, ••3063, ••1874 stop at Nov 2025. No 2026 statements at all. Missing 8+ months to tie to pay records and verify no hidden transfers.

Have:

Aug-Nov 2025 only

Missing:

Dec 2025 → present (all 2026)

⚠ Request: Updated statements through present. Verify 2026 income flows match paystubs. Catch any hidden withdrawals or transfers.

⚖ Capacity Claim — "NO She Can't Work"

RED FLAG Constanza Claims "NO" Earning Capacity Contradicted by Income

Opposing Position (Belleau): Constanza has zero earning capacity and cannot work. Reality: She is actively employed at Helping Hearts (~$54,718/yr, 2026 YTD annualized) + Fleet Feet (~$13,607/yr, Q1-2025 documented). She works 2 jobs while claiming she can't work.

HH Income:

$54,718/yr

Fleet Feet:

$13,607/yr

Combined:

$68,325+/yr

Claim:

$0 capacity

⚠ CONTRADICTION: She's employed and earning $68K+ but claims zero capacity. This contradicts child support & spousal maintenance income basis. Challenge her capacity claim with evidence of current employment.

📋 Missing Documents Priority List

Priority	Document	Status	Impact
1	Chase ••5296 (SSI)	Never disclosed	$967/mo understatement
2	DOS 6/23/2024 Statements	All accounts missing	$1.76M estate unverified
3	Part A Re-productions	Claimed sent, not in file	Closure of gaps
4	Chase CD ••2285 Statement	Screenshot only	$268K asset unproven
5	Luis/Marital Statements	No current values	401(k) $686K unverified
6	2026 Bank Statements	All accounts missing	Verify 2026 income flows
7	Pay Records	Apr-Dec 2025 gaps	$25K+ income material

✓ Documents on File (Verified)

ON FILE Chase Freedom ••5013 (Community CC) Sept 2024 – Nov 2025

Constanza's community credit card statements on file. Full transaction detail available for expense analysis.

Period:

Sept 2024 – Nov 2025

Status:

Complete ✓

Gap:

DOS statement + Dec 2025→present

ON FILE Fleet Feet W-2 & Stubs (Partial) Some periods

Fleet Feet documentation on file: Aug–Oct 2024, Jan-Mar 2025, Feb-Jun 2026. Gap: Apr-Dec 2025.

Have:

Partial periods

Missing:

Apr-Dec 2025 + W-2s

ON FILE Helping Hearts 1099-NEC & Stubs (Partial) Most periods

Helping Hearts income documented: Jan-Jul 2025, Feb-Jul 2026, 2024 annual 1099. Gap: Aug-Dec 2025 (estimated via 1099 residual).

2025 Total:

$41,961 (1099)

Documented:

$23,797.50

Gap (estimated):

$18,163.50

📋 Litigation Strategy — Key Actions

Challenge "NO Capacity" Claim Immediately. Constanza claims zero earning capacity but is employed at Helping Hearts ($54,718/yr) + Fleet Feet ($13,607/yr) = $68,325+/yr. Use her own pay stubs to contradict her assertion in child support & spousal maintenance arguments.
Meet & Confer on Disclosure Deficiencies. Issue formal letter per Missing_Documents_and_Disclosure_Discrepancies_7.30.26.md. Demand Belleau re-produce items claimed as "disclosed" or explain why absent. Focus: SSI account ••5296 was never disclosed at all.
Demand DOS 6/23/2024 Statements for All Accounts. The $1.76M marital estate rests on BeachFleischman Findings Letter reconstruction. Without original bank statements (Caterpillar 401(k) $686,527 largest unverified), valuations are uncontested claims.
Request Chase CD ••2285 Statements + Source Documentation. Only screenshot ($268,400) on file. Need: actual CD statements (opening 4/29/2025 → present) + account-opening & source-of-funds docs to verify home-sale-proceeds claim ($268K is material 15% of estate).
Subpoena Bank Statements Directly if Needed. Chase and other institutions for full DOS-to-present periods, bypassing counsel. Document Belleau's delays for discovery violation record.
Update Income Calculations with Verified Data. Once missing pay records obtained (Fleet Feet Apr-Dec 2025, Helping Hearts Aug-Dec 2025), recalculate child support & spousal maintenance using verified figures, not estimates.

📊 Red Flags Summary

Category	Count	Key Issues	Priority
Critical Disclosure Gaps	2	SSI account never disclosed; DOS statements all missing ($1.76M unverified)	CRITICAL
High Priority Gaps	5	$19,916 mystery expense; pay records gaps; CD screenshot only; 2026 statements missing	HIGH
Capacity Contradiction	1	"NO" capacity claim vs $68K+ actual employment income (2 jobs)	HIGH
Partial Documentation	3	Fleet Feet, Helping Hearts, Chase statements (gaps to fill)	MEDIUM