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Affidavit of Maria Higgins
(neighbor of Barbara Kurth) - 09/17/79

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1. My name is Maria Higgins and my address is 124 Mohawk Forest. I am submitting this affidavit in support of the motion of Stephen H. Fagan for permanent custody of his children, Rachael and Wendy.

2. I am a neighbor of Barbara (Fagan) Waugh. My home is directly across the street from Barbara's. I have lived across the street from Barbara for about a year. Barbara has had custody of Rachael and Wendy throughout this time period.

3. Throughout this summer, I have observed Barbara and her children, and have had considerable contact with the children. The younger child, Wendy, is often outside with no pants on and occasionally no clothing at all. She also frequently says that she is hungary and has not been fed regularly. I (and many of other neighbors) often feed Rachael and Wendy their meals because their mother has not fed them. Frequently Rachael and Wendy are left without their mother's supervision for hours at a time, often three or more hours.

4. I have frequently observed Barbara in what I consider to be a drunken state. She stumbles, seems forgetful and smells like alcohol on those occasions. She has, on one occasion, called me three times for the same reason and did not remember that she had previously called.

5. This past Sunday, I saw Wendy, who is only two years old, on the window sill of the front window of Barbara's apartment. That window sill is approximately 35 inches from the floor, and wendy was totally unsupported. Barbara was oblivious to this situation. I was afraid that Wendy would fall off and hurt herself seriously.

6. I hope that something can be done about this situation, because children this young deserve much better care.

7. I had never met Stephen fagan, the children's father, before Friday, September 14, 1979. He showed tremendous concern at the situation, even driving three hours from Framingham just to speak with me and other neighbors of Barbara's.

Signed Under the pains and penalties of perjury;

Sept 17, 1979(Maria Higgins signature)
DatedMaria Higgins

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