Deborah Jean Dahl v. James Richard Dahl 02-3-02768-6

02-3-027686
17208352
CICS
08-29-02
J
Please check one category that best describes this case for indexing purposes.
Presumed tracks are listed next to the cause codes. (Non PCLR indicates no Track Assignment Request is required.)
If you cannot determine the appropriate category, please describe the cause of action below. This will create a
AMiscel/aneous:cause which is not subject to PCLR 1, and does not require a Track Assignment Request Form.
APPEAL I REVIEW
_Administrative Law Review (ALR 2) Non PCLR
_Civil, Non-Traffic (LCA 2) Non PCLR
_Civil, Traffic (LCI 2) Non PCLR
CONTRACT I COMMERCIAL
_ Breach of Contract (COM 2) EXPEDITED
_Commercial Contract (COM 2) EXPEDITED
_Commercial Non-Contract (COM 2) EXPEDITED
_Third Party Collection (COL 2) EXPEDITED
DOMESTIC RELATIONS
_Annulment/ Invalidity (INV 3) DISSOLUTION
_Child Custody (CUS 3) DISSOLUTION
_)'... Dissolution with children (DIC 3) DISSOLUTION
_ Dissolution without children (DIN 3) DISSOLUTION
_ Foreign Judgment (FJU 3) Non PCLR
_Legal Separation (SEP 3) DISSOLUTION
_Mandatory Wage Assignment (MW A 3) Non PCLR
_Meretricious Relationship (MER 2) Non PCLR
_Modification (MOD 3) Non PCLR
_Out-of-State Custody (OSC 3) DISSOLUTION
_Reciprocal, Respondent in county (RIC 3) Non PCLR
_ Reciprocal, Respondent out of county (ROC 3) Non PCLR
JUDGMENT
_Abstract Only (ABJ 2) Non PCLR
_Foreign Judgment (FJU 2) Non PCLR
_Judgment, Another County (ABJ 2) Non PCLR
_Judgment, Another State (FJU 2) Non PCLR
_Tax Warrant (TAX 2) Non PCLR
_Transcript of Judgment (TRJ 2) Non PCLR
OTHER COMPLAINT OR PETITION
_Compel/Confirm Binding Arbitration (MSC 2) Non PCLR
_Change of Name (CHN 2) Non PCLR
_ Deposit of Surplus Funds (MSC 2) Non PCLR
_ Emancipation of a Minor (EOM 2) Non PCLR
_Injunction (INJ 2) Non PCLR
_ Intcrplcader (MSC 2) Non PCLR
_Malicious Harassment (MHA 2) Non PCLR
_Minor Settlement /No Guardianship (MST 2) Non PCLR
_ Petition for Civil Commit/Sexual Predator (PCC 2) Non PCLR
_ Seizure of Property from Comm of Crime (SPC 2) Non PCLR
_ Seizure of Property Resulting from Crime (SPR 2) Non PCLR
_ Subpoenas (MSC 2) Non PCLR
ADOPTION I PATERNITY
_Adoption (ADP 5) Non PCLR
_ Confidential Intermediary (MSC 5) Non PCLR
_ Initial Pre-Placement Rpt (PPR 5) Non PCLR
_ Modification (MOD 5) Non PCLR
_ Paternity (PAT 5) Non PCLR
_ Patemity/URESA/UIFSA (PUR 5) Non PCLR
_ Relinquishment (REL 5) Non PCLR
_Terminate of Parent-Child Relation (TER 5) Non PCLR
PROBATE I GUARDIANSHIP
_Absentee (ABS 4) Non PCLR
_Disclaimer (DIS 4) Non PCLR
_ Estate (EST 4) Non PCLR
_ Foreign Will (FNW 4) Non PCLR
_Guardianship (GDN 4) Non PCLR
_Guardianship I Estate (G/E 4) Non PCLR
_Limited Guardianship (LGD 4) Non PCLR
_Minor Settlement /With Guardianship (MST 4)Non PCLR
_Non-Probate Notice to Creditors (NNC 4) Non PCLR
_Will Only (WLL 4) Non PCLR
PROPERTY RIGHTS
_Condemnation (CON 2) STANDARD
_Foreclosure (FOR 2) STANDARD
_Property Fairness (PFA 2) STANDARD
_Quiet Title (QTI 2) STANDARD
_Unlawful Detainer/Eviction (UND 2) Non PCLR
TORT I MEDICAL MALPRACTICE
_Hospital (MED 2) COMPLEX
_ Medical Doctor (MED 2) COMPLEX
_Other Health Care Professional (MED 2) COMPLEX
TORT I MOTOR VEHICLE
_ Death (TMV 2) STANDARD
_Non-Death Injuries (TMV 2) STANDARD
_ Property Damage Only (TMV 2) STANDARD
TORT I NON MOTOR VEHICLE
_Asbestos (PIN 2) STANDARD
_Other Malpractice (MAL 2) COMPLEX
_Personal Injury (PIN 2) STANDARD
_ Products Liability (PIN 2) STANDARD
_ Property Damage (PRP 2) STANDARD
_Wrongful Death (WDE 2) STANDARD
WRIT
_ Habeas Corpus (WHC 2) Non PCLR
_ Mandamus (WRM 2) Non PCLR
_Review (WRY 2) Non PCLR
8?29/2002
02-3-02768-6
17209355
SM
6231
~0002
OB-29-02
FILED
1N COUNTY CLERK'S OFFICE

PIERCE COUNTY, WASHINGTON
3
A.M.
4
5
}
}
AUG 2 8 2002
P.M.
;i;
-i
BOB SAN SOUCIE

COUNTY CLER~EPUTY
6
7
SUPERIOR COURT OF WASHINGTON

COUNTY OF PIERCE
02 3 02768 6
9
In re the Marriage of:
NO.
DEBORAH J. DAHL
SUMMONS
{SM)
10
11
Petitioner,
and
12
JAMES R. DAHL
13
Respondent.
14
TO THE RESPONDENT:
JAMES R. DAHL
15
1.
The petitioner has started an action in the above court requesting that
your marriage be dissolved.
16
17
Additional requests, if any, are stated in the petition, a copy of which

is attached to this summons.
18
2.
You must respond to this summons and petition by serving a copy of

your written response on the person signing this summons and by
filing the original with the clerk of the court. If you do not serve your
written response within 20 days (or 60 days if you are served outside
of the State of Washington) after the date this summons was served
on you, exclusive of the day of service, the court may enter an order
of default against you, and the court may, without further notice to
you, enter a decree and approve or provide for the relief requested in
the petition. In the case of a dissolution of marriage, the court will not
enter a decree until at least 90 days after filing and service. If you
serve a notice of appearance on the undersigned person, you are
entitled to notice before an order of default or a decree may be
entered.
19
20
21
22
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24
25
SUMMONS
WPF OR 01.0200 (9/2001)
CR 4.1
Page 1 of 2
Famqi+1'/ua
10.7
EISENHOWER & CARLSON, PLLC

1200 WELLS FARGO PLAZA
1201 PACIFIC AVENUE
TACOMA, WA 98402
{253) 572-4500
(253) 272-5732 FAX
B/29.1'2frn2
&23.1
50003
3.
Your written response to the summons and petition must be on form

WPF DR 01.0300, Response to Petition (Domestic Relations). This
form may be obtained by contacting the clerk of the court at the
address below, by contacting the Office of the Administrator for the
Courts at (360) 705-5328, or from the Internet at the Washington
State Supreme Court Homepage:
2
3
4
http://www.courts.wa.gov/forms
5
4.
If this action has not been filed with the court, you may demand that
the petitioner file this action with the court. If you do so, the demand
must be in writing and must be served upon the person signing this
summons. Within 14 days after you serve the demand, the petitioner
must file this action with the court, or the service on you of this
summons and petition will be void.
5.
If you wish to seek the advice of an attorney in this matter, you

should do so promptly so that your written response, if any, may be
served on time.
6
7
8
9
10
11 6.
One method of serving a copy of your response on the petitioner is to

send it by certified mail with return receipt requested.
12
13
This summons is issued pursuant to Superior Court Civi

of Washington.
le 4. 1 of the State
14
Dated:
15
16
17 FILE ORIGINAL OF YOUR
RESPONSEWITH THE CLERK
18 OF THE COURT AT:
Clerk of the Court
19 Pierce County Court
County-City Building
20 930 Tacoma Ave. S., Rm 110
Tacoma, WA 98402
SERVE A COPY OF YOUR

RESPONSEON:
Petitioner's Attorney
P. Craig Beetham
Eisenhower & Carlson, PLLC
1201 PACIFIC AVENUE, STE. 1200
TACOMA, WA 98402
21
22
23
24
25
SUMMONS
WPF DR 01.0200 (9/2001)
CR 4.1
Page 2 of 2
Interoffice II:
Client File: P:\SCPLUS\DAHL\dahl.SCP 08/26/2002
11:05 a.m.
Form: P:\SCPLUS\DAHL\summons.DOC
08/26/2002
11:05 a.m.
f'DrJM+.PfU.11
10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 FAX
B~29/2~82
02-3-02768-6
17208357
PTDSS
&231
00004
OB-29-02
FILED
IN COUNTY Cl.ERK'S OFFICE

3
4
A.M.
AUG 2 8 2002
BOB SAN SOUCIE

COUNTY CLERK
6
7
P.M.
DEPUT

COUNTY OF PIERCE
8
9
02 3 02768 6
NO.
DEBORAH J. DAHL
PETITION FOR DISSOLUTION

OF MARRIAGE
(PTDSS)
10
11
Petitioner,
and
12
JAMES R. DAHL
13
Respondent.
14
15
I. BASIS
, .,
IDENTIFICATION OF PETITIONER.
16
Name (first/last) DEBORAH DAHL, Birth date 07/29/57
17
Last known residence PIERCECounty, WA (county and state)
18
1.2
IDENTIFICATION OF RESPONDENT.
19
Name (first/last) JAMES DAHL, Birth date 01 /08/54
20
Last known residence PIERCECounty, WA (county and state}
21
, .3
22
CHILDREN OF THE MARRIAGE DEPENDENTUPON EITHER OR BOTH

SPOUSES.
23
Name (first/last) AMANDA DAHL
24
Name (first/last) SARA\bAHL
25
Name (first/last) ELIZABETH DAHL
Age 13
Age 10
Age 5
PETITION FOR DISSOLUTION OF MARRIAGE

WPF DR 01.0100 (9/2001)
RCW 26.09.020
Page 1 of 5
roNM+Plu~
10. 7
EISENHOWER& CARLSON, PLLC

1 200 WELLS FARGO PLAZA
1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 FAX
8/29/2002 623~ 08005
1
2
1.4
3
4
ALLEGATION REGARDING MARRIAGE.

This marriage is irretrievably
1.5
broken.
DATE AND PLACE OF MARRIAGE.

The parties were married on 09/09/83 at PIERCE COUNTY,
WASHINGTON.
6
1.6
SEPARATION.
7
Husband and wife are not separated.
8
1.7
JURISDICTION.
9
This court has jurisdiction
over the marriage.
10
This court has jurisdiction
over the respondent because:
11
The respondent is presently residing in Washington.
12
1.8
PROPERTY.
13
There is community or separate property owned by the parties. The
court should make a fair and equitable division of all the property.
14
15
The division of the property should be determined by the court at a

later date.
16
1.9
DEBTS AND LIABILITIES.
17
The parties have debts and liabilities. The court should make a fair
and equitable division of all debts and liabilities.
18
19
The division of debts and liabilities should be determined by the court

at a later date.
20
1.10
SPOUSAL MAINTENANCE.
21
Spousal maintenance should not be ordered.
22
1 . 11
CONTINUING RESTRAINING ORDER.
23
Does not apply.
24
25
WPF DR 01.0100 (9/2001)
RCW 26.09.020
Page 2 of 5

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(2531 272-5732 FAX
8/29/2002 623~ 00606
1 .12
2
3
PREGNANCY.
The wife is not pregnant.
1 .13
JURISDICTION OVER THE CHILDREN.

This court has jurisdiction over the children for the reasons set
forth below:
5
This state is the home state of the children because the
children lived in Washington with a parent or a person
acting as a parent for at least six consecutive months
immediately preceding the commencement of this
proceeding.
6
7
8
1.14
9
10
11
16
CHILD SUPPORT AND PARENTING PLAN FOR DEPENDENT

CHILDREN.
Support for the dependent children listed in paragraph 1 .3, above,
should be set pursuant to the Washington State Child Support
Schedule.
The petitioner's proposed parenting plan for the children is attached

and is incorporated by reference as part of this Petition.
17
18
19
(The following information is required only for those children who are
included in the petitioner's proposed parenting plan.)
20
During the last five years, the children have lived in no place other
than the State of Washington and with no person other than the
petitioner or the respondent.
21
Claims to custody or visitation:
22
23
The petitioner does not know of any person other than the
respondent who has physical custody of, or claims to have
custody or visitation rights to, the children.
24
25
WPF DR 01.0100 (9/2001)
RCW 26.09.020
Page 3 of 5

1201 PACIFIC AVENUE
TACOMA, WA 98402
{253) 572-4500
(253) 272-5732 FAX
8/29/2802
6231
80007
~I
Involvement in any other proceedings concerning the children:
The petitioner has not been involved in any other proceeding

regarding the children.
3
Other legal proceedings concerning the children:
The petitioner does not know of any other legal proceedings

concerning the children.
5
6
1 .1 5
OTHER:
7
8
11. RELIEF REQUESTED
9
The petitioner REQUESTS the Court to enter a decree of dissolution and to
10 grant the relief below.
11
Approve the petitioner's proposed parenting plan for the dependent

children.
12
13
Determine support for the dependent children pursuant to the

Washington State Child Support Schedule.
14
Divide the property and liabilities.
15
Award the tax exemptions for the dependent children as follows:
16
One to each and alternating the third exemption every other year
with Mother taking even tax years and Father taking odd tax years.
17
18
Order payment of attorney's fees, other professional fees and costs.
19
20
Dated:
21
22
23
24
25
WPF DR 01.0100 (9/2001)
RCW 26.09.020
Page 4 of 5
f"ormuP/u,. 10.7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 FAX
.., .
1
I declare under penalty of perjury under the laws of the State of Washington
that the foregoing is true and correct.
2
Signed at
3
;f(fu4.
(<IA
)(City and State)
4
~
, on
4llf;0J(Date
f7t; 'io&.
JfaM,
Declarant/
6
7
8
9
10
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12
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15
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WPF DR 01.0100 (9/2001)
RCW 26.09.020
Page 5 of 6

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 FAX
8~29/20H2
02-3-02768-6
17208359
6231
00089
AST
FILED
IN COUNTY CLERK'S OFFICE
A.M.
AUG 2 8 2002
P.M.
BOB SAN SOUCIE
BY
COUNTY~LERKDEPUTY
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR PIERCE COUNTY
No.02-3-02768-6
ORDER ASSIGNING CASE
TO DEPARTMENT
Docket Code: AST
In accordance with PCLR 40(b}, this case is hereby assigned to Department 10, Judge D. Gary Steiner.
Notice to Petitioner:
Once the case has been filed, the petitioner shall serve a copy of this Order Assigning Case to Department on
the respondent with the summons and petition. Provided, however, that in those cases where service is by
publication the petitioner shall serve a copy of this Order Assigning Case to Department within five (5) court
days of service of the respondent's first response/appearance.
If the case has not been filed, but an initial
pleading is served, a copy of this Order Assigning Case to Department shall be served within five (5) court days
of filing. PCLR 1 (b ).
Trial Date:
A trial date may be obtained pursuant to PCLR 40(d) by filing a 'Note of Issue' for assignment of a trial date by
noon at least six (6) court days prior to the date fixed for assignment of the trial date. PCLR 40(d}
If a trial date is not obtained pursuant to PCLR 40(d), failure to appear on this date will result in dismissal of the
case by the Court. PCLR 40(d)
Assignment for Trial Date
Friday, January 3, 20039:30 AM
At that time the Court will provide you with a Case Schedule which shall include the trial date. Failure to
appear on this date will result in dismissal of the case by the Court. PCLR 40(d).
Uncontested Dissolutions/Settlements:
If this case is agreed upon by both petitioner and respondent, you are not required to wait for the trial date in
order to settle your case. If you settle your case and the appropriate time requirements have been met, you
may file a 'Note for Commissioner's Calendar' to appear before a Court Commissioner for entry of final papers.
August28,2002
Ix civil. d_family _law_ assignment_notice
Judge D. Gary Steiner

Department 10 (253) 798-7572
l l l\ rn 1111 rn IDH
02-3-02768-6
17211109
NTC
FILE 0
IN COUNTY CLERK'SOFFICE
PIERCE COUNlY, WASHINGTON
OB-29-02
AUG 2 8 2002
A.M.
BOB SAN SOUCIE
BY
COUNTY CLERK
~
DEPUTY
PIERCE COUNTY SUPERIOR COURT, STATE OF WASHINGTON

DEBORAHDAHL
Plalntiff(s)/Petitloner(s),
vs.
JAMES DAHL
)
)
)
)
)
)
)
Case No.
02 3 02768 6
_
NOTE FOR COMMISSIONER'SCALENDAR
Defenclant(s)/Respondent(s).
TO THE CLERK OF THE SUPERIOR COURT AND TO:
NAME
_J_A_M_E_S_D_A_H_L~~~~~~~~~~WSB#~~~~~~~~~
ADDRESS
ATTORNEY FOR._~~~~~
--------------~PHONE
(Please note addillonal attorneyson an attached page)
Please take notice that an issue of law in this case will be heard on the date below and the clerk is
directed to note this issue on the appropriate calendar:
II
CALENDAR
DATE._S_e~p_te_m_b_e_r 1_6_, _20_0_2
II
Nature of Case: DISSOLUTIONW/CHILDREN

SELECT ONE BOX BELOW
[a.I] (MO) Show Cause/Family Law, Confinnation Required

(9:30 Mon.~ Thurs.)
PARTY SETTING HEARING MUST CONFIRM BY CALLING (253)798-6697 BY NOON, TWO (2)
COURT/WORKINGDAYS PRIOR TO HEARINGOR HEARING WILL BE CANCELLED
] (VY) Adoption, No Confinnation Required
(9:30 Fri.)
] (OE) Supplemental Proceedings, No Confinnation Required
(1 :30 Mon.~ Fri.)
] (UD) Unlawful Detainer, No Confinnation Required
(1 :30 Mon.~ Fri.)
] (GD) Probate/Gdnsh~nr Settlement, No Confirmation Required
(1 :30 Mon.~ Fri.)
] (DD) Uncontested Dissolutions, No Confinnation Required.............
ys (3:00Mon.~Fri.)
] (FC) Paternity, No Confinnation Required..........................
:30 Mon., Tues.
.)
Dated: 8/27/2002
NAME
P. CRAIG BEETHAM
ADDRESS
Signed:__
l--1'-\-~+---------20139
1201 PACIFIC AVENUE, SUITE 1200

TACOMA, WA 98402
THE ABOVE INFORMATION MUST BE COMPLETED AND SIGNED
FORMS\COMNOTE32001.00C
P.M.
S/29/2002
02-3-02768-6
17208374
PPP
231
00023
.J
FILED
IN COUNTY CLERK'S OFFIC

PIERCE COUNTY, WASHINGTO
3
A.M.
4
5
BY
AUG 2 8 2002
808 SAN SOUCIE

OUNTY CLERK
'f
DEPU
6
7

COUNTY OF PIERCE
02 3 02768 6
9
NO.
DEBORAH J. DAHL
PARENTING PLAN
PROPOSED (PPP)
10
11
Petitioner,
and
12
JAMES R. DAHL
13
Respondent.
14
This parenting plan is proposed by Mother.
15
IT IS HEREBY ORDERED, ADJUDGED AND DECREED:
16
I. GENERAL INFORMATION
17
This parenting plan applies to the following children:
18
Name
Age
19
20
AMANDA
SARA\-\
ELIZABETH
DAHL
DAHL
DAHL
13
10
5
21
II. BASIS FOR RESTRICTIONS
22
23
Under certain circumstances, as outlined below, the court may limit or prohibit
a parent's contact with the children and the right to make decisions for the
children.
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 1 of 12

1201 PACIFIC AVENUE
TACOMA, WA 98402
(2531 572-4500
(253) 272-5732 FAX
B/29/2002
2.1
6231
00024
PARENTAL CONDUCT (RCW 26.09.191 (1), (2)).

Does not apply.
3
2.2
OTHER FACTORS (RCW 26.09.191 (3)).
4
The father's involvement or conduct may have an adverse effect on
the children's best interests because of the existence of the factors
which follow:
6
A long-term impairment resulting from drug, alcohol, or other
substance abuse that interferes with the performance of parenting
functions.
8
111. RESIDENTIAL SCHEDULE
9
The residential schedule must set forth where the children shall reside each
10 day of the year, including provisions for holidays, birthdays of family
members, vacations, and other special occasions, and what contact the
11 children shall have with each parent. Parents are encouraged to create a
residential schedule that meets the developmental needs of the children and
12 individual needs of their family. Paragraphs 3.1 through 3.9 are one way to
write your residential schedule. If you do not use these paragraphs, write in
13 your own schedule in Paragraph 3.13.
14
3.1
15
16
17
18
19
SCHEDULE FOR CHILDREN UNDER SCHOOL AGE.

There are no children under school age.
3.2
SCHOOL SCHEDULE.
Upon enrollment in school, the children shall reside with the mother,
except for the following days and times when the children will reside
with or be with the other parent: other:
Saturday 9:00 a.m. - 8:00 p.m. and Sunday 9:00 a.m. 8:00 p.m. every other weekend.
20
21
The school schedule will start when each child begins kindergarten
22
23
24
25
PARENTING PLAN
WPF DR 01 .0400 (9/2001)
RCW 26.09.181; .187; .194
Page 2 of 12

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 FAX
8/29/2002
17
6231
00025
The residential schedule for the children for the holidays listed below
is as follows:
18
With Mother
(Specify
Year
Odd/Even/Every)
19
20
21
22
23
24
25
New Year's Day

Martin Luther King Day
Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 3 of 12
FormsPfu.1 10. 7
With Father
(Specify
Year
Odd/Even/Every)
Odd
Even
Odd
Even
Odd
Even
Odd
Even
Even
Odd
Even
Odd
Even
Odd
Even
Odd

1201 PACIFIC AVENUE
TACOMA, WA 98402
(2531 572-4500
(2531 272-5732 FAX
8/2~/2002
Christmas Day
Odd
6231
00026
Even
For purposes of this parenting plan, a holiday shall begin and end as
follows (set forth times):
3
10:00 a.m. - 8:00 p.m. but for Christmas Eve which shall extend to
10:00 p.m.
5
6
7
Other:
*January 1st is youngest child's birthday and shall be shared as
designated in special occasions below.
8
9
3.8
SCHEDULE FOR SPECIAL OCCASIONS.
10
The residential schedule for the children for the following special
occasions (for example, birthdays) is as follows:
11
12
With Mother
(Specify
Year
Odd/Even/Every)
13
With Father
(Specify
Year
Odd/Even/Every)
14
Mother's Day
Every
15 Father's Day
Every
Mother's Birthday
Every
16 Father's Birthday
Every
Children's Birthdays
Share
Share
17
3.9
PRIORITIES UNDER THE RESIDENTIAL SCHEDULE.
18
If the residential schedule, paragraphs 3.1 - 3.8, results in a conflict
19
where the children are scheduled to be with both parents at the same
time, the conflict shall be resolved by priority being given as follows:
20
Rank the order of priority, with 1 being given the highest priority:
21
3 School schedule (3.1, 3.2)

Winter vacation (3.3)
Spring vacation (3.4)
Summer schedule (3.5)
Vacation with parents (3.6)
1 Holidays (3. 7)
2 Special occasions (3.8)
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 4 of 12
fDhns+Pluf 10.7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 FAX
8/29/2002
3.10
6231
08027
RESTRICTIONS.
The father's residential time with the children shall be limited because
there are limiting factors in paragraphs 2.1 and 2.2. The following
restrictions shall apply when the children spend time with this parent:
3
4
Father is limited to daytime visitation
only.
5
3.11
TRANSPORTATION
ARRANGEMENTS.
6
Transportation costs are included in the Child Support Worksheets
and/or the Order of Child Support and should not be included here.
7
8
Transportation
as follows:
arrangements
for the children between parents shall be
9
Father shall provide transportation.
10
11 3.12
DESIGNATION OF CUSTODIAN.
12
The children named in this parenting plan are scheduled to reside the
majority of the time with the mother. This parent is designated the
custodian of the children solely for purposes of all other state and
federal statutes which require a designation or determination of
custody. Th is designation shall not affect either pa rent's rights and
responsibilities under this parenting plan.
13
14
15
3.13
OTHER.
3.14
SUMMARY OF RCW 26.09.430 ~ .480, REGARDING RELOCATION OF

A CHILD.
16
17
18
19
20
This is a summary only. For the full text, please see RCW 26.09.430
through 26.09.480.
21
If the person with whom the child resides a majority of the time plans
to move, that person shall give notice to every person entitled to court
ordered time with the child.
22
23
If the move is outside the child's school district, the relocating person
must give notice by personal service or by mail requiring a return
receipt. This notice must be at least 60 days before the intended
move. If the relocating person could not have known about the move
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page5 of 12
forrm+l'l1.1~ 10.7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(2531 572-4500
(253) 2725732 FAX
B/29/2002
&231 00023
in time to give 60 days' notice, that person must give notice within 5
days after learning of the move. The notice must contain the
information required in RCW 26.09.440. See also form DRPSCU
07.0500, (Notice of Intended Relocation of A Child.)
2
3
If the move is within the same school district, the relocating person
must provide actual notice by any reasonable means. A person
entitled to time with the child may not object to the move but may ask
for modification under RCW 26.09.260.
4
5
6
Notice may be delayed for 21 days if the relocating person is entering

a domestic violence shelter or is moving to avoid a clear, immediate
and unreasonable risk to health and safety.
7
8
If information is protected under a court order or the address

confidentiality program, it may be withheld from the notice.
9
A relocating person may ask the court to waive any notice
requirements that may put the health and safety of a person or a child
at risk.
10
11
Failure to give the required notice may be grounds for sanctions,
including contempt.
12
13
If no objection is filed within 30 days after service of the notice of

intended relocation. the relocation will be permitted and the proposed
revised residential schedule may be confirmed.
14
15
A person entitled to time with a child under a court order can file an
objection to the child's relocation whether or not he or she received
proper notice.
16
17
An objection may be filed by using the mandatory pattern form WPF

DRPSCU07.0700, (Objection to Relocation/Petition for Modification of
Custody Decree/Parenting Plan/Residential Schedule). The objection
must be served on all persons entitled to time with the child.
18
19
The relocating person shall not move the child during the time for
objection unless: (a) the delayed notice provisions apply; or {b) a court
order allows the move.
20
21
If the objecting person schedules a hearing for a date within 1 5 days

of timely service of the objection, the relocating person shall not move
the child before the hearing unless there is a clear, immediate and
unreasonable risk to the health or safety of a person or a child.
22
23
24
25
PARENTING PLAN
WPF DR 01 .0400 (9/2001)
RCW 26.09.181; .187; .194
Page 6 of 12
Forrnt ..Plu tD.7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
1253) 272-5732 FAX
B/29/2002
6231
e0029
1
IV. DECl~ION MAKING
2
4.1
DAY-TO-DAY DECISIONS.
3
Each parent shall make decisions regarding the day-to-day care and
control of each child while the children are residing with that parent.
Regardless of the allocation of decision making in this parenting plan,
either parent may make emergency decisions affecting the health or
safety of the children.
5
6
4.2
MAJOR DECISIONS.
7
Major decisions regarding each child shall be made as follows:
8
Education decisions:
joint
10
Non-emergency health
care:
joint
11
Religious upbringing:
mother
12 4.3
RESTRICTIONS IN DECISION MAKING.
13
There are limiting factors in paragraph 2.2, but there are no

restrictions on mutual decision making for the following reasons:
14
History of cooperation between the parties with regard to
15 education and medical decisions. Mother shall have sole decisionmaking with
regard to the children's religious upbringing to keep them in the same religious
16 routine that they are accustomed to.
17
V. DISPUTE RESOLUTION
18
The purpose of this dispute resolution process is to resolve disagreements
19 about carrying out this parenting plan. This dispute resolution process may,
and under some local court rules or the provisions of this plan must, be used
20 before filing a petition to modify the plan or a motion for contempt for failing
to follow the plan.
21
Disputes between the parties, other than child support disputes, shall
22
be submitted to {list person or agency):
23
24
mediation by P.C. Dispute Resolution Center, or

The cost of this process shall be allocated between the parties as
follows:
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 7 of 12

1201 PACIFIC AVENUE
TACOMA, WA 98402
{253) 572-4500
(253) 272-5732 FAX
B/29/2002
6231
00036
based on each party's proportional share of income from line 6

of the child support worksheets.
1
2
The counseling, mediation or arbitration process shall be commenced

by notifying the other party by written request.
In the dispute resolution process:
(a)
Preference shall be given to carrying out this Parenting Plan.
(b)
Unless an emergency exists, the parents shall use the

designated process to resolve disputes relating to
implementation of the plan, except those related to financial
support.
(c)
A written record shall be prepared of any agreement reached in
7
8
9
counseling or mediation and of each arbitration award and shall

be provided to each party.
10
(d)
If the court finds that a parent has used or frustrated the

dispute resolution process without good reason, the court shall
award attorneys' fees and financial sanctions to the other
parent.
(e}
The parties have the right of review from the dispute resolution
process to the superior court.
11
12
13
14
VI.
OTHER PROVISIONS
15
There are the following other provisions:
16
A. The child shall have reasonable telephone privileges with the parent
17 with whom the child is not then residing, without interference from the
residential parent.
18
8. Each parent agrees to exert every reasonable effort to maintain free
19 access and unhampered contact and communication between the child and
the other parent, and to promote the emotions of affection, love and respect
20 between the child and the other parent. Each parent agrees to refrain from
words or conduct, and to discourage other persons from uttering words or
21 engaging in conduct which would have a tendency to estrange the child from
the other parent, to damage the opinion of the child as to the other parent, or
22 which would impair the natural development of the child's love and respect
for the other parent. Each parent agrees and understands that words or
23 conduct which have a tendency to estrange or diminish the opinion of the
child from the other parent, also tends to diminish the child's self-esteem and
24 self-worth.
25
C.
Each parent agrees to honor the other's parenting style, privacy
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 8 of 12
F'ortna+l'lu 10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 FAX
8/29/2002
2
3
4
5
6
6231
80031
and authority, so long as it is not adverse to the child's best interest. Neither
parent shall interfere in the parenting style of the other, nor shall either parent
make plans or arrangements that would impinge upon the other parent's
authority or time with the child without the express agreement of the other.
Each parent shall encourage the children to discuss his or her grievance
against a parent directly with the parent in question. It is the intent of both
parents to encourage direct parent-child communication and bonding.
D. Each parent shall have equal authority to confer with school,

daycare, health and other program personnel regarding the child's progress,
and each parent shall have full and equal access to the education and
healthcare records of the child.
7
E. Each parent shall inform the other when that parent plans to be
away from his or her residence with the child for more than two consecutive
nights. The information to be provided shall include duration of the period,
9 the destination(s) and destination telephone number(s). This provision is
included solely for purposes of knowing the parent's and child's location in
10 the event of an emergency and is not meant to be intrusive.
11
F. Neither parent shall advise the child of the status of child support
payments or other legal matters regarding the parental relationship and
1 2 obligation.
13
14
G. Neither parent shall use the children, directly or indirectly, to gather

information about the other parent or take verbal messages to the other
parent.
15
H. Each parent shall have the right and responsibility to insure that the
children attend school and other scheduled activities while in that parent's
16 care. Activities shall not be scheduled to unreasonably interfere with the
other parent's residential time with the child.
17
I. Each parent shall provide the other parent with the address and
18 telephone number of their residence and update such information promptly
whenever it is anticipated to change or changes. "Reasonableness" is defined
19 at least 30 days in advance of a scheduled move, or within 72 hours of an
unscheduled move.
20
J. Neither parent shall ask the child to make decisions or requests
21 involving the residential schedule with the children except for plans which
have already been agreed to by both parents in advance.
22
K.
Neither parent shall encourage the child to change his or her
23 primary residence or encourage the child to believe that it is his or her choice
24
to do so. It is a choice which will be made by the parents or, if they cannot
agree, the courts.
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 9 of 12
F"o1ms ...Plu1
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1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 FAX
B/29/2082
1
2
3
6231
00832
L. Neither parent shall introduce a significant other during the

pendency of the temporary Parenting Plan nor have a significant other spend
the night during their visitation periods.
M. Father shall refrain from the consumption of alcohol twenty-four
hours prior to visitation and during visitation.
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
PARENTINGPLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 10 of 12
F'ONMl'lu~
10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(2531 272-5732 FAX
8/29/2002
6231
00033
1
VII.
DECLARATION FOR PROPOSED PARENTING PLAN
2
[ ]
Does not apply.
[ ]
(Only sign if this is a proposed parenting plan.) I declare under

penalty of perjury under the laws of the State of Washington
that this plan has been proposed in good faith and that the
statements in Part II of this Plan are true and correct.
3
4
5
6
7
of'~J~
Mother
Date and Place

Signature
Father
Date and Place of

Signature
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 f9/2001)
RCW 26.09.181; .187; .194
Page 13 of 14

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(2531 272-5732 FAX
..
8/2~/2002
6231
VIII. ORDER BY THE COURT
It is ordered, adjudged and decreed that the parenting plan set forth above is
adopted and approved as an order of this court.
00034
3
4
5
6
7
8
WARNING: Violation of residential provisions of this order with actual

knowledge of its terms is punishable by contempt of court and may be a
criminal offense under RCW 9A.040.060(2) or SA.40.070(2). Violation of
this order may subject a violator to arrest.
When mutual decision making is designated but cannot be achieved, the
parties shall make a good faith effort to resolve the issue through the dispute
resolution process.
If a parent fails to comply with a provision of this plan, the other parent's
obligations under the plan are not affected.
.Judqe/Cornrnlssicner
11
Presented by:
Approved for entry:
12
13
14
W.S.B.A. #
Attorney for Respondent
15
16
17
18
19
20
21
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 12 of 12
Interoffice ff:
Client File: P:\SCPLUS\DAHL\dahl.SCP
08/26/2002 11:41 a.m.
Form: P:\SCPLUS\DAHL\PP.DOC 08/26/2002
11:42 a.m.

1201 PACIFIC AVENUE
TACOMA, WA 98402
{2531 572-4500
(253) 272-5732 FAX
..
8/29/Zfl02 6231
02-3-02768-6
\ 7200368
00010
FNDCLR
1
FILED
2
3
A.M.
AUG 2 8 2002
BY
BOB SAN SOUCIE

COUNTY CLERK
DEPUTY
----.,]r1-' --
5
6
7
8
9

COUNTY OF PIERCE
In re:
02 3 02768 6
DEBORAH J. DAHL
NO.
10
11
Petitioner,
And
JAMES R. DAHL
12
13
14
15
16
FINANCIAL DECLARATION
[X]PETITIONER
[]RESPONDENT
(FNDCLR)
Res ondent.
Name: Deborah J. Dahl
Date of Birth: 07/29/57
I. SUMMARY OF BASIC INFORMATION

Declarant's Total Monthly Net Income (from 3.3 below)
Declarant's Total Monthly Household Expenses (from 5.9 below)
Declarant's Total Monthly Debt Expenses (from 5.11 below)
Declarant's Total Monthly Expenses (from 5.12 below)
Estimate of the other party's gross monthly income (from 3.1g below)
17
18
$2,423.60
[X]
[ ]
$3,295.00
$377.00
$3,672.00
$4,502.00
Unknown
II. PERSONAL INFORMATION

2.1
Occupation: Nurse
19
2.2
The highest year of education completed: 16
20
2.3
Are you presently employed?

[X] Yes
[ ] No
a. If yes:
(1) Where do you work. Employer's name and address must be listed on the
Confidential Information Form.
(2) When did you start work there? (month/year)
21
22
b. If no:
1.
When did you last work? (month/year)
23
2. What were your gross monthly earnings?
24
{3) Why are you presently unemployed?
25
FINANCIAL DECLARATION (FNDCLR - Page 1 of 6)
WPF DR 01.0550 (912001)- RCW 26.18.220 (1)
Firm Name Here

UseFonts and graphics!
SupportCa/c/FD 2002
Click Options/Edit Firm

Customize as desired
P.M.
8/29/2002
6231
1
2
3
4
5
Ill. INCOME INFORMATION

If child support is at issue, complete the Washington State Child Support Worksheet{s), skip
Paragraphs 3.1 and 3.2. If maintenance, fees, costs or debts are at issue and child support is NOT an
issue this entire section should be completed. (Estimate of other party's income information is
optional.)
3.1
7
8
9
10
11
GROSS MONTHLY INCOME.

If you are paid on a weekly basis, multiply your weekly gross pay by 4.3 to determine your
monthly wages and salaries. If you are paid every two weeks, multiply your gross pay by 2.15. If
you are paid twice monthly, multiply your gross pay by 2. If you are paid once a month, list that
amount below.
a.
b.
c.
d.
e.
Imputed Income
Wages and Salaries
Interest and Dividend Income
Business Income
Spousal Maintenance From Other
Relationships
f.
g.
Other Income
Total Gross Monthly Income
(add lines 3.1 a through 3.1e)
Actual Gross Income (Year-to-date)
12
13
14
15
h.
3.2
16
18
19
20
21
3.3
22
Respondent
$2,977.50
$4,502.00
$2,977.50
$4,502.00
MONTHLY DEDUCTIONS FROM GROSS INCOME.

a.
b.
c.
d.
e.
f.
g.
h.
17
Petitioner
Income Taxes
FICA/Self-employment Taxes
State Industrial Insurance Deductions
MANDATORY Union/Professional Dues
Pension Plan Payments
Spousal Maintenance Paid
Normal Business Expenses
Total Deductions from Gross Income
(add lines 3.2a through 3.2g)
MONTHLY NET INCOME. (Line 3.1f minus line 3.2h

.Qt.line 3 from the Child Support Worksheet(s).)
Petitioner
$243.71
$227.78
Respondent
$602.79
$344.40
$22.26
$60.15
$167.00
$553.90
$1,114.19
$2,423.60
$3,387.81
23
24
25
WPF DR 01.0550 (912001)- RCW 26.18.220 (1)
Firm Name Here

SupponCa/c/FD 2002
Use Fonts and graphics!

00011
8/29/2002
3.4
2
3
4
5
6
7
8
9
MISCELLANEOUS INCOME.
a. Child support received from other relationships
Name:
Name:
b. Other miscellaneous income (list source and amounts)
Income of current spouse
Name:
Name:
Income of children
Name:
Name:
Income from assistance programs
Name:
Name:
Non-recurring income
Name:
Name:
Other Income:
Petitioner
6231
Respondent
10
11
12
c.
Total Miscellaneous Income (add lines 3.4a through 3.4b)
3.5
Income of Other Adults in Household

Name:
Name:
3.6
If the income of either party is disputed, state monthly income you believe is correct and
explain below:
17
4.1
4.2
4. 3
18
4.4
Cash on hand
On deposit in banks
Stocks and bonds
Cash value of life insurance
Other liquid assets:
13
14
15
IV. AVAILABLE ASSETS
16
19
20
21
22
23
V. MONTHLY EXPENSE INFORMATION

Monthly expenses for myself and 3 dependents are: (Expenses should be calculated for the future, after
separation, based on the anticipated residential schedule for the children.)
5.1
HOUSING.
Rent, 1st mortgage or contract payments
Installment payments for other mortgages or
encumbrances
Taxes & insurance (if not in monthly payment)
Total Housing
$980.00
$275.00
$1,255.00
24
25
FINANCIAL DECLARATJON(FNDCLR - Page 3 of 6)
WPF DR 01.0550 (912001)- RCW 26.18.220 (1)
Firm Name Here

Suppor1Ca/c/FO 2002

~0612
8/29/2002
~231
00013
8/29/2002
5.8
MISCELLANEOUS EXPENSES
Life insurance (if D.Q1 deducted from income)
Other:
Other:
Total Miscellaneous Expenses
5.9
TOTAL HOUSEHOLD EXPENSES

(The total of Paragraphs 5.1 through 5.8)
5.10 INSTALLMENT DEBTS INCLUDED IN PARAGRAPHS 5.1THROUGH5.8.

Creditor/Description of Debt
Balance
Month of Last Payment
WA Mutual/Home Loan
$147,600.00
August
231
$3,295.00
8
9
10
11
12
13
14
5.11
OTHER DEBTS AND MONTHLY EXPENSES NOT INCLUDED IN PARAGRAPHS 5.1 - 5.8
Month of
Amount of
Balance
Last Payment
Monthly Payment
Healthcare Billing Services
$200.00
August
$50.00
Penneys
$350.00
August
$17.00
Visa Colleague Services
$4,487.22
August
$135.00
Capitol One Mastercard
$896.99
August
$26.00
SLM Financial
$3,000.00
August
$40.00
Chevron
$1,147.27
August
$109.00
15
16
17
18
19
20
21
22
23
24
25
WPF DR 01.0550 (912001)-RCW 26.18.220 (1)
SupportCa/c/FD 2002
Firm Name Here

ClickOptions/Edit Finn
00014
8/29/2002 6231 00015

., ..
1
2
'
Total Monthly Payments for Other Debts and Monthly

Expenses
$377.00
TOTAL EXPENSES (Add Paragraphs 5.9 and 5.11)
$3,672.00
3
VI. ATTORNEY FEES
4
6.1
Amount paid for attorney fees and costs to date:
6.2
The source of this money was: Salary
6.3
Fees and costs incurred to date:
6.4
Arrangements for attorney fees and costs are: Fee Agreement
6.5
Other:
5
6
$1,500.00
9
10
11
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at
on
[Place]
12
13
_
[Date]
Deborah J. Dahl
Declarant/Petitioner
14
The following financial records are being provided to the other party and filed separately with the court:
15
Financial records pertaining to myself:
16
17
18
19
20
21
22
[ ] Individual [] Partnership or Corporate Income Tax returns for

the years:
including all W-2s and schedules;
[]Pay stubs for the dates of
[]Other:
DO NOT ATTACH THESE FINANCIAL RECORDS TO THE FINANCIAL DECLARATION. THESE
FINANCIAL RECORDS SHOULD BE SERVED ON THE OTHER PARTY AND FILED WITH THE
COURT SEPARATELY USING THE SEALED FINANCIAL SOURCE DOCUMENTS COVER SHEET
(WPF DRPSCU 09.0220). IF FILED SEPARATELY USING THE COVER SHEET, THE RECORDS WILL
BE SEALED TO PROTECT YOUR PRIVACY (ALTHOUGH THEY WILL BE AVAILABLE TO THE
OTHER PARTIES IN THE CASE, THEIR ATTORNEYS, AND CERTAIN OTHER INTERESTED
PERSONS. SEE GR 22 (C)(2)).
23
24
25
WPF DR 01.0550 (912001)- RCW 26.18.220 (1)
Firm Name Here

SupportCalc/FD 2002

f>
I hereby declare under penalty of perjury and in accordance with the laws of the State of
Washington that the foregoing is true and correct.
DATED this _tl/ctay
of
!Jvef ,
2002.
4
5
Debbie Dahl
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
-1
DOCUMENTS

A 1TORNEYSATl.A
W
1200 WEU.S FARGO PLAZA
1201 PACIACAVBNUB
TACOMA,WASHINGTON 984-02
PHONE 253.572.4500
FAX 253-2725732
\ET SYNOPSIS
02-3-02768-6
17208370
csw
08-29-02
1. Monthly Net Income

2. Proportional Share of Income
3. Basic Support:
Amanda $671.00
Sarah $543.00
Elizabeth $543.00
4.
TOTAL
MOTHER
$2,423.60
.417
COMBINED
$5,811.41
02 3 02768 6
$11s1.oo
5. Total Basic Support Obligation

6. OBLIGATION for Extraordinary Health
Care, Day Care, and Special Exp.
7.
FATHER
$3,387.81
.583
TOTAL OBLIGATION
$1024.33
$364.46
$732.67
$260.69
$1388.79
$993.36
8. CREDIT for Extraordinary Medical

9. CREDIT for Day Care and Special Exp.
10. CREDIT for Ordinary Expenses
$358.00
11.
TOTAL CREDITS
$358.00
12.
Father Pays Mother
$1757.00
$625.15
$355.00
$355.00
$1030.79
FILED

File Name: Dahl.SCP
Page was printed on 8/27/2002 at 03:00 PM
A.M.
P.M.
BOB SAN SOUCIE
SupportCalc2001-T
CASE ALERT
INCOME EXCEEDS $5000

PRESUMPTIVE AMOUNT: $1550.00
ADVISORY AMOUNT: $1757.00
SupportCa/c2002
AUG 2 8 2002
BY
rp
COUN1
CLERK
DEPUTY
8/29/2002
6231
Washington State Child Support Schedule

Worksheets (CSW)
Mother: Deborah J. Dahl
Coun : PIERCE
02 3 02768 6
Father: James R. Dahl

Su erior Court Number:
Children and Ages: Amanda, 13; Sarah, 10; Elizabeth, 5

Part I: Basic Child Support Obligation (See Instructions, Page 5)
1. Gross Monthly Income
a.
b.
c.
d.
e.
f.
Wa es and Salaries
Business Income
S ousal Maintenance Received
Other Income
add lines 1a throu h 1e
Father
Mother
$4,502.00
$2,977.50
$4,502.00
$2,977.50
$602.79
$344.40
$243.71
$227.78
$167.00
$22.26
$60.15
$1,114.19
$553.90
2. Monthly Deductions from Gross Income

a.
b.
c.
d.
Income Taxes Federal and State

FICA Soc.Sec.+Medicare /Self-Em lo ment Taxes
Mandato Union/Professional Dues
Pension Plan Pa ments
Normal Business Ex enses

h. Total Deductions from Gross Income
add lines 2a throu h 2
line 1f minus 2h
4. Combined Monthly Net Income
(Line 3 amounts combined)
If line 4 is less than $600, ski to line 7.
5. BASIC CHILD SUPPORT OBLIGATION: Combined 7
Amanda
$671.00
Sarah
$543.00
Elizabeth
$543.00
WSCSS-Worksheets (CSW) 9/2000 Page 1 of 5
$5,811.41
$1757.00
Continue to Next Page
00018
8/29/2002
Father
Each arent's net income from line 3 divided b line 4
.7. Each Parent's Basic Child Support Obligation
(Multiply each number on line 6 by line 5)
(If line 4 is less than $600, enter each parent's support
obligation of $25 per child. Number of children: 3
Ski to line 15a and enter this amount.
231
Mother
.583
.417
$1024.33
$732.67
Part II: Health Care, Day Care, and Special Child Rearing Expenses (See Instructions, Page 7)
8. Health Care Ex enses
a. Children's Monthl Health Insurance
$358.00
b. Children's Uninsured Monthl Health Care
c. Total Monthly Health Care Expenses
$358.00
line 8a lus line Sb
d. Combined Monthly Health Care Expenses
add father's and mother's totals from line 8c
$358.00
e. Maximum Ordinary Monthly Health Care
multi I line 5 times .05
$87.85
f. Extraordinary Monthly Health Care Expenses
(line 8d minus line 8e., if "O" or negative, enter "O")
$270.15
a.
$355.00
b.
c.
d.
e. Total Day Care and Special Expenses

Add lines 9a throu h 9d
10. Combined Monthly Total Day Care and Special Expenses
(Combine amounts on line 9e)
11. Total Extraordinary Health Care, Day Care, and Special
Expenses (line Bf plus line 10)
12. Each Parent's Obligation for Extraordinary Health Care,
Day Care, and Special Expenses
$355.00
$355.00
$625.15
$364.46
$260.69
$1388.79
$993.36
Part Ill: Gross Child Support Obligation

Part IV: Child Support Credits (See Instructions, Page 7)
$358.00
b.
d. Total Su ort Credits add lines 14a throu h 14c

$355.00
$358.00
$355.00
88019
B/29/2002
6231
Part V: Standard Calculation/Presumptive Transfer Payment (See Instructions, Page 8)

15. Standard Calculation
Father
Mother
a. Amount from line 7 if line 4 is below
$600. Skip to Part VI.
b. Line 13 minus line 14d, if line 4 is over
$1030.79
$638.36
$600 (see below if aool.)
Limitation standards adjustments
c. Amount on line 15b adjusted to meet 45%
net income limitation
d. Amount on line 15b adjusted to meet
need standard limitation
e. Enter the lowest amount of lines 15b, 15c or 15d:
$1030.79
$638.36
Part VI: Additional Factors for Consideration (See Instructions, Page 8)
16. Household Assets
Father's
Mother's
(Present estimated value of all maier assets.)
Household
Household
a. Real Estate
b. Stocks and Bonds
c. Vehicles
d. Boats
e. Pensions/IRAs/Bank Accounts
f. Cash
o. Insurance Plans
h. Other:
-
17. Household Debt

(list liens against household assets, extraordinary debt.)
a.
b.
c.
d.
e.
f.
18. Other Household Income
a. Income Of Current Spouse
(if not the other oarent of this action)
Name
Name
b. Income of Other Adults in Household
Name
Name
c. Income of Children (if considered extraordinarv)
Name
Name
d. Income from Child Support
Name
Name
.
.
--
00020
8/29/2002
Other Household Income (continued)

e. Income From Assistance Programs
Proqrarn
Program
f. Other Income (describe)
Father's
Household
Mother's
Household
19. Non-Recurrinq Income (describe)
.
20. Child Support Paid For Other Children
Name/age:
Name/age:
6231
.
-
21. Other Children Living In Each Household

(First names and ages)
22. Other Factors For Consideration

Father's income based on 7/22/02 paystub YTD divided by 6.5 months. Taxes: S/3. Medical and
dental credits. Maximum benefit for pension.
Mother's income based on $32. 72 per hour/21 hours a week. Taxes: HH/2. Union dues and
pension contribution deducted
Continueto Next Page
80021
8/29/2002
6231
Other factors for consideration (continued)
Signature and Dates

I declare, under penalty of perjury under the laws of the State of Washington, the information
contained in these Worksheets is complete, true, and correct.
Mother's Signature
Date
Father's Signature
City
Judge/Reviewing Officer
Date
City
Date
Worksheet certified by the State of Washington Administrator for the Courts.

Photocopying of the worksheet is permitted.
WSCSS~Worksheets (CSW) 9/2000 Page 5 of 5
SupportCa/c 2002
00022
ml\l\~IH\~ l\~l~l\ H\ ~~\~
02-3-02766-6
17789932
LTR 10
12-30-02
SUPERIOR COURT
OF THE
. 'ATE OF WASHINGTON
FOR PIERCE COUNTY
(253) 798-3654
FAX (253) 798-7214
December 27, 2002
534 County-City Building

930 Tacoma Avenue South
Tacoma, Washington 98402-2102
IN COUNrf b~~R~'S OFFICE
P. CRAIG BEETHAM
ATIORNEYAT LAW
WELLS FARGO PLAZA
1201 Pacific Ave Ste 1200
TACOMA, WA 98402-4395
Re: DEBORAH J DAHL VS. JAMES R DAHL

Pierce County Superior Court Cause N0.:02-3-02768-6
Dear P. CRAIG BEETHAM;
Judge D. GARY STEINER Department 10, of Pierce County Superior Court is on recess Friday, January 3,
2003.
Therefore, the motion and/or assignment you have noted in the above matter for Friday, January 3, 2003,
has been set over for hearing on Friday, January 10, 2003 at 9:00 AM.
It is up to you as moving counsel to notify all other attorneys involved in this motion and/or
assignment.
All motions must be confirmed by the moving party no later than 12:00 Noon two court days prior to the
hearing pursuant to PCLR 7(a)(5).
Thank you.
OFFICE OF SUPERIOR COURT
cc: Pierce County Clerk for Filing
S/29/2002
02-3-02768-6
17208377
DCSPP
6231
03e3s
08-29-02
1
FILED
IN COUNTYCLERK'S OFF CE
PIERCE COUNTY, WASHING ON
AM.
AUG 2 8 2002
.M.
SAN SOUCIE
L BOB
COUNTY CLERK
BY~
DE UTY
6
7

COUNTY OF PIERCE
02 3 02768 6
9
NO.
DEBORAH J. DAHL
DECLARATION IN SUPPORT
OF PARENTING PLAN
(DCLR)
10
11
Petitioner,
and
12
JAMES R. DAHL
13
Respondent.
14
(COMPLETE A SEPARATE FORM FOR EACH CHILD IF NECESSARY)
15
This declaration is made by the mother.
16
1 .
17
The children have resided with the following persons during the past
twelve months:
18
Length of Time
Child Resided With
This Person
19
Name
20
Deborah Dahl
James Dahl
Birth+
Birth+
DEC. RE PROPOSED TEMP. PLAN

WPF DR 04.0120 (9/2001)
RCW 26. 09. 194( 1)
Page 1 of 4
21
22
23
24
25

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 FAX
3/29/2802
2.
(a)
6231
80036
The mother's performance of parenting functions relating to the

daily needs of the children during the past twelve months:
2
3
4
5
Mother performed all of the parenting functions including grooming,

preparing meals, homework, reading, taking to doctor and dentist
appointments, attending parent teacher conferences, volunteering once a
week in children's classrooms, field trips and other activities, Vice President
of PTA, coached sports, took them to park or beach, and had an annual trip
to Spokane for a family reunion.
6
7
8
(b)
The mother's work schedule for the past twelve months:
I worked on-call, opposite shifts as Father, until February 19, 2002. At

that point, I took a permanent position and now work 21 hours per week. I
also pick up on-call shifts on a weekly basis.
10
11
12
(c)
The mother's current work schedule:
7 days on/7 days off from 7:30 a.m. - 2:00 p.m. My on-call is flexible
and I work it around the children's schedules.
13
14
3.
(a)
15
The father's performance of parenting functions relating to the

Father was available for the children in the evenings when I worked.
Even so, the eldest pretty much took care of the younger two with grooming,
homework and preparing meals during this time. Father will occassionally
17 take them out on the boat on hot days and let them play on the beach.
16
18
(b)
19
20
The father's work schedule for the past twelve months:
Monday - Friday flexible hours but consistently 1 0-1 2 hour shifts.

states that he is "on-call" twenty-four hours a day.
He
21
22
(c)
The father's current work schedule:
23
Same.
24
25
WPF DR 04.0120 (9/2001)
RCW 26.09.194(1)
Page 2 of 4
f'Orml +/l'/UI
l0.1

1201 PACIFIC AVENUE
TACOMA, WA 98402
(2531 572-4500
12531 272-5732 FAX
8/29/2002
(a)
4.
Until February 19, 2002, I was home during the day and most
evenings. I did work approximately two evenings a week which at that time
Father was home.
6231
0003?
The child-care schedule for the past twelve months:
4
5
6
7
8
(b)
The current child-care schedule:
Since February 19, 2002 through present, the youngest has been in
preschool at Multicare daycare center while I have been at work. The two
older children have been at home. My parents have been in town this summer
to watch the children when necessary. Once school commences in
September, friends and neighbors have been arranaged to watch the children.
5.
Any circumstances under RCW 26.09.191 that are likely to pose a

serious risk to the children and that warrant limitation on the award to
a parent of temporary residence or time with the children pending
entry of a permanent parenting plan are set forth in Part II of my
proposed temporary parenting plan.
6.
OTHER:
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
DEC. RE PROPOSEDTEMP. PLAN

WPF DR 04.0120 (9/2001)
RCW 26.09.194(1)
Page 3 of 4
Form1+Plu1
10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 5724500
(253) 272-5732 FAX
..
B/29/2002
1
2
623_
DA TED this
?i} day of
!Iv~ ,
2002.
4
5
Debbie Dahl
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
- 1
DOCUMENTS

AITORNEYSAT-1.AW
1200 WEU_<; FARGO PLAZA
1201 PACIFIC AVENUE
TACOMA, WASHINGTON98402
PHONE 2S3-S72-4SOO
FAX 253272-5732
00038
8/29/2a02
02-3-02768-6
17208382
MTAF
6231
00039
08-29-02
Fl LE 0
AM.
AUG 2 8
BOB SAN SOUCIE
BY
zooz
P.M.
COUNTY CLERK
DEPUTY
6
7

COUNTY OF PIERCE
02 3 02768 6
9
NO.
DEBORAH J. DAHL
MOTION AND DECLARATION

FOR TEMPORARY ORDER
(MTAF)
10
11
Petitioner,
and
12
JAMES R. DAHL
13
Respondent.
14
I. MOTION
15
16
Based on the declaration below, the undersigned moves the court for a
temporary order which:
17
Orders child support as determined pursuant to the Washington

State Support Schedule.
18
Approves the parenting plan which is proposed by the wife.
19
Restrains or enjoins both parties from transferring, removing,
encumbering, concealing or in any way disposing of any
property except in the usual course of business or for the
necessities of life and requiring each party to notify the other of
any extraordinary expenditures made after the order is issued.
20
21
22
Restrains or enjoins both parties from assigning, transferring,

borrowing, lapsing, surrendering or changing entitlement of any
insurance policies of either or both parties whether medical,
health, life or auto insurance.
23
24
25
MOT\DEC FOR TEMP ORDER

WPF DR 04.0100 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 1 of 5
FormsPlua
10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(2531 572-4500
(2531 272-5732 FAX
0/29/2002
&231
00040
Makes each party immediately responsible for their own future

debts whether incurred by credit card or loan, security interest
or mortgage.
3
Divides responsibility for the debts of the parties.
4
To Husband:
5
1.
6
2.
3.
7
8
9
4.
5.
6.
7.
8.
Seafirst Visa
Seafirst Business Visa
Capital One Mastercard
Westop Credit Union Loan
Rainier Pacific Boat Loan
PLC Washington Mutual
PRA Columbia Bank
Mortgage/utilities/taxes on 25812 120th
Lane SW
10
To Wife:
11
1.
12
2.
3.
13
4.
5.
14
6.
7.
15
16
Multicare Healthcare Billing Services

J.C. Penneys
Colleague Services Corp. Visa
Capital One Business Mastercard
SLM Financial
Chevron
Mortgage/utilities/taxes on 916 Manor
Drive
Rental mortgage on 228 Contra Costa to be paid

from proceeds from rents per status quo.
17
Authorizes the family home to be occupied by the wife.
18
Orders the use of property.
19
To Husband:
20
1.
21
2.
3.
22
4.
23
5.
2581 2 1 20th Lane SW Real Property

1982 Chevrolet Truck
2002 Seaswirl Boat
Household goods and furnishings currently
located at 2581 2 1 20th Lane SW
Personal items and clothing
24
25
WPF DR 04.0100 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 2 of 5

1201 PACIFIC AVENUE
TACOMA, WA 98402
{253) 572-4500
{253) 272-5732 FAX
8/29/Z002
6231
00041
To Wife:
1.
2.
3.
4.
5
6
The real property at 228 Contra Costa shall

remain and be operated status quo as rental
property.
Requires the husband to vacate the family home.
Requires the husband to pay temporary attorney's fees, other

professional fees and costs in the amount of $2,000.00 to:
Eisenhower & Carlson, PLLC.
916 Manor Drive Real Property

2001 Chevrolet Tahoe
located at 916 Manor Drive
10
11
Dated:
12
13
14
II. DECLARATION
15 Temporary relief is required because:

16
17
18
19
20
21
22
23
24
Use of Property. Respondent and I own three homes, the main Fircrest
home, a Fircrest rental and a beach home. Since I am asking to be the
children's primary caretaker, I would request that I remain in the family home
and Respondent move to the beach home. The family home has the children's
bedrooms and is in their school district and around their friends. The
separation of their parents will be stressful enough but with school starting in
just a week, I respectfully request that the girls not be uprooted at this
vulnerable time in their lives. Respondent should be quite comfortable in the
beach home during the pendency of this matter and I would ask that he
vacate the family home as soon as possible, either before or at the time of this
hearing, to ease any tension that may occur. The rental home is currently
rented and the rent collected covers the mortgage and expenses for that
property.
History of Work Schedules and Involvement with Children. Respondent
and I have three daughters, ages 13, 10 and 5. Throughout our marriage, I
have always been the girls' primary caretaker. I worked on call for Multicare
until l took a permanent position at Group Health in February, 2002. When I
25
WPF DR 04.0100 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 3 of 5

1201 PACIFIC AVENUE
TACOMA, WA 98402
(2531 572-4500
{253) 272-5732 FAX
8/29~2002
3
4
5
6
7
6231
00042
worked on call I would be sure to work opposite my husband's hours to

ensure that there was an adult at home with the children. This was usually on
weekends, evenings or nights after the girls were asleep. We mutually made
this decision as we believed it would benefit the children to not have to be
subjected to daycare. Even though Respondent was home with the girls, the
oldest, Amanda, would take care of the younger two by making sure they
were fed and did their homework while Respondent worked on his computer
or fell asleep. I now have a permanent position with Group Health where I
work seven days on and seven days off from approximately 7:30 a.m. - 2:00
p.m. This allows me to be home with the children when they need me before
and after school. I also picked up on-call shifts with Multicare which allowed
me to keep a steady stream of needed income. These on-call shifts were
flexible which I worked around the children's schedules.
Respondent works 1 0-1 2 hour shifts Monday through Friday. He has
always advised me, however, that he is on call twenty four hours a day.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
I feel that I have a great relationship with all of my children. I make

sure that I am with them in all of their activities. I have coached softball,
basketball and t-ball. We play together, eat together, learn together and talk
together. The girls confide in me and I feel that we have an extremely strong
bond which can only help once they start entering their teenage years.
Respondent is distant with the girls. He yells at them quite often which they
have confided in me that it makes them uncomfortable. He gets angry with
them and myself on almost a daily basis. Just recently he kicked a ball out of
Amanda's hands and broke a vase. He rarely attends school functions or
sporting events. He does not help them with homework or special school
projects. The only activity that Respondent will do with the girls is take them
out on the boat and while they play on shore he will anchor out in the water
and sit on the boat listening to music. He chooses not to have any interaction
with them where on the other hand they are my entire livelihood and focus.
Parentin Plan Restrictions. I have asked that there be restrictions in
the Parenting Plan wit regar to Respondent's visitation with the children.
Respondent has a history of alcohol abuse with a DWI just last December and
continued rehabilitation/counseling. I am not sure that he is "cured" of his
disease. There are times when Respondent will leave for the evening or just
doesn't come home from work without letting me know where he is. In the
past, he has come home between 2:00 and 3:00 a.m. and slept out in his
truck or he doesn't come home at all until the following day. Respondent
does not show genuine interest in the girls day-to-day activities or events.
When he is with them, he allows them to do whatever they want while he
sleeps or works on his computer. I have called the girls from work and the
oldest two will tell me that they had to cook dinner themselves and put the
youngest to bed. He does not take them to the park or play soccer/basketball
with them which is what they enjoy. I need to know that they are safe and
being taken care of while with Respondent and because of these patterns
topped off with his alcohol abuse, I am not sure that this would happen.
WPF DR 04.0100 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 4 of 5

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(2531 272-5732 FAX
8/29/2002
..
6231
00043
Child Su~port. I only had access to one of Respondent's recent

paystubs whic went through mid-July, 2002. I calculated his gross income
2 based on the YTD on that stub and gave him credit for the mandatory pension
allowance of $167 per month although it seems as if he puts closer to
3 $600.00 per month into his plan. Respondent also receives a credit for
medical and dental premiums that he pays monthly for the children. Taxes
4 were calculated Single, with three exemptions. I calculated my income using
my hourly of $32. 72 for 21 hour work weeks at Group Health. I allowed
5 myself the deduction for my monthly union dues and the $60.00 per month
that I contribute towards my pension. I did not take into consideration my
6 Multicare income as it is an elective income for "on-call" shifts which are
usually in the evening and into the night. I will not be able to take on as
7 many, if any at all, of these shifts due to now becoming a single mother of
one teenage and two pre-teen girls. For example, I do not have any
8 scheduled shifts with Multicare for September. Taxes were calculated Head
of Household, with two exemptions. Our two youngest will be in before
9 school care on the days that I have to work. This will be approximately
$150.00 per month. Our youngest child will be in all day kindergarten which
10 is an additional cost of $205.00 per month. This is only for the upcoming
school year. The transfer payment from Father shall be $1,030.00 per
11 month.
12
Division of Debts. Respondent and I have kept separate accounts and

paid separate liabilities for some time now. I would just request that this
13 remain status quo and become part of the Temporary Order. Since I have
requested to stay in the family home, I will continue to pay the mortgage and
14 other expenses on that property and Husband will pay likewise on the beach
home where he may reside.
15
Attorney's Fees. I have paid my attorney $1, 500.00 for his retainer fee
16 so far. I paid this money from my personal earnings. I request that Husband
be ordered to pay another $2,000.00 for the initial filing of this matter and the
17 need for the temporary hearing.
18
Conclusion. I respectfully request the Court to adopt my Parenting Plan

based on the pattern of care over the last twelve months and Respondent's
19 continuous alcohol abuse; adopt my proposed child support worksheets; enter
a Temporary Order dividing the property and debts as requested; order
20 Husband to vacate the family home, if he has not voluntarily done so by the
time of the hearing, no later than twenty-four hours after the hearing date;
21 and order the payment of attorney's fees by Respondent.
22
23
24
25
WPF DR 04.0100 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 5 of 5
Interoffice n:
Client File: P:\SCPLUS\DAHL\dahl.SCP OB/2?/2002 03:07 p.m.
Form: P:\SCPLUS\DAHL\MOTIONTO.DOC 06/27/2002 03:07 p.m.
rorrn1 Pl.u~ 10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(2531 272-5732 FAX
8/29/20@2
6231
DATEDthis~ayof
~r
, 2002.
4
5
Debbie Dahl
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
-I
DOCUMENTS

AlTORNEYS-AT-LAW
1201 PACIACAVENUE
PHONE 253-572-4500
FAX 253-272-5732
00044
9/1,&1'2082
6G83
FILED

A.M.
BY
5
BOB SAN SOUCIE

COUNTY CLERK
DEPUTY
NO. 02-3-02768-6
DEBORAH DAHL,
NOTICE OF APPEARANCE ON
BEHALF OF RESPONDENT
Petitioner,
10
P.M.
SUPERIOR COURT OF WASHINGTONFOR PIERCE COUNTY
6
7
SEP 1 2 2002
v.
JAMES DAHL,
11
Respondent.
12
TO:
DEBORAH DAHL, Respondent, and
TO:
P. CRAIG BEETHAM, her attorney.
13
14
PLEASE TAKE NOTICE that the appearance of the respondent, JAMES
15
DAHL is entered in the above-entitled action through the undersigned attorneys.
16
You are hereby requested that all further pleadings or other process herein be
17
served upon said attorneys at the office address below stated.
18
DATED this
\ _'_dayof September, 2002.
19
KRILICH, LA PORTE, WEST
20
21
By:
Richard W. Lockner, WSB #19664

22
23
Notice of Appearance - l
K rilich, La Pone,
West & Lockner, P.S.
Tacoma, Washington 98402
(253) 383-4704
ORIGf N/\L
00174
9/27/2002
02-3-02768-6
17348897
ACSR
6998
~~zaz
09-27-02
2
IN
f;
IL
eD
COUNTY CLERK'S 0
FFCE
2 6 2002
PIERCE COUNT
i~s
SAN souc1l
A.M.
$t:p
I;
5
6
7

COUNTY OF PIERCE
8
9
N0.02-3-02768-6
DEBORAH J. DAHL
Petitioner,
and
ACCEPTANCE OF SERVICE
(ACSR)
10
11
12
JAMES R. DAHL
13
14
15
Respondent.
,.
ACCEPTANCE OF SERVICE.
RICHARD LOCKNER, on behalf of Respondent, JAMES R. DAHL,
accepts service of:
16
17
The summons and petition, motion and declaration for

temporary order, proposed parenting plan, declaration in
support of proposed parenting plan, proposed child support
worksheets, financial declaration and sealed financial
declaration in this action.
18
19
20
2.
CONSENT TO PERSONAL JURISDICTION.
21
Does not apply.
22
3.
OTHER:
23
24
Dated:
25
ACCEPTANCE OF SERVICE
WPF DR 01.0310 {9/2001)
RCW 26.09.030(1)
Page 1 of 2
Interoffice ff:
Form: P:\SCPLUS\DAHL\ACCEPTAN.DOC
f'atms Plua
10. 7
09/10/2002
01:25 p.m.
09/10/2002
01:25 p.m.

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 FAX
10102
02-3-02768-6
17562957
COPC
11/12/200
11-07-02
FI LED
IN COUNT'V CLERK'S OrrlCE
2
A.M.
NOV 0 7 2002
U
P.M.
GION
CLERK
oHUTY
5
6
7

IN AND FOR THE COUNTY OF PIERCE
8
9
NO. 02-3-02768-6
DEBORAH DAHL,
10
11
12
Petitioner,
vs.
PETITIONER'S CERTIFICATE OF
COMPLETION OF MANDA TORY
PARENTING SEMINAR
JAMES DAHL,
13
Res ondent.
14
15
16
17
18
19
20
21
22
23
24
25
26
PETITIONER'S CERTIFICATE OF COMPLETION OF

MANDATORY PARENTING SEMINAR - I
00237567.DOC

ATTORNEYS-ATLAW
1201 PACIFIC AVENUE
TACOMA, WASHINGTON 98402
PHONE 253-572-4500
FAX 253-272-5732
008&2
18102
Court Cause Number:
1~/12/2802
08863
--------m
THIS CERTIFIES THAT
Has successfully completed the four-hour class,
What Children of Divorce Really Need

Presented by Lesa Swanson, MS. W. and Richard Macleod, MS. W.
Dated this
.23rd Dayof .Sl fflntlcttJ002
'
Lesa Swanson, M.S. W.
Location: Mary Bridge Children
'.or Health
Center
at the City a/Tacoma, State of Washington.
1/8/2083
18311
08123
.ouar OF THE STATE OF WASHINGTON

02-3-02768-6
1 8251604
ND FOR PIERCE COUNTY

ORSCS
01-08-03
FILED
IN OPEN COURT
DEBORAH J DAHL
Petitioner(s)
No. 02-3-02768-
~o
0RDER SETTI G
CASE SCHEDU E
JAN - 7 2003
vs.
Pierce C~tperk
~drv
Type of Case:
DIC
ay .....
Track Assignment:
Dissolution
Assigned Department: 10 - JudgeD. Gary Ste
Docket Code:
ORSCS
JAMES R DAHL
Respondent(s)
Confirmation of Service
04/28/03
Status Conference (Contact Court for Specific Date)
Week Of 07/14/03
Obtain Settlement Cont Judge/Comm from Commissioners' Services& Contact Assigned Dept
Week Of 07/14/03
Plaintiff's Disclosure of Primary Witnesses
07128103
Defendant's Disclosure of Primary Witnesses
08/25/03
Disclosure of Rebuttal Witnesses
09/15/03
Deadline for Filing Motion to Adjust Trial Date
09/29/03
Discovery Cutoff
11/03/03
Joint Statement of Evidence
11/17/03
Exchange of Witness and Exhibit Lists and Documentary Exhibits
11/17/03
Settlement Conference (To be held)
Week Of 12/01/03
Pretrial Conference (Contact Court for Specific Date)
Week Of 12/08/03
Trial
12/15/03 9:30
NOTICE TO PLAINTIFF/PETITIONER
If the case has been filed, the plaintiff shall serve a copy of the Case Schedule on the defendant(s) with the summons and
complaint/petition: Provided that in those cases where service is by publication the plaintiff shall serve the Case Schedule
within five (5) court days of service of the defendant's first response/appearance. If the case has not been filed, but an
initial pleading is served, the Case Schedule shall be served within five (5) court days of filing. See PCLR 1.
NOTICE TO ALL PARTIES
Alt attorneys and parties shall make themselves familiar with the Pierce County Local Rules, particularly those relating to
case scheduling. Compliance with the scheduling rules is mandatory and failure to comply shall result in sanctions
appropriate to the violation. If a statement of arbitrability is filed, PCLR 1 does not apply while the case is in arbitration.
117/03
DATED:
Judge D. Gary Steiner

Department 10 (253) 798-7572
II l 11! 111111111
02-3-02768-6
18541395
FNDCLR
03-04-03
2
3
4
5
6
7
8
9

COUNTY OF PIERCE
In re:
DEBORAH J. DAHL
NO. 02-3-02768-6
10
11
Petitioner,
And
JAMES R. DAHL
12
13
Res ondent.
Name: Deborah J. Dahl
14
15
16
[X]PETITIONER
[]RESPONDENT
(FNDCLR)
Date of Birth: 07/29/57

Declarant's
Declarant's
Declarant's
Declarant's
Estimate of
Total Monthly Net Income (from 3.3 below)

Total Monthly Household Expenses (from 5.9 below)
Total Monthly Debt Expenses (from 5.11 below)
Total Monthly Expenses (from 5.12 below)
the other party's gross monthly income (from 3.1 g below)
17
[X]
[ ]
$3,350.89
$3,695.00
$310.00
$4,005.00
$2,166.70
Unknown
18
2.1
Occupation:
19
2.2
The highest year of education completed:
20
2.3
Are you presently employed?

[X] Yes
[ ] No
a. If yes:
(1) Where do you work. Employer's name and address must be listed on the
Confidential Information Form.
(2) When did you start work there? (month/year}
21
22
b. If no:
Nurse
16
1.
When did you last work? (month/year)
23
2.
What were your gross monthly earnings?
24
(3) Why are you presently unemployed?
25
WPF DR 01.0550 (912001) - RCW 26.18.220 (1)
EISENHOWER & CARI.SON,
PLLC
SupportCa/c/FD 2002

1201 PACIFIC AVENUE
TACOMA, WA98402
3
4
5
6
If child support is at issue, complete the Washington State Child Support Worksheet(s}, skip
Paragraphs 3.1 and 3.2. If maintenance, fees, costs or debts are at issue and child support is NOT an
issue this entire section should be completed. (Estimate of other party's income information is
optional.}
3.1
7
8
9
10
11
GROSS MONTHLY INCOME.

If you are paid on a weekly basis, multiply your weekly gross pay by 4.3 to determine your
monthly wages and salaries. If you are paid every two weeks, multiply your gross pay by 2.15. If
you are paid twice monthly, multiply your gross pay by 2. If you are paid once a month, list that
amount below.
a.
b.
c.
d.
e.
Imputed Income
Wages and Salaries
Business Income
Spousal Maintenance From Other
Relationships
f.
g.
Other Income
(add lines 3.1a through 3.1e)
Actual Gross Income (Year-to-date)
12
13
14
15
h.
3.2
16
18
19
20
21
3.3
22
Respondent
$4,021.30
$2, 166.70
$4,021.30
$2,166.70
Petitioner
$362.78
$307.63
Respondent
$166.25
$165.75
$670.41
$332.00
$3,350.89
$1,834.70
MONTHLY DEDUCTIONS FROM GROSS INCOME.

a.
b.
c.
d.
e.
f.
g.
h.
17
Petitioner
Income Taxes
FICNSelf-employment Taxes
MANDATORY Union/Professional Dues
Spousal Maintenance Paid
Normal Business Expenses
Total Deductions from Gross Income
(add lines 3.2a through 3.2g}
MONTHLY NET INCOME. (Line 3.1f minus line 3.2h

QLline 3 from the Child Support Worksheet{s).)
23
24
25
WPF DR 01.0550 (912001)- RCW 26.18.220 (1)
SupportCa/c/FD 2002
EISENHOWER & CARISON,

PLLC
1201 PACIFIC A VENUE
TACOl\tlA, WA98402
13647
3.4
3
4
5
6
7
8
9
MISCELLANEOUS INCOME.
Name:
Name:
b.
Other miscellaneous income (list source and amounts)
Income of current spouse
Name:
Name:
Income of children
Name:
Name:
Income from assistance programs
Name:
Name:
Non-recurring income
Name:
Name:
Other Income:
Petitioner
3/4/2003
00040
Respondent
10
11
12
c.
Total Miscellaneous Income
(add lines 3.4a through 3.4b)
3.5
Income of Other Adults in Household

Name:
Name:
3.6
If the income of either party is disputed, state monthly income you believe is correct and
explain below:
16
4.1
4.2
17
4.3
18
4.4
Cash on hand
On deposit in banks
Stocks and bonds
Cash value of life insurance
Other liquid assets:
13
14
15
19
20
21
22
23

Monthly expenses for myself and 3 dependents are: (Expenses should be calculated for the future, after
separation, based on the anticipated residential schedule for the children.)
5.1
HOUSING.
Installment payments for other mortgages or
encumbrances
Taxes & insurance (if not in monthly payment)
Total Housing
$980.00
$275.00
$1,255.00
24
25
WPF DR 01.0550 (912001) - RCW 26.18.220 (1)
PLLC
1201 PACIFIC AVENUE
SupportCalcJFO
2002
TACOMA, WA98402
5.2
2
3
4
UTILITIES.
Heat (gas & oil)
Electricity
Water, sewer, garbage
Telephone
Cable
Other: Cell
Total Utilities
$80.00
$80.00
$125.00
$60.00
$40.00
$385.00
5
6
5.3
7
8
9
5.4
10
11
12
5.5
13
14
15
16
5.6
17
18
19
20
21
22
5.7
FOOD AND SUPPLIES

Food for 4 persons
Supplies (paper, tobacco, pets)
Meals eaten out
Other:
Total Food Supplies
CHILDREN.
Day Care/Babysitting
Clothing
Tuition (if any)
Other child related expenses
Total Expenses Children
TRANSPORTATION.
Vehicle payments or leases
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
Parking
Other transportation expenses
Total Transportation
HEAL TH CARE. (Omit if fully covered)
Insurance
Uninsured dental, orthodontic, medical, eye
care expenses
Other uninsured health expenses
Total Health Care
PERSONAL EXPENSES (Not including children).
Clothing
Hair care/personal care expenses
Clubs and recreation
Education
Books, newspapers. magazines, photos
Gifts
Other:
Total Personal Expenses
$500.00
$50.00
$550.00
$400.00
$200.00
$205.00
$805.00
$85.00
$140.00
$225.00
$250.00
$250.00
$100.00
$50.00
$25.00
$50.00
$225.00
23
24
25
WPF DR 01.0550 (912001)- RCW 26.18.220 (1)
EISENHOWER & CARLSON,
PLLC
SupportCa/c/F D 2002

1201 PACIFIC AVENUE
TACOMA, WA 98402
5.8
Life insurance (if not deducted from income)
Other:
Other:
5.9
TOTAL HOUSEHOLD EXPENSES

(The total of Paragraphs 5.1 through 5.8)
5.10 INSTALLMENT DEBTS INCLUDED IN PARAGRAPHS 5.1 THROUGH 5.8.

Balance
Month of Last Payment
WA Mutual/Home Loan
$147,600.00
current
2
3
$3,695.00
7
8
9
10
11
12
13
14
5.11
OTHER DEBTS AND MONTHLY EXPENSES NOT INCLUDED IN PARAGRAPHS 5.1 - 5.8
Month of
Amount of
Balance
Last Payment
Monthly Payment
Healthcare Billing Services
Penneys
Visa Colleague Services
$4,600.00
Current
$135.00
Capitol One Mastercard
$1,400.00
Current
$26.00
SLM Financial
$2,800.00
Current
$40.00
$1,000.00
Chevron
Current
$109.00
15
16
17
18
19
20
21
22
23
24
25
WPF DR 01.0550 (912001) - RCW 26.18.220 (1)
PLLC
SupportCalc/FO 2002

1201 PACIFIC AVENUE
TACOMA, WA98402
Total Monthly Payments for Other Debts and Monthly

Expenses
$310.00
TOTAL EXPENSES {Add Paragraphs 5.9 and 5.11)
$4,005.00
3
VI. ATTORNEY FEES
4
6.1
Amount paid for attorney fees and costs to date:
6.2
The source of this money was: Salary
6.3
Fees and costs incurred to date:
6.4
Arrangements for attorney fees and costs are: Fee Agreement
6.5
Other:
$2,070.00
$2,880.00
9
10
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
11
Signed at
on
[Place]
12
13
_
[Date]
Deborah J. Dahl
Deela rant/Petitioner
14
The following financial records are being provided to the other party and filed separately with the court:
15
Financial records pertaining to myself:
16
17
18
[] Individual [] Partnership or Corporate Income Tax returns for

the years:
including all W-2s and schedules;
[] Pay stubs for the dates of
[]Other:
19
20
21
22
DO NOT ATTACH THESE FINANCIAL RECORDS TO THE FINANCIAL DECLARATION. THESE

FINANCIAL RECORDS SHOULD BE SERVED ON THE OTHER PARTY AND FILED WITH THE
COURT SEPARATELY USING THE SEALED FINANCIAL SOURCE DOCUMENTS COVER SHEET
(WPF DRPSCU 09.0220). IF FILED SEPARATELY USING THE COVER SHEET, THE RECORDS WILL
BE SEALED TO PROTECT YOUR PRIVACY (ALTHOUGH THEY WILL BE AVAILABLE TO THE
OTHER PARTIES IN THE CASE, THEIR ATTORNEYS, AND CERTAIN OTHER INTERESTED
PERSONS. SEE GR 22 (C)(2)).
23
24
25
WPF DR 01.0550 (912001)- RCW 26.18.220 (1)
EISENHOWER & CARLSON,
PLLC
SupportCa/c/FD 2002

1201 PACIFIC AVENUE
TACOMA, WA98402
13647
3/4/2003
2
DA TED this
1J( day of h~~4
, 2003, at Tacoma,
Washington.
3
4
De~l)Mf
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
- 1
DOCUMENTS

ATTORNEYS-AT-LAW
1201 PAC!F[C A.VENUE
TACOMA, WASIIlNGTON 98402
PHONE 253-572-4500
FAX 253-272-57J2
80044
,
...
02-3-02768-6
18716993
TMO
04-04-03
IN couNrf
A.M.
b'tirPK'S OFFICE
APR .. '
P.M.
6
7

COUNTY OF PIERCE
8
9
)
)
DEBORAH J. DAHL
10
11
Petitioner,
and
12
JAMES R. DAHL
13
14
Respondent.
)
)
)
)
)
NO. 02-3-02768-6
AGREED
TEMPORARY ORDER
(TMO)
~~~~~~~~~~~~~~~)
I. JUDGMENT/ORDER SUMMARIES
15
1. 1
Restraining Order Summary:
16
Does not apply.
17
1 .2
Money Judgment Summary:
18
Does not apply.
19
20
II. BASIS
21
A motion for a temporary order was presented to this court and the court
finds reasonable cause to issue the order.
22
23
24
25
TEMPORARY ORDER
WPF DR 04.0250 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 1 of 4
Eisenhower and Carlson, PLLC
;.--,, -,~r--'i'\Form=-+Plu.s 10. 7
V f ,_ 0; ~ ! ,~~
!
Wells Fargo Plaza

1201 Pacific Avenue, Suite 1200
(253) 572-4500 Phone
(253) 272-5732
Ill. ORDER
It is ORDEREDthat:
3.1
5
6
RESTRAINING ORDER.
Does not apply.
3.2
TEMPORARY RELIEF
Child support shall be paid in accordance with the order of child
support, signed by the court.
8
9
10
11
12
13
The parties shall comply with the Temporary Parenting Plan

signed by the court.
Both parties are restrained and enjoined from transferring,
removing, encumbering, concealing, or in any way disposing of
any property except in the usual course of business or for the
any extraordinary expenditures made after the order is issued;
Both parties are restrained and enjoined from assigning,
transferring, borrowing, lapsing, surrendering, or changing
entitlements of any insurance policies of either or both parties
whether medical, health, life or auto insurance.
14
15
Each party shall be immediately responsible for their own future

or mortgage.
16
Responsibility for the debts of the parties is divided as follows:
17
To Husband:
18
19
20
21
22
1.
2.
3.
4.
5.
6.
7.
8.
Seafirst Visa
PRA Columbia Bank
Mortgage/utilities/taxes on 25812 120th
Lane SW
23
To Wife:
24
25
1.
2.

J.C. Penneys
TEMPORARY ORDER
WPF DR 04.0250 (9/2001)
RCW 26.09.060; .11 O; .120; .194
Page 2 of 4

Wells Fargo Plaza
{253) 572-4500 Phone
(253) 272-5732
3.
4.
5.
6.
7.
8.
9.
1
2
3
4

SLM Financial
Chevron
Old Navy
Multicare Daycare Owing for Elizabeth
Mortgage/utilities/taxes on 91 6 Manor
Drive
5
6
7
The family home shall be occupied by the wife.
Use of property shall be as follows:
To Husband:
10
1.
2.
3.
4.
11
2581 2 1 20th Lane SW Real Property

2002 Seaswirl Boat
located at 2581 2 1 20th Lane SW
12
5.
t)
13
l,
14
~?-77C__$
$""-;-)" /;/~
77ftr /7l"E
b@>r ~L-L--~C?-;7~ -15

~L!:P,.7 /fry) <cs ,r-,;--p 2~
15
j-u~1.-vG
16
17
~~GJ>
18
t?F
19
J1
20
/(-5
/7% ~770/
~4"'~
1'9-A/::::1Jvd,c7i?~~
=..2/J/eM;-
/f.L-LRC~-Zlhf./ ~
/-z:>
~?r<
21
~
22
23
24
25
TEMPORARY ORDER
WPF DR 04.0250 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 3 of 4
Forma+~/us
10.7

Wells Fargo Plaza
1201 Pacific Avenue, Suite 1 200
(253) 572-4500 Phone
(253) 272-5732
..
1
To Wife:
2
3
1.
2.
3.
4.

property.
916 Manor Drive Real Property

located at 91 6 Manor Drive
7
The issue of husband paying temporary attorney's fees, other
professional fees and costs to Eisenhower & Carlson, PLLC is
reserved.
8
9
OTHER:
10
Orders the rental property at 228 Contra Costa,
Fircrest, WA to remain status quo until further order
of the Court or upon mutual agreement of the parties
to refinanc~n order to eliminate community debt.
11
12
~~~C....7/>JV~/f'_..4z:A,~~
13
3.3
BOND OR SECURITY.
14
Does not apply.
IN
15
16 3.4
OTHER:
couNrib1rJ&s
A.M.
APR ., 3 2003
N
17
OFFI E
~~~Es~i~K,
ASHl~G
NTY JP ~
18
19
Dated:
20
LJ. '3 03
~-'-~~~~~~
~~-C)._
JUaQeJornmissioner
X. Mdafl7f:/v\.
~
21
Presented by:
22
Approved for entry:

N
resentation waived:
23
24
25
TEMPORARY ORDER
WPF DR 04.0250 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 4 of 4
Interoffice#:
Client File: P:\SCPLUS\DAHL\DAHL.SCP
04/01/2003
10:59
Form: P:\SCPLUS\PAHL\TO.DOC
04/01/2003
10:59 a.m.
Forms+,lus
10. 7
a.m.
Wells Fargo Plaza

(253) 572-4500 Phone
(2531 272-5732
02-3-02768-6
18541397
csw
03-04-03

Worksheets (CSW)
county: PIERCE

S upenor COU rtN um ber: 02-3-02768-6
Children and Ages: Amanda, 13; Sarah, 10; Elizabeth,6

a.
b.
c.
d.
e.
f.
Father
Waqes and Salaries

Business Income
Spousal Maintenance Received
Other Income
(add lines 1a throuoh 1e}
Mother
$2,166.70
$4,021.30
$2,166.70
$4,021.30
$166.25
$165.75
$362.78
$307.63

a.
b.
c.
d.
e.
f.
Income Taxes (Federal and State)

FICA (Soc.Sec.+Medicare)/Self-Employment Taxes
Mandatory Union/Professional Dues
Soousal Maintenance Paid
Q. Normal Business Expenses
(add lines 2a throuoh 2q)
(line 1 f minus 2h)
(If line 4 is less than $600, skip to line 7.)
5. BASIC CHILD SUPPORT OBLIGATION: Cornbined-e
Amanda
$611.00
Sarah
$494.00
Elizabeth
$494.00
..
.. ..
$332.00
$670.41
$1,834.70
$3,350.89
$5,185.59
...
..
1~.~t
.
:.:<:;ji:1
$1599.00
WSCSS-Worksheets (CSW) 9/2000Page1of5
Father
Mother

.354
.646
7. Each Parent's Basic Child Support Obligation

$566.05
$1032.95
$94.00
line Ba lus line 8b
add father's and mother's totals from line 8c
(line 8d minus line Be., if "O" or negative, enter "O")
$94.00
$94.00
$79.95
$14.05
a.
$400.00
b.
c.
d.

Expenses {line Bf plus line 10)
$400.00
$400.00
$414.05
$146.57
--
$267.48
Part Ill: GrossChild SupportObligation

$712.62
$1300.43
Part IV: Child SupportCredits (See Instructions, Page 7)

$94.00
$400.00
c. Other Ordinary Expenses Credit (describe)
d. Total Su art Credits add lines 14a throu h 14c

$494.00
Part V: Standard Calculation/Presumptive
Transfer Payment

$600 (see below if appl.)
(See Instructions, Page 8)

Father
Mother
$712.62
$806.43
$712.62
$806.43
Part VI: AdditionalFactors for Consideration (See Instructions, Page 8)

(Present estimated value of all major assets.)
a. Real Estate
b. Stocks and Bonds
c. Vehicles
d. Boats
f. Cash
s. Insurance Plans
h. Other:
Father's
Household
Mother's
Household
17. Household Debt

(List liens against household assets, extraordinary debt.)
a.
b.
c.
d.
e.
f.
(if not the other parent of this action}
Name
Name
Name
Name
c. Income of Children (if considered extraordinary)
Name
Name
d. Income from Child Suooort
Name
Name
WSCSS-Worksheets {CSW) 9/2000 Page 3 of 5

e. Income From Assistance Proarams
Proqrarn
Prooram
Father's
Household
Mother's
Household
19. Non-Recurrina Income (describe)
20. Child Suooort Paid For Other Children

Name/age:
Name/age:

Father's income based on unemployment benefits of $500/week. Taxes: S/2. Mother's income
based on $29.00 per hour/32 hours a week. Taxes: HH/3. Daycare averaged over year of
before/after care and full time summer.
13647
3/4/2003
Signature and Dates

Mother's Signature
Father's Signature
Date
City
Judge/Reviewing
Officer
Date
City
Date

SupportCa/c 2002
~8049
WORKSHEET SYNOPSIS
3. Basic Support:
Amanda
$611.00
Sarah
$494.00
Elizabeth $494.00
4.
TOTAL
FATHER
$1,834.70
.354
MOTHER
$3,350.89
.646
$566.05
$146.57
$1032.95
$267.48
$712.62
$1300.43
$1599.oo

7.
TOTAL OBLIGATION

$94.00
$400.00
11.
TOTAL CREDITS
$494.00
12.
Father Pays Mother
$712.62
File Name: Dahl.SCP

SupportCalc 2001-T
CASE ALERT

SupportCa/c 2002
COMBINED
$5, 185.59
.I"'"'.
<.)
:-"1i.r'
I'\ 1 . :
j ... : \;;
1 "~ . ~
$1599.00
$414.05
02-3-02760-6
18541399
csw
03-04-03

Worksheets (CSW)
County: PIERCE
Superior Court Number: 02-3-02768-6
Father

a. Wages and Salaries
b. Interest and Dividend Income
C. Business Income
d. Spousal Maintenance Received
e. Other Income
f. Total Gross Monthly Income
(add lines 1a through 1e)
Mother
$2,166.70
$4,021.30
$2,166.70
$4,021.30
$166.25
$165.75
$362.78
$307.63

a.
b.
c.
d.
e.
Income Taxes (Federal and State)

FICA (Soc.Sec. +Medicare)/Self-Emolovment Taxes
Mandatorv Union/Professional Dues
f. Spousal Maintenance Paid
a. Normal Business Expenses
(add lines 2a through 2Q}
<line 1 f minus 2h)
5. BASIC CHILD SUPPORT OBLIGATION: Combined -7
Amanda
$611.00
Sarah
$494.00
Elizabeth
$494.00
$332.00
$670.41
$1,834.70
$3,350.89
. ,,/1!
$5,185.59
.;
'''.;
-;:;,,.
''
$1599.00
'1~.'
.
I'~
<f
-'.:_;f~:
' ,.; t'i
[fi,:,: :.,~;
~-
,\
Father
Mother

.354
.646

$566.05
$1032.95
$94.00
$94.00
line Sa lus line Sb
add father's and mother's totals from line Sc
$94.00
$79.95
(line Sd minus line Be., if "O" or negative, enter "O")
$14.05
a.
$400.00
$205.00
b.
C.
d.

Expenses (line Bf plus line 10)
$605.00
$605.00
$619.05
$219.14
$399.91
$785.19
$1432.86
Part Ill: Gross Child SupportObligation

$94.00
$605.00

WSCSS~Worksheets(CSW) 9/2000 Page 2 of 5
$699.00
Part V: Standard Calculation/Presumptive Transfer Payment

e. Enter the lowest amount of lines 15b, 1 Sc or 15d:

Father
Mother
$785.19
$733.86
$785.19
$733.86
Part VI: AdditionalFactors for Consideration(See Instructions, Page 8)

(Present estimated value of all rnaior assets.)
a. Real Estate
b. Stocks and Bonds
c. Vehicles
d. Boats
f. Cash
g. Insurance Plans
h. Other:
17. Household Debt

a.
b.
c.
d.
e.
f.
(if not the other parent of this action)
Name
Name
Name
Name
C. Income of Children (if considered extraordlnarv)
Name
Name
Name
Name
Father's
Household
Mother's
Household
.,

e. Income From Assistance
Proqrarn
Program
f. Other Income (describe}
Father's
Household
Mother's
Household
Proarams
19. Non-Recurrinq Income (describe)
20. Child Support Paid For Other Children

Name/age:
Name/age:
~
~


before/after care and full time summer. Tuition for full time kindergarten.
-.
Other factors for consideration {continued)
Signatureand Dates
Mother's Signature
Date
Father's Signature
City
Date
City
Date
Worksheet certifiedby the State of Washington Administratorfor the Courts.

Photocopyingof the worksheetis permitted.
SupportCa/c2002
'..._ ~
13647 3/4/2003
~0856
WORKSHEET SYNOPSIS
3. Basic Support:
Amanda
$611.00
$494.00
Sarah
$494.00
Elizabeth
4.
TOTAL
FATHER
$1,834.70
.354
MOTHER
$3,350.89
.646
COMBINED
$5, 185.59
$566.05
$219.14
$1032.95
$399.91
$1599.00
$619.05
$785.19
$1432.86
$1599.oo

7.
TOTAL OBLIGATION

$94.00
$605.00
11.
TOTAL CREDITS
$699.00
12.
Father Pays Mother
$785.19
File Name: Dahl.SCP

Support Cal~ 2001-T
CASE ALERT

SupportCa/c 2002
~.n~!'lJ:\
.
~\11\- v~
.
',.,_
~.
. .~!...
.:!
'!.~
13647 3/4/2B03
02-3-02768-6
16541400
PPP
90057
03-04-03
2
3
4
FILED
IN COUNTY CLERK'S OFF! E
A.M.
PIERCE COUNTY
MAR 0 3 2003
STOCK,'
------
8~EVIN

COUNTY OF PIERCE
8
9
NO. 02-3-02768-6
DEBORAH J. DAHL
PARENTING PLAN
PROPOSED (PPP)
10
11
Petitioner,
and
12
JAMES R. DAHL
13
Respondent.
14
This parenting plan is proposed by Mother.
15
16
17
18
Name
Age
19
AMANDA
SARAH
ELIZABETH
20
DAHL
DAHL
DAHL
13
10
6
21
22
23
children.
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 1 of 12
Forms+Pl1.1s
10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
i253) 572-4500
i253) 272-5732
2.1
PARENTAL CONDUCT (RCW 26.09.191 {1}, (2)).

Does not apply.
2
3
2.2
4
Does not apply.
5
6
Ill. RESIDENTIAL SCHEDULE
day of the year, including provisions for holidays, birthdays of family
8 members, vacations, and other special occasions, and what contact the
children shall have with each parent. Parents are encouraged to create a
9 residential schedule that meets the developmental needs of the children and
individual needs of their family. Paragraphs 3.1 through 3.9 are one way to
10 write your residential schedule. If you do not use these paragraphs, write in
your own schedule in Paragraph 3.13.
11
3.1
12
13
3.2
SCHOOL SCHEDULE.
14
15
with or be with the other parent:
16
Friday at 6:00 p.m. to Sunday 6:00 p.m. every other
17
weekend.
18
3.3
SCHEDULE FOR WINTER VACATION.
19
The children shall reside with the mother during winter vacation,
20
21
In even-numbered years Father shall have first half of

winter vacation from the time school ends until Christmas
Day, 11 :00 a.m. and Mother shall have second half of
winter vacation from 11 :00 a.m. Christmas Day until
school resumes. In odd-numbered years Mother shall have
the first half of winter vacation from the time school
ends until 11 :00 a.m. Christmas Day and Father shall have
Christmas Day 11 :00 a.m. until school resumes.
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 2 of 12
Farrns.P/u~ 10.7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732
1
2
3.4
SCHEDULE FOR SPRING VACATION.

The children shall reside with the mother during spring vacation,
Shared equally with the exchange to take place at 6:00

p.m. on Wednesday, the midweek point of the Spring
Vacation week.
5
6
7
3.5
SUMMER SCHEDULE.
8
Upon completion of the school year, the children shall reside with the
mother, except for the following days and times when the children will
reside with or be with the other parent:
9
10
Father shall receive four weeks of summer/vacation time

with the children. In year one (2003), Father shall
divide the four weeks so that there is only one two-week
block, thereby leaving two one-week blocks for vacation.
In year two (2004} and thereafter, Father shall receive
two two-week non-consecutive blocks of summer/vacation
time with the children ..
11
12
13
14
3.6
VACATION WITH PARENTS.
15
Does not apply.
16
3.7
SCHEDULE FOR HOLIDAYS.
17
is as follows:
18
19
With Mother
(Specify
Year
Odd/Even/Every)
20
With Father
(Specify
Year
Odd/Even/Every)
21
New Year's Day
Presidents Day
23 Memorial Day
July 4th
24 Labor Day
Veterans Day
25 Thanksgiving Day
22
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 3 of 12
f'orms+P/us 10. 7
*
**
**
**
Odd
**
**
Even
*
**
**
**
Even
**
**
Odd

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 5 7 2-4500
(2531 27 2-5 732
Christmas Eve
Christmas Day
Odd
Even
Even
Odd
2
* * Monday holidays. Holiday goes with whomever has

visitation that weekend
4
5
Thanksgiving shall be from the time school lets out on

Wednesday until 6:00 p.m. Sunday evening.
6
7
July 4th shall be 9:00 a.m. on July 4th until 11 :00 a.m.
the next morning.
8
The times for Christmas Eve and Christmas Day are
identified in section 3.3.
9
10
If not otherwise specified or agreed to, the times for

other holidays shall be 9:00 a.m. to 9:00 p.m.
11
12
Other:
13
*January 1st is youngest child's birthday and shall be

shared as designated in special occasions below.
14
15
3.8
16
17
18
With Mother
(Specify
Year
Odd/Even/Every)
19
With Father
(Specify
Year
Odd/Even/Every)
20
21
22
Mother's Day
Father's Day
Mother's Birthday
Father's Birthday
Every
Every
Every
Share
Every
Share
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 4 of 12
f.ormt Plu:J
10.?

1201 PACIFIC AVENUE
TACOMA, WA 98402
1253) 572-4500
(253) 272-5732
~364?
3.9
3/4?2003
900~1

3
4

3 Winter vacation (3.3)
4 Spring vacation (3.4)
5 Summer schedule (3.5)
1 Holidays (3. 7)
5
6
7
8
3.10
RESTRICTIONS.
9
Does not apply
10
11
3.11
TRANSPORTATION ARRANGEMENTS.
and/or the Order of Child Support and should not be included here.
12
13
14
Transportation arrangements for the children between parents shall be

as follows:
15
Fath er shal I provide transportation.
16
3.12
17
custody. This designation shall not affect either parent's rights and
18
19
20
21
3.13
OTHER.
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 5 of 12

l 200 WELLS FARGO PLAZA
1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732
13647
3.14
3/4/2003
00062
SUMMARY OF RCW 26.09.430 - .480, REGARDING RELOCATION OF

A CHILD.
2
3
4
5
6
7
8
9
through 26.09.480.
07 .0500, (Notice of Intended Relocation of A Child.)
10
11
12
13
14
15
If information ls protected under a court order or the address
16
17

at risk.
18
19
20
21
22
23
24
25

including contempt.
intended relocation, the relocation will be permitted and the proposed
proper notice.
DRPSCU 07 .0700, (Objection to Relocation/Petition for Modification of
Custody
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 6 of 12

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253] 272-5732
Decree/Parenting Plan/Residential Schedule). The

objection must be served on all persons entitled to time
with the child.
1
2
objection unless: (a) the delayed notice provisions apply; or (b) a court
3
4
If the objecting person schedules a hearing for a date within 15 days

5
6
7
IV. DECISION MAKING
8
4.1
9
10
11
12
MAJOR DECISIONS.
4.2
13

14
joint
16
care:
joint
17
joint
18
The parties represent and acknowledge that the children

have been and shall continue to be raised in according
with the same general religious routine that they are
accustomed to, presently at Sunset Bible Church. Each
parent agrees to actively foster, encourage and cooperate
with the children in this regard.
15
19
20
21
22
4.3
23
Does not apply.
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 7 of 12
Form:s+Plua
10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(2531 572-4500
(2531 272-5732
2
3
4
5
about carrying out this parenting plan. This dispute resolution process may,
before filing a petition to modify the plan or a motion for contempt for failing
to follow the plan.
be submitted to (list person or agency):
6
mediation by Pierce County Dispute Resolution
Center, or a mediator mutually agreeable to both
parties.
7
8

follows:
10

11
12

13
14
(a)
15
(b)

support.
(c)

(d)

parent.
(e)
16
17
18
19
20
21
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 8 of 12

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732
13647
3/4/2803
008.S
1
VI.
OTHER PROVISIONS
2
3
4
with whom the child is not then residing, without interference from the
residential parent.
5
B. Each parent agrees to exert every reasonable effort to maintain free
access and unhampered contact and communication between the child and
11 self-worth.
6
12
C. Each parent agrees to honor the other's parenting style, privacy

13 parent shall interfere in the parenting style of the other, nor shall either parent
14 authority or time with the child without the express agreement of the other.
15 against a parent directly with the parent in question. It is the intent of both
16
17 daycare, health and other program personnel regarding the child's progress,
18 healthcare records of the child.
19
20 nights. The information to be provided shall include duration of the period,
the destination(s) and destination telephone number(s). This provision is
21 included solely for purposes of knowing the parent's and child's location in
the event of an emergency and is not meant to be intrusive.
22
23 payments or other legal matters regarding the parental relationship and
obligation.
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 9 of 12
form1 .. fl'h11 10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732
13&47
1
2
3
4
3.141"2883 088G6

parent.
care. Activities shall not be scheduled to unreasonably interfere with the
5
6
7
telephone number of their residence and update such information promptly
at least 30 days in advance of a scheduled move, or within 72 hours of an
unscheduled move.
8
9

involving the residential schedule with the children except for plans which
10
K. Neither parent shall encourage the child to change his or her
to do so. It is a choice which will be made by the parents or, it they cannot
12 agree, the courts.
L. Neither parent shall introduce a significant other during the

14 the night during their visitation periods.
13
15

16
17
18
19
20
21
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 10 of 12
forms ...P/us 10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253] 272-5732
~3647
3/4/2003
B80~7
1
VII. DECLARATION FOR PROPOSED PARENTING PLAN
2
(Only sign if this is a proposed parenting plan.) I declare under
penalty of perjury under the laws of the State of Washington
that this plan has been proposed in good faith and that the
statements in Part II of this Plan are true and correct.
3
4
5
6
R~&
DEBORAHl}AHL
Mother
Date and Place of

Signature
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 11 of 12
Fo~ .. Plus 10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732
VIII. ORDERBY THE COURT
3
4
5
6
7
8

knowledge of its terms is punishable by contempt of court and may be a
criminal offense under RCW 9A.040.060(2) or 9A.40.070(2). Violation of
resolution process.
Judge/Commissioner
Approved for entry:
W.S.B.A. #

Interoffice#:
Client File: P:\SCPLUS\DAHL\Dahl.SCP
02/24/2003 04:27 p.m.
Form: P:\SCPLUS\DAHL\PP.DOC
02/24/2003 03:19 p.m.

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 5724500
(253) 2725732
D2-3-n?68-6
18541403
DCSPP
03-04-03
2
3
FILED
IN COUNTY CLERK'S OFFIC
MAR 0 3 2003
A.M.
PIERCE COUNTY,
lNGTO
KEVIN STOCK, County Clerk
BY
DEPUT

COUNTY OF PIERCE
8
9
N0.02-3-02768-6
DEBORAH J. DAHL
DECLARATION IN SUPPORT
OF PARENTING PLAN
(DCLR)
10
Petitioner,
11
and
12
JAMES R. DAHL
Respondent.
13
14
(COMPLETE A SEPARATE FORM FOR EACH CHILD IF NECESSARY)

15
This declaration is made by the mother.
16
1.
The children have resided with the following persons during the past
twelve months:
17
18
19
Name
20
Deborah Dahl
James Dahl
Length of Time
Child Resided With
This Person
Birth+
Birth+
21
22
23
24
25
WPF DR 04.0120 (9/2001)
RCW 26.09.194(1)
Page 1 of 4
forms+P/us
10. 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(2531 572-4500
(2531 272-5732
"
1
2.
The mother's performance of parenting functions relating to the

(a)
2
3
4
5
Mother performed all of the parenting functions including grooming,

preparing meals, homework, reading, taking to doctor and dentist
appointments, attending parent teacher conferences, volunteering once a
week in children's classrooms, field trips and other activities, Vice President
of PTA, coached sports, took them to park or beach, and had an annual trip
to Spokane for a family reunion.
7
8
9
(b)
The mother's work schedule for the past twelve months:
In February, 2002, Mother worked 21 hours per week and also picked
up on-call shifts on a weekly basis. Her schedule was usually one week
on/one week off and flexible. In December, 2002, Mother was hired at
University of Washington as a research nurse working 32 hours per week.
10
11
(c)
The mother's current work schedule:
12
32 hours a week with a very flexible schedule that she works around
13 the children's schedules.
14
3.
(a)
The father's performance of parenting functions relating to the

15
16
Father was available for the children in the evenings when Mother
worked. Even so, the eldest pretty much took care of the younger two with
17 grooming, homework and preparing meals during this time. Father will
occasionally take them out on the boat on hot days and let them play on the
18 beach. Since separation and most recently since he has been unemployed he
has become a more active participant in the children's lives. He has exercised
19 visitation on alternate weekends with occasional overnights during those
visits.
20
21
(b)
The father's work schedule for the past twelve months:
22
Monday - Friday flexible hours but consistently 10-12 hour shifts.
23 stated that he was "on-call" twenty-four hours a day.
He
24
25
WPF DR 04.0120 (9/2001)
RCW 26.09.194(1)
Page 2 of 4
farms+Pfus 10, 7

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732
1
(c)
The father's current work schedule:
2
Unemployed.
3
The child-care schedule for the past twelve months:
4.
The youngest did attend preschool/daycare at Multicare daycare center

while I was at work. The other two were at home or with neighbors/friends.
Friends and neighbors have been watching children since the commencement
of school in September, 2002, and Father has also been there for the girls
since his unemployment.
6
7
(a)
(b)
With friends and neighbors before/after school or with the eldest child.
The current child-care schedule:
10
5.
Any circumstances under RCW 26.09.191 that are likely to pose a

serious risk to the children and that warrant limitation on the award to
a parent of temporary residence or time with the children pending
entry of a permanent parenting plan are set forth in Part II of my
proposed temporary parenting plan.
6.
OTHER:
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

WPF DR 04.0120 (9/2001)
RCW 26.09.194(1)
Page 3 of 4
EISENHOWER & CARLSON. PLLC

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(2531 272-5732
13647
....
3/4/2083
2
DA TED this
1:1_ day of ~'oNOrt{
, 2003, at Tacoma, Washington.
3
4
5
Deborahf.Dahl
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
- 1
DOCUMENTS

AITORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-5732
~0072
13647
02-3-02768-6
18541405
3/4/2003
Q-007'3
03-04-03
MTAF
2
3
4
FILED
IN COUNTY CLERK'S OFFI
5
6
7
PIERCE COUNTY, WASHINGT N

KEVIN STOCK, County Cler y

COUNTY OF PIERCE
BY
DEPU
8
9
N0.02-3-02768-6
DEBORAH J. DAHL
MOTION AND DECLARATION

FOR TEMPORARY ORDER
(MTAF)
10
11
Petitioner,
and
12
JAMES R. DAHL
13
Respondent.
14
I. MOTION
15
Based on the declaration below, the undersigned moves the court for a
16 temporary order which:
17
Orders child support as determined pursuant to the Washington

State Support Schedule.
18
Approves the parenting plan which is proposed by the wife.
19
20
21
Restrains or enjoins both parties from transferring, removing,

encumbering, concealing or in any way disposing of any
property except in the usual course of business or for the
any extraordinary expenditures made after the order is issued.
22
23
24
Restrains or enjoins both parties from assigning, transferring,

borrowing, lapsing, surrendering or changing entitlement of any
insurance policies of either or both parties whether medical,
health, life or auto insurance.
25
WPF DR 04.0100 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 1 of 6
r\)1n!~i~
'"''"n:
.:
Wells Fargo Plaza

(253) 572-4500 Phone
(253) 272-5732
l.:l64? 3/4/2803
80074
1
2
Makes each party immediately responsible for their own future

or mortgage.
3
Divides responsibility for the debts of the parties.
4
To Husband:
5
1 .
2.
4.
3.
5.
8
9
6.
7.
8.
Seafirst Visa
PRA Columbia Bank
Mortgage/utilities/taxes on 2581 2 1 20th
Lane SW
10
To Wife:
11
12
13
1.
2.
3.
4.
5.
14
6.
7.
15
8.
9.
16
17

J.C. Penneys
SLM Financial
Chevron
Old Navy
Multicare Daycare Owing for Elizabeth
Mortgage/utilities/taxes on 916 Manor
Drive

18
Authorizes the family home to be occupied by the wife.
19
Orders the use of property.
20
To Husband:
21
1 .
22
23
2.
3.
4.
24
5.
25812 120th Lane SW Real Property

2002 Seaswirl Boat
located at 25812 120th Lane SW
25
WPF DR 04.0100 (9/2001)
RCW 26.09.060; .11 O; .120; .194
Page 2 of 6

Wells Fargo Plaza
(253) 572-4500 Phone
(253) 272-5732
To Wife:
1.
2.
91 6 Manor Drive Real Property

located at 916 Manor Drive
3.
4.

property.
The issue of husband to pay temporary attorney's fees, other

professional fees and costs is hereby reserved.
7
8
9
10 Dated:
11
12
11.
13
Temporary relief is required because:
14
Use of Property. Respondent and I own three homes, the main Fircrest
15 home, a Fircrest rental and a beach home. Since I am asking to be the
children's primary caretaker, I would request that I remain in the family home
16 and Respondent take residence in the beach home. In fact, the Respondent
has already moved out to the beach home and this arrangement seems to be
17 working. The family home has the children's bedrooms and is in their school
district and around their friends. The rental home is currently rented and the
18 rent collected covers the mortgage and expenses for that property.
19
History of Work Schedules and Involvement with Children. Respondent

and I have three daughters, ages 13, 10 and 5. Throughout our marriage, I
20 have always been the girls' primary caretaker. I worked on call for Multicare
until I took a permanent position at Group Health in February, 2002. When I
21 worked on call I would be sure to work opposite my husband's hours to
ensure that there was an adult at home with the children. This was usually on
22 weekends, evenings or nights after the girls were asleep. We mutually made
this decision as we believed it would benefit the children to not have to be
23 subjected to daycare. Even though Respondent was home with the girls, the
oldest, Amanda, would take care of the younger two by making sure they
24 were fed and did their homework while Respondent worked on his computer
or fell asleep. In February, 2002, I started a permanent position with Group
25 Health where I worked seven days on and seven days off from approximately
WPF DR 04.0100 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 3 of 6
Forms+r/u.,
10. 7

Wells Fargo Plaza
(253) 572-4500 Phone
(2531 2725732
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
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17
7:30 a.m. - 2:00 p.m. This allowed me to be home with the children when
they needed me before and after school. I also picked up on-call shifts with
Multicare which allowed me to keep a steady stream of needed income.
These on-call shifts were flexible which I worked around the children's
schedules. Just recently, I became employed with the University of
Washington as a research nurse. I work 32 hours per week and my hours are
flexible in order to still work around the children's schedules.
Respondent worked 10-12 hour shifts Monday through Friday. He
always advised me, however, that he was on call twenty four hours a day.
Respondent lost his job and is currently unemployed. I do not know his
schedule with regard to job searches or interviews that the State requires in
order to receive unemployment.
I feel that I have a great relationship with all of my children. I make
sure that I am with them in all of their activities. I have coached softball,
basketball and t-ball. We play together, eat together, learn together and talk
together. The girls confide in me and I feel that we have an extremely strong
bond which can only help once they start entering their teenage years.
Respondent was always distant with the girls. He yelled at them quite often
which they had confided in me that it makes them uncomfortable. When we
were together, he would get angry with them and myself on almost a daily
basis. Husband rarely attended school functions or sporting events. He never
helped them with homework or special school projects. The only activity that
Respondent would do with the girls is take them out on the boat and while
they play on shore he will anchor out in the water and sit on the boat listening
to music. He seemed to choose not to have any interaction with them where
on the other hand they are my entire livelihood and focus. Since separation
and especially since he stopped working, Husband has become more involved
in the girls' lives. He now takes them every other weekend to his separate
residence and spends time with them after school since he is home. He has
done a complete 180 degree turn with respect to his parenting. This can only
be in the best interests of the girls to finally have an active Father but I am
saddened that it took the demise of our marriage for this to occur.
18
Parenting Plan Restrictions. I have asked that there be restrictions in
19 the Parenting Plan with regard to Respondent's visitation with the children.
Respondent has a history of alcohol abuse with a DWI in December, 2001 and
20 continued rehabilitation/counseling. I am not sure that he is "cured" of his
disease. There were times when Respondent would leave for the evening or
21 just didn't come home from work without letting me know where he was. In
the past, he has come home between 2:00 and 3:00 a.m. and slept out in his
22 truck or he doesn't come home at all until the following day. Respondent
never showed genuine interest in the girls day-to-day activities or events.
23 When he was with them, he allowed them to do whatever they want while he
slept or worked on his computer. l have called the girls from work and the
24 oldest two will tell me that they had to cook dinner themselves and put the
youngest to bed. He does not take them to the park or play soccer/basketball
25 with them which is what they enjoy. I need to know that they
WPF DR 04.0100 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 4 of 6
Forms+P/"" 10. 7

Wells Fargo Plaza
(253) 57 2-4500 Phone
(253) 272-5732
13.47
1
2
"3/4/2003
08077
are safe and being taken care of while with Respondent and because of these
patterns topped off with his alcohol abuse, I am not sure that this would
happen. I have asked that Respondent refrain from drinking alcohol while in
the girls' presence and before his visitation.
3
4
5
I am also asking for the restriction of introduction of significant others

of either parent to the children during the pendency of this matter. The girls
are going through a transition period of having their parents separated and
don't need the added confusion of a third party by either of us at this time.
would think this is a reasonable request for a temporary order.
6
Child Support. Respondent is currently unemployed. I believe he
makes $500.00 per week on unemployment. I calculated his monthly income
at this figure and taxes of Single, 2 exemptions. I calculated my income using
8 my hourly of $29.00 for a 32 hour work week and taxes of Head of
Household, three exemptions. There is the cost of before/after school care
9 for our two youngest children which I pay monthly to neighbors or our eldest
child. I have averaged the cost to be $400.00 per month which averages the
10 summer months when the children are not in school. There is also a cost
through June, 2003 for our youngest child to be in all day kindergarten which
11 is an additional cost of $205.00 per month. I have provided two separate
worksheets with the kindergarten cost through June, 2003, and then
12 removed this cost as of July, 2003.
7
13
Division of Debts. Respondent and I have kept separate accounts and

paid separate liabilities for some time now. 1 would just request that this
14 remain status quo and become part of the Temporary Order. Since I have
requested to stay in the family home, I will continue to pay the mortgage and
15 other expenses on that property and Husband will pay likewise on the beach
home where he may reside.
16
Medical Insurance. When Husband lost his job, the family lost our
I don't believe he picked us up on COBRA as this option
was too expensive. I have inquired at my employment as to coverage on
18 myself and the three children. I have been told that this coverage is $94.00
per month but I am in the process of receiving the verification. I would
19 respectfully request that I receive this monthly premium as a credit on the
child support worksheets.
17 medical coverage.
20
2002 Tax Return. I would hope that Husband and I could work
21 together on the filing of our tax return to see what best benefits the
community. I am in contact with my accountant and she is running a few
22 different scenarios, however, this is difficult without Husband's 2002 W2 or
other financial information.
23
Attorney's Fees. I would ask that the issue of Husband paying a
24 portion of my attorney's fees for this temporary hearing be reserved at this

time.
25
WPF DR 04.0100 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 5 of 6
forms+P/u:s
10.7

Wells Fargo Plaza
(253) 572-4500 Phone
(2531 272-5732
13647
3/4/2003
0e07a
Conclusion. I respectfully request the Court to adopt my Parenting Plan

based on the pattern of care over the last twelve months and Respondent's
continuous alcohol abuse; adopt my proposed child support worksheets; and
enter a Temporary Order dividing the property and debts as requested.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
WPF DR 04.0100 (9/2001)
RCW 26.09.060; .110; .120; .194
Page 6 of 6
Interoffice#:
02/28/2003 03,32 p.m.
Form: P:\SCPLUS\DAHL\MOTIONTO.DOC
02/28/2003 03:32 p.m.

Wells Fargo Plaza
(2531 572-4500 Phone
(2531 272-5732
13647
.
3/4/2003
2
DATED this
lf day of nbruo..t\.( , 2003, at Tacoma, Washington.
3
4
5
6
7
8
9
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- 1
DOCUMENTS

ATTORNEYS-AT-LAW
1201 PACIFIC AVEN\JE
PHONE 253-572-4500
FAX 253-272-5732
08\l?~
3/5/2083
02-3-02768-6
1 6541787
NTC
12402
03-04-03

)
)
DAHL, DEBORAH J
Plaintiff(s)/Petitioner(s),
)
)
vs.
Case No. 02-3-02768-6
)
)
)
DAHL, JAMES R
Defendant( s)/Respondent( s).
NOTE FOR COMMISSIONER'S CALENDAR

NAME
RICHARD WILLIAM LOCKNER
524 Tacoma Ave S
---------------~
ADDRESS
WSB# 19664
ATTORNEY FOR Respondent
TACOMA WA 98402-5416
PHONE (253) 383-4704
-------:-::(P,.,...le-ase_note_a_dd_iti_ona_l_attome--ys-on_a_n-atta-ched
page)
Please take notice that an issue of law In this case will be heard on the date below and the clerk is
directed to note this issue on the appropriate calendar:
11
CALENDAR
DATE,_M_a_r_c_h _19_;,_2_0_0_3
_
11
Nature of Case: Dissolution with Children

[V] (MO) Show Cause/Family Law, Confinnation Required

[
[
[
[
[
[
(9:30 Mon.- Thurs.)

COURT/WORKING DAYS PRIOR TO HEARING OR HEARING WILL BE CANCELLED
] (VY) Adoption, No Confinnation Required
(9:30 Fri.)
] (OE) Supplemental Proceedings, No Confinnation Required
(1 :30 Mon.- Fri.)
] (UD) Unlawful Detainer, No Confinnation Required
(1 :30 Mon.- Fri.)
] (GD) Probate/GdnshplMnr Settlement, No Confinnation Required
(1 :30 Mon.- Fri.)
] (DD) Uncontested Dissolutions, No Confinnation Required
WI
3:00Mon.- Fri.)
] (FC) Patemity, No Confinnation Required..........................
. 1:
. Thur.)
Dated: 2/28/2003
NAME
Signed: __ __,.__r--11----;-.c+--------P. CRAIG BEETHAM
ADDRESS
FORMS\COMNOTE3-2001.DOC
00118
02-3-02768-6
18613865
03-17-03
NTC
IN couNrf
bt~&s
OFF {
P.M.
PIERCECOUNT
ASHINGTON
BY
DEPUTY

)
DAHL, DEBORAH J
Pia lntiff( s)/Petitioner( s ),
) Case No. 02-3-02768-6

)
Wf-NOTE FOR COMMISSIONER'S CALENDAR
vs.
DAHL, JAMES R
Defendant( s)/Respondent( s).

NAME
-=5__;_2_4 _T.:_:_ac"-'o_m_:_a.:..c.A__;_v-=.e-=S:..__
ADDRESS
WSB# 19664
~
PHONE
~--------------~
(Please note additional attorneys on an attached page)
(253) 383-4704
Please take notice that an issue of law in this case will be heard on the date below and the clerk is
directed to note this Issue on the appropriate calendar:
Ii
CALENDAR
DATE._A__,p_ri_.,.1&~-2_00_3

[V] (MO) Show Cause/Family Law, Confinnation Required

[
[
[
[
[
[
]
]
]
]
]
]
(9:30 Mon.- Thurs.)

COURT/WORKING DAYS PRIOR TO HEARING OR HEARING WILL BE CANCELLED
(VY) Adoption, No Confinnation Required
{9:30 Fri.)
(OE) Supplemental Proceedings, No Confinnation Required
(1 :30 Mon.- Fri.)
(UD) Unlawful Detainer, No Confinnation Required
(1 :30 Mon.- Fri.)
(GD) Probate/Gdnshp/Mnr Settlement, No Confinnation Required
(1 :30 Mon.- Fri.)
(DD) Uncontested Dissolutions, No Confinnation Required.................
n.- Fri.f
(FC) Patemity, No Confinnatlon Required.............................
., Tues. & Thur.)
Dated: 3/13/2003
Signed:.__
NAME
P. CRAIG BEETHAM
ADDRESS
Wells Fargo Plaza I 1201 Pacific Ave Ste 1
---+=-.L__jf--~'----------
FORMS\COMNOTE32001.DOC
OR!GINAL
4/4-"'2003
14724
0014.a
F~LED
d~ OPEN COURT
COURT OF THE STATE OF WASHIN

AND FOR PIERCE COUNTY
02-3-02768-6
18716945
CME
APR 0 3 2003
Pl~:c~~
04-04-03
DEBORAH J DAHL
No. 02-3-02768-6
Petitioner(s ),
DEPUTY
Memorandum of Journal Entry
VS.
[){Show
JAMES R DAHL
Cause
(ADM02)
Respondent(s)
For Petitioner
April 3, 2003 9:30 AM
For Respondent
Show Cause
PT COM. REBECCA KAYE REEDER
Clerk:Ad
Courtroom number: 264
Calendar:C3-SHOW CAUSE/FAMILY LAW
Run date/time 04/03/03 9:02

lxcrtrpt.pbl
d_joumal_ entl}'_ showcause _report
Clerk
~ l 111111111111 ll
02-3-02760-6
19159060
NTAB
06-20-03
IN
Fl LED
COUNTY CLERK'S OFFICE
PIERCE couar
KEVIN STOC
SY __
~~-1---~
6
7
IN THE SUPERIOR COURT OF THE STATE OF WASHING

8
NO. 02-3-02768-6
DEBORAH DAHL,
10
Petitioner,
OF
vs.
11
12
NOTICE OF UNAVAILABILITY
COUNSEL
JAMES DAHL,
13
Res ondent.
14
TO:
CLERK OF THE COURT
15
ANDTO:
RICHARD W. LOCKNER, Krilich, La Porte, West & Lockner, PS, attorney for
Respondent
16
YOU AND EACH OF YOU please take notice that attorney P. Craig Beetham will be
17
unavailable from July 1, 2003 through July 10, 2003 and will be returning to the office on July
18
11,2003.
19
PLEASE REFRAIN from filing or attempting to serve, any motions or other forms of
20
expedited pleading practice that would conflict with the undersigned's unavailability for the
21
period specified.
22
23
DA TED this 18th day of June, 2003.

24
25
26
00253922.DOC
OF COUNSEL - l
OR\G\NAL

ATTORNEYS-AT-LAW
1201 PAClflC AVENUE
TACOMA. WASHINGTON 98402
PHONE 253-572-4500
FAX 253-272-5732
02-3-02766-6
10716946
Fl LED
04-04-03
ORSW
A.M.
APR ~ 3 2003
P.M.
6
7

COUNTY OF PIERCE
8
9
NO. 02-3-02768-6
DEBORAH J. DAHL
ORDER OF CHILD
SUPPORT
(ORS)
10
11
Petitioner,
and
12
JAMES R. DAHL
13
Respondent.
Clerk's Action Required
14
I. JUDGMENT SUMMARY
15
Does not apply because no attorney's fees or back support has been ordered.
16
II. BASIS
17
2.1
TYPE OF PROCEEDING.
18
19
This order is entered pursuant to a hearing for temporary child support

and upon agreement of the parties.
20 2.2
CHILD SUPPORT WORKSHEET.
21
22
The child support worksheet which has been approved by the court is
attached to this order and is incorporated by reference or has been
initialed and filed separately and is incorporated by reference.
23 2.3
OTHER:
24
25
ORDER OF CHILD SUPPORT
WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 1 of 7
Forms+Pf"' 10. 7

Wells Fargo Plaza
(2531 572-4500 Phone
(253) 272-5732
111. FINDINGS AND ORDER
1
2
IT IS ORDERED that:
3.1
CHILDREN FOR WHOM SUPPORT IS REQUIRED.
Name {first/last)
AMANDA
SARAH
ELIZABETH
Age
DAHL
DAHL
DAHL
13
10
7
3.2
PERSON PAYING SUPPORT {OBLIGOR).
8
Name (first/last):
JAMES DAHL
Birth date:
01 /08/54
Service Address: [You may list an address that is not your residential
address where you agree to accept legal documents.]
9
10
11
25812 120th LANE SW

VASHON, WA 98070
12
13
14
15
16
17
THE OBLIGOR PARENT MUST IMMEDIATELY FILE WITH THE COURT AND
THE WASHINGTON STATE CHILD SUPPORT REGISTRY, AND UPDATE AS
NECESSARY, THE CONFIDENTIAL INFORMATION FORM REQUIRED BY RCW
26.23.050.
THE OBLIGOR PARENT SHALL UPDATE THE INFORMATION REQUIRED BY
PARAGRAPH 3.2 PROMPTLY AFTER ANY CHANGE IN THE INFORMATION.
THE DUTY TO UPDATE THE INFORMATION CONTINUES AS LONG AS ANY
MONTHLY SUPPORT REMAINS DUE OR ANY UNPAID SUPPORT DEBT
REMAINS DUE UNDER THIS ORDER.
18
Monthly Net Income: $1834.70*
19
*Father currently unemployed.

unemployment compensation
Net income based on

of $500 per week.
20
3.3
PERSON RECEIVING SUPPORT (OBLIGEE):
21
Name {first/last)
DEBORAH DAHL
Birth date:
07/29/57
Service Address: [You may list an address that is not your residential
address where you agree to accept legal documents.]
91 6 MANOR DRIVE
FIRCREST, WA 98466
22
23
24
25

WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132{5)
Page 2 of 7
f"orms+Plu~ 10. 7

Wells Fargo Plaza
(253) 572-4500 Phone
(2531 272-5732
14724
4/4/2883
~8143
THE OBLIGEE PARENT MUST IMMEDIATELY FILE WITH THE COURT AND
26.23.050.
3
4
THE OBLIGEE PARENT SHALL UPDATE THE INFORMATION REQUIRED BY

6
Monthly Net Income: $3350.89
7
The obliger may be able to seek reimbursement for day care or special
child rearing expenses not actually incurred. RCW 26.19.080.
8
9
3.4
10
SERVICE OF PROCESS.
SERVICE OF PROCESS ON THE OBLIGOR AT THE ADDRESS
REQUIRED BY PARAGRAPH 3.2 OR ANY UPDATED ADDRESS, OR ON
THE OBLIGEE AT THE ADDRESS REQUIRED BY IN PARAGRAPH 3.3
OR ANY UPDATED ADDRESS, MAY BE ALLOWED OR ACCEPTED AS
ADEQUATE IN ANY PROCEEDING TO ESTABLISH, ENFORCE OR
MODIFY A CHILD SUPPORT ORDER BETWEEN THE PARTIES BY
DELIVERY OF WRITTEN NOTICE TO THE OBLIGOR OR OBLIGEE AT
THE LAST ADDRESS PROVIDED.
11
12
13
14
3.5
TRANSFER PAYMENT.
15
The obliger parent shall pay $785.19 per month from
March 1, 2003 - June 1, 2003. Commencing with the
July 1, 2003 payment, the obliger parent shall pay
$712.62 per month.
16
17
18
19
THE OBLIGOR PARENT'S PRIVILEGES TO OBTAIN OR MAINTAIN A

LICENSE, CERTIFICATE, REGISTRATION, PERMIT, APPROVAL, OR
OTHER SIMILAR DOCUMENT ISSUED BY A LICENSING ENTITY
EVIDENCING ADMISSION TO OR GRANTING AUTHORITY TO
ENGAGE IN A PROFESSION, OCCUPATION, BUSINESS, INDUSTRY,
RECREATIONAL PURSUIT, OR THE OPERATION OF A MOTOR
VEHICLE, MAY BE DENIED, OR MAY BE SUSPENDED IF THE
OBLIGOR PARENT IS NOT IN COMPLIANCE WITH THIS SUPPORT
ORDER AS PROVIDED IN CHAPTER 74.20A REVISED CODE OF
WASHINGTON.
20
21
22
23
24
25

WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 3 of 7
Forms +Pl11J 10. 7

Wells Fargo Plaza
(253) 572-4500 Phone
(253) 272-5732
1
STANDARD CALCULATION.
3.6
2
$785.19 per month.

$712.62 per month.
3
4
3.7
(See Worksheet #1 line 15.)

(See Worksheet #2 line 15 .)
REASONS FOR DEVIATION FROM STANDARD CALCULATION.

The child support amount ordered in paragraph 3.5 does not deviate
from the standard calculation.
6
7
3.8
REASONS WHY REQUEST FOR DEVIATION WAS DENIED.
8
9
A deviation was not requested.

3.9
STARTING DATE AND DAY TO BE PAID.
10
Starting Date:
11
Day(s) of the month

support is due:
03/01/03
. .........-:::: ~
~t~
12
3.10
r9
C--.11
INCREMENTAL PAYMENTS.
13
Does not apply.
14
3. 11
HOW SUPPORT PAYMENTS SHALL BE MADE.
15
Selec either Enforcement and Collection or Payment
16
Payment rocessing only: The Division of Chil
upport does not
provide su port enforcement services fort case. Support
~}
payments s all be made to:
~
17
18
Washington St
Support Registry
45A
P.l~,'.y,~~a~
~8504
;/v./.Clf'?~'ILt..
one -800-922-4306 /'?"J-K.. ~/'l
&r:r ~"'1
f:'t11
or
00-442-5437
7lJ /,,;v'/~
"'{ ~~
19
20
21
paym
:r--2..~ .
ts but will not take any collection action.)
22
ments to the Washington State Support
Registry ill not receive ere for a payment made to any other party
or en . The obligor parent s all keep the registry informed whether
he
she has access to health i urance coverage at reasonable cost
ct, if so, to provide the health i surance policy information.
23
24
25

WPF DR 01 .0500 (9/2001)
RCW 26.09.175; 26.26. 132(5)
Page 4 of 7
forms+Plu
10. 7

Wells Fargo Plaza
(253) 572-4500 Phone
(253) 272-5732

WPF DR 01 .0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 5 of 7
Fonm+PIU$ 10. 7

Wells Fargo Plaza
(253) 572-4500 Phone
(253) 272-5732
.1
3.18
2
MEDICAL INSURANCE FOR THE CHILDREN LISTED IN PARAGRAPH

3.1.
Unless one or more of the boxes below are checked, each parent shall
maintain or provide health insurance coverage if:
4
(a) Coverage that can be extended to cover the children is or becomes
available to each parent through employment or is union-related; and
5
6
(b) The cost of such coverage for the mother does not exceed
$258.24 (25 percent of mother's basic child support obligation on
Worksheet Line 7), and the cost of such coverage for the father does
not exceed $141 .51 (25 percent of father's basic child support
obligation on Worksheet Line 7).
8
9
The parents shall maintain health insurance coverage, if available for

the children listed in paragraph 3.1, until further order of the court or
until health insurance is no longer available through the parents'
employer or union and no conversion privileges exist to continue
coverage following termination of employment.
10
11
12
A parent who is required under this order to provide health insurance

coverage is liable for any covered health care costs for which that
parent receives direct payment from an insurer.
13
14
A parent who is required under this order to provide health insurance

coverage shall provide proof that such coverage is available or not
available within twenty days of the entry of this order to the physical
custodian or the Washington State Support Registry if the parent has
been notified or ordered to make payments to the Washington State
Support Registry.
15
16
17
If proof of health insurance coverage is available or not available is not

provided within twenty days the obligee or the Department of Social
and Health Services may seek direct enforcement of the coverage
through the obliger's employer or union without further notice to the
obliger as provided under Chapter 26.18 RCW.
18
19
20
3.19
EXTRAORDINARY HEALTH CARE EXPENSES.
21
The OBLIGOR shall pay 35% of extraordinary health care expenses
(the obliger's proportional share of income from the Child Support
Schedule Worksheet, line 6), if monthly medical expenses exceed
$79.95 (5% of the basic support obligation from Worksheet line 5).
22
23
24
3.20
25
BACK CHILD SUPPORT.

No back child support is owed at this time.

WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 6 of 7
fo1msPlus 10. 7

Wells Fargo Plaza
(253) 572-4500 Phone
(253) 272-5732
1
3.21
BACK INTEREST.
2
No back interest is owed at this time.
3
s
:
3. 22
OTHER:
~2J"l-'I j .S-.#1-c-c...
~_l'/Y-';P?""
/h
'1-K~ ~
lf'(i<!.-,6"'/fl""-V~,-v,6
~,r""/.c/n..,..r~r;?Lg:
Dated:
Cf.3-03
~
n-f
~-1"1'-7__.....,..
?IV(~,
~u.~1.J--lar
k'fk~
f1?.trJ71-
Judge/Court Commissioner
8
Presented by:
t:fv\,
Approved for entry:

~resentation
9
10
11
~ckner
12
13
14
15
p~ 6//~
/le~
16
~j>~-
.:::Z-1/?'~~4/b: ~
~11)cz,A/G>
17
~_/P'f7'7-J
18
::I> /Vd/~191
19
c:eru~~/7~ 7 ~ K?z-t:5C-/
143"95
;r~
;, ~.C-~y~r
7_f...ASf/"t/'lj~
7f"0
C/t09L--
d6zr ~ -1) ~~ES

/11&"'">7 f>/N1t::-"'-r3
vc:::J> ;:xF"'
,/17"6::...&" %l.--l.-
20
~
21
\N couNnf h'r.~~s OFFICE
22
23
24
25
WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 7 of 7
Interoffice ij:
Client File: P:\SCPLUS\DAHL\DAHL.SCP
04/01/2003 1127
Form: P:\SCPLUS\DAHL\OCS.DOC
04/01/2003 11:27 a.m..
a.m.
ForrnaPlua 10. 7

Wells Fargo Plaza
(253) 572-4500 Phone
(2531 272-5732
'
'-~ . -
W_O_R_K_S_H_E_ET S._Y_N_O_P_S_l_S __
-..
~ ~~ \.
or
L:, ~ \ ~\ ~ \{
! . I . - - . -.. , : T
1. Monthly Net lncciin~.!.~....
~ '. .. ;
':, .
2. Proportional Share _o! Income ; , ; ..

3. Basic Support: 1- - ~.
Amand~ __ $~}:1.00.
Sar?h~ ;\;$494.00 '

$494.00
.
1
.
--
'.~CE\\/
~. -~
.. , '\
\1.il.R \...1 L
C f')
\.-.t--
2,0\\~
MOTHER
COMBINED
$1,834.70
.354
$3,350.89
.646
$5,185.59
KRJUCH LaPORTE?..
-..;t;ST
& LOCKN\?.f\,
FILED
.
IN COUNTY CLERK'S OFF1CE
PIER(.t; (.'0,! 1~!TV.lfl_l,l\~l-llNGTON
A.M.
TOTAL
t.AAR
0 3 2003
11
P.M.
,..,;:viN STOCK
COUtHY CLERK
$1599.oo

6. OBLIGATIQN for Extraordinary Health
BY ~--c=--..-=-..-.;=--
OEPUTY
$566.05
$219.14
$1032.95
$399.91
$785.19
$1432.86

7.
TOTAL OBLIGATION
$94.00
$605.00

10. CREDIT for Ordin.ary Expenses
11.
TOTAL CREDITS
12.
Father Pays Mother
$699.00
$785.19
File Name: Dahl.SCP

SupportCalc3' 2001-T
CASE ALERT
INCOMEEXCEEDS $5000
PRESUMPTIVEAMOUNT: $1550.00
'
SupportCa/c 2002
'{Jg:JAB
FATHER
Elizabeth
4.
/--~yi~i~'~
ceOJ,~~1/2303
$1599.00
$619.05
;-
14724 4/4/2803 80149
. .. --~------------------
-------

Worksheets (CSW)
Suoenor Court N um ber: 02-3-02768-6
County: PIERCE
Father

a.
b.
c.
d.
e.
f.
Mother
$4,021.30
$2,166.70
Waoes and Salaries

Business Income
Soousal Maintenance Received
Other Income
(add lines 1a throuqh 1e)

a. Income Taxes (Federal and State)
b. FICA (Soc.Sec.+Medicare)!Self-Emolovment Taxes
C. State Industrial Insurance Deductions
d. Mandatorv Union/Professional Dues
e. Pension Plan Payments
!=l. Normal Business Expenses
(add lines 2a through 2g)
(line 1f minus 2h)
5. BASIC CHILD SUPPORT OBLIGATION: Combined-?
$611.00
Amanda
$494.00
Sarah
$494.00
Elizabeth
$2,166.70
$4,021.30
$166.25
$165.75
$362.78
$307.63
$332.00
$670.41
$1,834.70.
$3,350.89
.i..:.J:-i<
~il~i
Ii
c.-':.t
:.~~- --
i"y,;(-ii.
.-~'.v:~ !_.~
J-
$5,185.59
$1599.00
~~j~~:')~;:j
11~
~(R~f[tj
Mother
Father
(Each parent's net income from line 3 divided bv line 4)
.354
.646

(1f line 4 is less than $600, enter each parent's support
(Skip to line 15a and enter this arnount.)
$566.05
$1032.95
8. Health Care Exoenses
a. Children's Monthlv Health Insurance
b. Children's Uninsured Monthly Health Care
(line Ba olus line Sb)
(add father's and mother's totals from line Sc)
(multiolv line 5 times .05)
(line Bd minus line Be., if "O" or negative, enter "O")
9. Dav Care and Soecial Child Rearinc Expenses
a. Dav Care Exoenses
b. Education Expenses
c. Lone Distance Transportation Expenses
d. Other Soecial Expenses (describe)

(Add lines 9a throuch 9d)
l-'.-.,---::(~C~o~m~b~in~e_a_m~o~u_n_ts-:-:-on---:lin~e---=9e~)~=---=~~---,--=-----:--:-~~
Expenses (I.me Sf pI us 1me 10)
$94.00
$94.00
$79.95~.
$14.os
[[~l~~&I
$400.00
$205.00
$605.00
$605_00
.:,;r~{~~~1f~~11
-.~~~~~~l:~~~~\~'-="IHI
~~~1
.
f:[,:<~f~r:;;J
$619 . 05 ~~~j~~;-?_J.,:
;~ >.;i~;~,151
$219.14
$399.91
$785.19
$1432.86
Part Ill: GrossChild SupportObligation

13. Gross Child Suooort Obligation (line 7 plus line 12)
Part JV: Child SupportCredits (See Instructions, Page 7)
14. Child Suooort Credits
a. Monthlv Health Care Expenses Credit
b. Dav Care and Special Expenses Credit
d. Total Support Credits {add lines 14a throuah 14cl

$94.00
$605.00
$699.00
_ _,,,
--....----
~ ----~---- --
---------
PartV: Standard.Calculation/Presumptive
TransferP_ayment(See Instructions, Page 8)
Mother
Father
15_ Standard Calculation
a_ Amount from line 7 if line 4 is below
$733.86
b_ Line 13 minus line 14d, if line 4 is over
$785.19
$600 (see below if apol.)
c. Amount on line 1 Sb adjusted to meet 45%
$733.86
$785.19
Part VI: AdditionalFactorsfor Consideration(See Instructions, Page 8)

a. Real Estate
b. Stocks and Bonds
c. Vehicles
d. Boats
f. Cash
g. Insurance Plans
h. Other:
Father's
Household
Mother's
Household
'
17. Household Debt

,
a.
b.
c.
d.
e.
f.
Name
Name
Name
Name
c. Income of Children (if considered extraordinarv)
Name
Name
Name
Name
--
-------------
-----

ProQram
Proa ram
19. Non-Recurrino Income (describe)

Name/age:
Name/age:
--
-------
------------
---------
Mother's
Household
Father's
Household
.-

before/after care and full time summer. Tuition for full time kindergarten.
WSCSS-Worksheets
(CSW) 9/2000 Page 4 of 5
--------------~---------
Signature and Dates

Mother's Signature
Date
Father's Signature
City
City
Date
Date
Worksheet certifiedby the State of Washington Administratorfor the Courts.

Photocopyingof the worksheetis permitted.
WSCSS-Worksheets (CSW) 912000 Page 5 of 5
SupportCa/c 2002
;--,_.__=r":
WORKSHEET SYNOPSIS
1. Monthly N.it'
i~~E:: ' '. 'nct; .
Hr
2. Proportional~~~.r.e.ct tncome-
;::
c E IV r,.: I
FATHER
$1,834.70
o
3. Basic support: ;"i.tt[\ V 1.1
. ~n;i~n~CI. ;j $1 ~ :QO. -- ---, !\RILICH LaPORTE
: 'Sarah' - $494.00
JEST & LOCKNER. P.: ..
Elizabeth $494.00
4.
TOTAL
i ,
~,
-,
.35 t-----=~~...:..:6:..:4=6---.
2nn3
FILED
IN COUNTY CL:RK'S OFFICE
PIERC:r- rri1 '~.TV \~1r.,c:4!MGTON
A.M.
MAR 0 3 2003
I BY -=--~-=,=DEPUTY
s1599_00
TOTAL OBLIGATION
$566.05
$146.57
$1032.95
$267.48
$712.62
$1300.43
$94.00
$400.00
8. CREDIT for ExtraordinaryMedical

10. CRED\Tfor Ordinary Expenses
11.
TOTAL CREDITS
12.
Father Pays Mother
$494.00
$712.62
File Name: Dahl.SCP

Page was printed on 2/2812003at 03:44 PM
SupportCalc 2001-T
CASE ALERT

SupportCa/c 2002
P.M.
:\c::vii~ STOCK
COUNTY CLER!<
5. Total Basic SupportObligation

7.
t '"'
COMBINED
$5,185.59
MOTHER
$3,350.89
$1599.00
$414.05
---:---------------~--
WashingtonState Child SupportSchedule

Worksheets (CSW)
ounty: PIERCE
S upenor C OU rt N um b er: 02 - 3 -027 68-6
Children and Ages: Amanda, 13; Sarah, 1 O; Elizabeth, 6

Father
a. Waaes and Salaries

b.
C.
d.
e.
f.
Interest and Dividend

Business Income
Spousal Maintenance
Other Income
Total Gross Monthly
(add lines 1a throuch
Mother
$2,166.70
$4,021.30
Income
Received
Income
1e)
$2,166.70
$4,021.30
$166.25
$165.75
$362.78
$307.63

b. FICA (Soc.Sec. +Medicare)/Self-Employment
Taxes
C. State Industrial Insurance Deductions
d. Mandatory Union/Professional Dues
e. Pension Plan Payments
.
a. Normal Business Expenses
(add lines 2a throuqh 2a)
(line 1 f minus 2h)
Amanda
$611.00
Sarah
$494.00
Elizabeth
$494.00
$332.00
$1;834.70
,''.'.:,e',_'.,\~1I'.' . .i
1 ~'.~ .~
i1f,,
$670.41
$3,350.89
$5,185.59
::: ::.v:i
V1
.,. ~1 :~~
. ~'. .
i)Ji~
$1599.00
~t~
~\&:t,=~\
14724 4/4/2003 80~56
.-
----.---------------
Father
(Ski to line 15a and enter this amount.
Part II: Health Care, Day Care, and Special Child Rearing Expenses
Mother
.354
.646
$566.05
$1032.95
(See Instructions,

a. Children's Monthl Health Insurance
b. Children's Uninsured Month! Health Care
line Ba lus line 8b
add father's and mother's totals from line Sc
(line 8d minus line Be., if "O" or negative, enter "O")
Page 7)
$94.00
$94.00
$94.00
$79.95
$14.05
c.
d.
$400.00

$400.00

Expenses (line Sf plus line 10)
$414.05

$146.57
$267.48
$712.62
$1300.43
Part Ill: Gross Child Support Obligation

Part IV: Child Support Credits (See Instructions, Page 7)
$94.00
$400.00
d. Total Su
ort Credits (add lines 14a throu h 14c)
WSCSS~Worksheets(CSW} 9/2000 Page 2 of 5
$494.00
......_~-----~.
--------------------
14?24
4/4/2603
,.
- --

TransferPayment (See Instructions, Page 8)
Father
Mother
$600 (see below if appl.) '
Limitation standards adiustments
d. Amount on line 1 Sb adjusted to meet
$712.62
$806.43
$712.62
$806.43
Part VI: AdditionalFactors for Consideration(See Instructions, Page 8)

Father's
Household

a. Real Estate
b. Stocks and Bonds
c. Vehicles
d. Boats
f. Cash
g. Insurance Plans
h. Other:
Mother's
Household
17. Household Debt

(List liens against household assets, extraordinary
a.
b.
c.d.
e.
f.
.a. Income Of Current Spouse
Name
Name
Name
Name
c. Income of Children (if considered extraordinary)
Name
Name
d. Income from Child Suooort
Name
Name
debt.)
88157
-
--
--------'"---
---
Father's
Household
Other Household Income (continued) .

e. Income From Assistance Proqrarns
Prooram
Proqrarn
Mother's
Household
19. Non-Recurrino Income (describe)

Name/age:
Name/age:

based on $29.00 per nour/sznours a week. Taxes: HH/3. Daycare averaged over year of
before/after care and full time summer.
~- -..-,-
FILED
A.M.
APR . ..;_3 2003
P.M.
Signature and Dates

Father's Signature
Mother's Signature
City
Date
Pf!-0 T ~
Date
City
Date

SupportCa/c 2002
. '
02-3-02768-6
18716994
P PT
04-04-03

COUNTY OF PIERCE
8
9
)
)
)

10
DEBORAH J. DAHL
11
Petitioner,
and
JAMES R. DAHL
14
PARENTING PLAN
TEMPORARY (PPT)
)
)
)
12
13
NO. 02-3-02768-6.
Respondent.
~~~~~~~~~~~~~~~)
This parenting plan is a temporary parenting plan entered by the Court upon
15 agreement of the parties.

16
17
18 This parenting plan applies to the following children:

19
Name
20
AMANDA
SARAH
ELIZABETH
21
Age
DAHL
DAHL
DAHL
13
10
6
22
23
children.
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 1 of 11

Wells Fargo Plaza
1 201 Pacific Avenue, Suite 1200
(2531 572-4500 Phone
Form1+P/us 10.7
(2531 272-5732
2.1
PARENTAL CONDUCT (RCW 26.09.191 (1 ), (2)).

Does not apply.
2
3
2.2
4
Does not apply.
5
6
Ill. RESIDENTIAL SCHEDULE
day of the year, including provisions for holidays, birthdays of family
8 members, vacations, and other special occasions, and what contact the
children shall have with each parent. Parents are encouraged to create a
9 residential schedule that meets the developmental needs of the children and
individual needs of their family. Paragraphs 3.1 through 3.9 are one way to
10 write your residential schedule. If you do not use these paragraphs, write in
your own schedule in Paragraph 3.13.
11
3.1
12
13
3.2
SCHOOL SCHEDULE.
14
15
16
Friday at 6:00 p.m. to Sunday 6:00 p.m. every other
17
weekend.
18
3.3
19
20
The children shall reside with the mother during winter vacation,
21
22
23
24
25

winter vacation from the time school ends until Christmas
Day, 11 :00 a.m. and Mother shall have second half of
winter vacation from 11 :00 a.m. Christmas Day until
school resumes. In odd-numbered years Mother shall have
the first half of winter vacation from the time school
ends until 11 :00 a.m. Christmas Day and Father shall have
Christmas Day 11 :00 a.m. until school resumes.
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 2 of 11

Wells Fargo Plaza
(2531 572-4500 Phone
(253) 272-5732
1
2
3.4
SCHEDULE FOR SPRING VACATION.

The children shall reside with the mother during spring vacation,
3
4
Shared equally with the exchange to take place at 6:00

p.m. on Wednesday, the midweek point of the Spring
Vacation week.
5
6
7
9
3.5
SUMMER SCHEDULE.
Upon completion of the school year, the children shall reside with the
mother, except for the following days and times when the children will
reside with or be with the other parent:
9
10

with the children. In year one (2003), Father shall
divide the four weeks so that there is only one two-week
block, thereby leaving two one-week blocks for vacation.
In year two (2004) and thereafter, Father shall receive
two two-week non-consecutive blocks of summer/vacation
time with the children ..
11
12
13
14
3.6
15
Does not apply.
16
3.7
17
is as follows:
18
19
With Mother
(Specify
Year
Odd/Even/Every)
20
With Father
(Specify
Year
Odd/Even/Every)
21
New Year's Day
Presidents Day
23 Memorial Day
July 4th
24 Labor Day
Veterans Day
25 Thanksgiving Day
22
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 3 of 11
formsf'lu1
10. 7
*
**
**
**
**
**
**
Odd
**
Even
**
**
Odd
Even
**

Wells Fargo Plaza
(253) 572-4500 Phone
(253) 272-5732
14724 4/4/2803
Christmas Eve
Christmas Day
Odd
Even
88167
Even
Odd
2
3
4
* * Monday holidays. Holiday goes with whomever has

5
July 4th shall be 9:00 a.m. on July 4th until 11 :00 a.m.
the next morning.
8
9
10

11
12
Other:
13

14
15
3.8
16
17
18
With Mother
(Specify
Year
Odd/Even/Every)
19
20
21
22
Mother's Day
Father's Day
Mother's Birthday
Father's Birthday
23
With Father
(Specify
Year
Odd/Even/Every)
Every
Every
Every
Share
Every
Share
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 4 of 11
~ornu+Plus IO. 7

Wells Fargo Plaza
(253) 572-4500 Phone
(253) 272-5732
14724 4/4/2003 08168
3.9

3
4

3 Winter vacation (3.3)
4 Spring vacation (3.4)
5 Summer schedule (3.5)
1 Holidays (3. 7)
5
6
7
8
3.10
RESTRICTIONS.
9
Does not apply
10
11
3.11
12
and/or the Order of Child Support and should not be included he
13
14
Transportation arrangements for the children between paren

as follows:
15
Father shall provide transporta~io
16
3.12
DESIGNATION OF CUSTODIA
t/Jt-J~eJ~-
/j~5~J:.r '
~~~,ll/t{-"
~'~~7i'
17
~
P-' ,,,
. . /(4U
~/t~.t)(S"l.tp
custody. This designation shall not affect either parent's rights and
18
19
20
21
;i:A~
s - all b
?
tSJ
3.13
OTHER.
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 5 of 11
F'orms+PJu:11 10.7

Wells Fargo Plaza
{253) 572-4500 Phone
(2531 272-5732
14724 4/4/2083
08~69
SUMMARY OF RCW 26.09.430 - .480, REGARDING RELOCATION OF

A CHILD.
3.14
2
through 26.09.480.
07.0500, (Notice of Intended Relocation of A Child.)
7
8
9
10
11
12

13
14
15
If information is protected under a court order or the address

16
at risk.
17
18

including contempt.
19
20
21

intended relocation, the relocation will be permitted and the proposed
22
23

proper notice.
24

DRPSCU 07 .0700, (Objection to Relocation/Petition for Modification of
Custody
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 6 of 11
forms+f'lus
10. 7

Wells Fargo Plaza
(2531 572-4500 Phone
(253) 272-5732
14724 4~4r26&3 ~8178

objection must be served on all persons entitled to time
with the child.
objection unless: {a) the delayed notice provisions apply; or {b) a court
4
5
If the objecting person schedules a hearing for a date within 15 days

6
7
IV. DECISION MAKING
8
4.1
9
10
11
12
4.2
MAJOR DECISIONS.
13
14
joint
16
care:
joint
17
joint
18

parent agrees to actively foster, encourage and cooperate
with the children in this regard.
15
19
20
21
22 4.3
23
Does not apply.
24
25
PARENTING PLAN
WPF DR01.0400 {9/2001)

RCW26.09.181; .187; .194
Page 7 of 11
Fonmi +Plus 10.7

Wells Fargo Plaza
(2531 572-4500 Phone
(253) 272-5732
2
3
about carrying out this parenting plan. This dispute resolution process may,
before filing a petition to modify the plan or a motion for contempt for failing
to follow the plan.
be submitted to (list person or agency):
6
Center, or a mediator mutually agreeable to both
parties.
7
8

follows:
9
10

11
12

13
14
(a)
15
(b)

support.
(c)

(d)

parent.
(e)
16
17
18
19
20
21
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 8 of 11
forrrrs+-PJu~ 10. 7

Wells Fargo Plaza
{253) 572-4500 Phone
(253) 272-5732
14724 4/4/2803
00172
1
VI. OTHER PROVISIONS
2
3
4
with whom the child is not then residing, without interference from the
residential parent.
5
B. Each parent agrees to exert every reasonable effort to maintain free
access and unhampered contact and communication between the child and
11 self-worth.
6
12
13
14
15
C. Each parent agrees to honor the other's parenting style, privacy

parent shall interfere in the parenting style of the other, nor shall either parent
authority or ti me with the child without the express agreement of the other.
against a parent directly with the parent in question. It is the intent of both
16
daycare, health and other program personnel regarding the child's progress,
18 healthcare records of the child.
17
19
20 nights. The information to be provided shall include duration of the period,
the destination(s) and destination telephone number(s). This provision is
21 included solely for purposes of knowing the parent's and child's location in
the event of an emergency and is not meant to be intrusive.
22
23 payments or other legal matters regarding the parental relationship and
obligation.
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 9 of 11
rorms +Plus 10. 7

Wells Fargo Plaza
(253) 572-4500 Phone
(253) 272-5732
2
3
4

parent.
care. Activities shall not be scheduled to unreasonably interfere with the
5
6
telephone number of their residence and update such information promptly
at least 30 days in advance of a scheduled move, or within 72 hours of an
unscheduled move.
8
9

involving the residential schedule with the children except for plans which
10
K. Neither parent shall encourage the child to change his or her
to do so. It is a choice which will be made by the parents or, if they cannot
12 agree, the courts.
L.
13
Neither parent shall introduce a significant other during the

14 the night during their visitation periods.
15

16
VII. DECLARATION FOR PROPOSEDPARENTING PLAN
17
Does not apply.
18
VIII. ORDER BY THE COURT
19
20
21
22
knowledge of its terms ls punishable by contempt of court and may be a
criminal offense under RCW 9A.040.060(2l or 9A.40.070(2). Violation of
23
24

resolution process.
25
PARENTING PLAN
WPF DR 01.0400 {9/2001)
RCW 26.09.181; .187; .194
Page 10 of 11
formhP/us
10, 7

Wells Fargo Plaza
(2531 572-4500 Phone
(2531 272-5732
. .
1
.J<. ~de,p.__
~l;::gg,iw_
JYee/Commission~D
4
Presented by:
1EfV\
.-.----.....ved for entry:
5
6
Richard Locknel 11:

W.S.B.A. # -=.---~~.,...._~~~~~
7
8
9
10
FILED
11
A.M.
APR. ~ 3 2003
P.M.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 11 of 11
Interoffice#:
Client File:
P:\SCPLUS\DAHL\DAHL.SCP
04/01/2003
11:01
04/01/2003
11:01
a.rn.
forrT'4+F'/ua rn.7

a.m.
Wells Fargo Plaza

(253) 572-4500 Phone
i253) 272-5732
19 4/30/2003
02-3-02768-6
18841876
cs
04-29-03
FILED
A.M.
APR 2 9 2003
P.M.
Pf-RCE COUNTY, WASHINGTON

\ilt~STOCK, County Clerk
DEPUTY

8
9
NO. 02-3-02768-6
DEBORAH DAHL,
10
Petitioner,
11
12
vs.
JAMES DAHL,
13
14
Res ondent.
cs
(X)
15
16
CSSRV ()
17
18
CONFIRMATION OF SERVICE
All the named defendants have been served, have joined or have accepted service
in writing. (Check if appropriate; otherwise, check the box below).
One or more named defendants have not yet been served. (If this box is checked,
an additional confirmation of service must be filed pursuant to subsection (b)
when service is obtained and the following information provided.
The following defendants have been served or accepted service:
19
20
The following defendants have not yet been served:
21
22
Reasons why service has not been obtained:
23
24
How service will be obtained:
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Date by which service is expected to be obtained:
CONFIRMATION OF SERVICE - l
0025 0321. DOC

ATIORNEYS-ATLAW
1200 WELL.5FARGO PLAZA
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-5732
00011
No other named defendants remain to be served.
2
A status conference is requested regarding:
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DATED this 28th day of April, 2003.

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, WSBA#20139
P titioner
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CONFIRMATION OF SERVICE-2
0025032 I.DOC

ATTORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-5732
\\\\\\\\\\\1\)\\\1\lt
02-3-02768-6
19100653
IN
FILED
COUNTY CLcRK'S OFFICE
A.M.
JUN 1 0 2003

DAHL, DEBORAH J
Plaintiff( s),
Case No. 02-3-02768-6
vs.
NOTE FOR MOTION DOCKET
DAHL, JAMES R
Defendant( s ).
TO THE CLERK OF THE SUPERIOR COURT:
NAME
ADDRESS

~---------~~--524 Tacoma Ave S
~--------------
WSB# 19664
_T_A_C_O_M_A_W_A_9_84_0_2_5_4_16
PHONE (253) 383-4704
(Please note addldonal attorneys on an attached page)
Please take notice that the undersigned will bring on for hearing a motion for:
Motion to Compel
The hearing Is requested to be held during the regular motion calendar on:
DATE REQUESTED FOR HEARING/MOTION
June 27, 2003
at9:00 am
Nature of case: Dissolution with Children

Dated: June 10, 2003
NAME
P. CRAIG BEETHAM
ADDRESS
ATTORNEY FOR Petitioner
PHONE (253) 572-4500
--------------~
------
FORMS\MOTIONNOTEJ-2001.DAC
P.M.
I'l 11111111111111
02-3-02768-6
19104344
MTCM
06-11-03
Fl Leo
IN COUNTY ClERK'S OFFICE
1
2
JUN 1 0 2003
A.M.
P.~
PIERCE COUNTY, ~N
BY
D~ITTY
5
6
7

8
9
NO. 02-3-02768-6
DEBORAH DAHL,
IO
11
12
Petitioner,
vs.
JAMES DAHL,
13
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MOTION AND AFFIDAVIT TO

COMPEL ANSWERS TO PETITIONERS'
FIRST SET OF REQUESTS FOR
PRODUCTION
Res ondent.
COMES NOW the Petitioner, Deborah Dahl, by and through her attorneys, Eisenhower &
Carlson, PLLC, and P. Craig Beetharn, and moves the Court for an order compelling the
16
Respondent, James Dahl, to answer requests for production and for terms.
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This motion is based on the affidavit of P. Craig Beetham appended hereto and the records
and files herein.
DATED this 10th day of June, 2003.
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MOTION TO COMPEL - I
00253307.DOC

AITORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 25J-S 72-4500
FAX 25)-272-5732
2H95
/11/20ti3 00139
ST ATE OF WASHING TON
County of Pierce
)
)ss.
)
P. Craig Beetharn, being first duly sworn, on oath, deposes and says:
That he is one of the attorneys for the Petitioner in the above-entitled action, and is
authorized to make this affidavit on behalf of Petitioner.
On February 27, 2003, requests for production were mailed to Respondent by and
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through his counsel of record, Richard Lockner, allowing thirty (30) days for answers. Pursuant
to CR 5(b )(2)(A), service was effective on the third day after mailing, making the answers due
on April 2, 2003.
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On May 9, 2003, our office received Respondent's answers to the requests for
production which enclosed documents that only partially responded to Request for Production
No. 2, partially responded to Request for Production No. 3, and did not answer Request for
14
15
Production No. l or 4-9 at all.

The requests for production request general information necessary to Petitioner's
16
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adequate preparation for the trial of this matter. The answers to the requests for production will
18
be approximately eighty-five days overdue at the time of hearing on this motion. Petitioner
19
qualifies for relief under CR 37(a) of the Civil Rules for Superior Courts for the State of
20
Washington, including an order compelling answers to the requests for production and awarding
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Petitioner sanctions in the form of her reasonable attorney's fees incurred in connection with
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bringing this motion.
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MOTION TO COMPEL - 2
00253307.DOC

ATTORNEYS-AT-LAW
IWO WELLS FARGO PLAZA
120 I PACIFIC A VENUE
PHONE lSJ.572-4500
FAX 253-272-5732
.~..
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3
___.c_\;.u-""='""'G=---' 2003, by P.
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My Appointment Expires
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IO
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MOTION TO COMPEL - 3
00253307.DOC

ATTORNEYSATLAW
1200 WELLS PARGO PLAZA
1201 PACIFIC AVENUE
PHONE 2SJ-S72-4SOO
FAX 2SJ-272-5732
j'.
\,
II
02-3-02768-6
19104346
C RTC
06-11-03
" lc\f&s OFFICE
IN COUNTY
2
AJ~. j
UN 1 0 2003
P.M.
WASHINGiON
PIERCE couONCT~' county Clef

KE\llN ST
B'f-
5
6
7
DEBORAH DAHL,
NO. 02-3-02768-6
Petitioner,
9
CERTIFICATE OF COMPLIANCE WITH

CR26(i)
vs.
IO
JAMES DAHL,
II
Res ondent.
12
Pursuant to Civil Rule 26(i), I, P. Craig Beetham, as the attorney for Petitioner, Deborah
13
Dahl, do hereby certify as follows:
14
On May 14, 2003, I sent a letter to Respondent's counsel, Richard Lockner, confirming
15
the scheduled CR 26(i) teleconference for May 19, 2003 to discuss the failure to produce
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answers to Petitioners' First Set of Requests for Production which were due on April 2, 2003. A
17
copy of this letter is attached as Exhibit A. The teleconference was conducted on May 19, 2003
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and a subsequent teleconference concerning discovery responses was conducted on June 3, 2003.
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The conference requirements of Civil Rule 26(i) have been met.
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DA TED this 101h day of June, 2003.
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CERTIFICATE OF COMPLIANCE-(~)R!Glf\.~}\t. ,
00253312.DOC

ATIORNEYS-ATLAW
rzot PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-5 732
2095 6/11/2803
LAW OFFICES OF
S, ALAN WEAVER
RICHARD D. TURNER
ROBERT BARONSKY
DONALD L. ANDERSON
JAMES M. HUSHAGEN
ROBERT G. CASEY
MARK J. ROSENBLUM
TERIU!NCE J. DONAHUE
GUY J. STE:RNAL
JOHN R. RUH!.
CARL.R. PETERSON
P. CRAIG BEETHAM
ANGELIA D. WESCH
DA Vil) B. PETRJCH
RONALD J. TROMPETER
AMYC.LEWIS
JASON M. WHAIBN
MICHAEL S. DELEO
EISENHOWER& CARLSON,PLLC
1200 Wells Fargo Plaza
1201 Pacific Avenue
Tacoma, WA 98402
(253) 572-4500
fl0142
CLEMENCIA CASTRO-WOOL.ER Y
STIJART C. MORGAN
JENNIFERA. WING
!.ANCEP. BLAJR
Gl.EN E. TEMPI.ETON
CS!l.LA MUHL
ll!OMA.S P. ROWLAND
DANIE!. W. CROWE
CARMEN R. ROWE
FAX (253) 272-5732
OF COUNSEL
JAMES F. HENRIOT
H. EUGENE QUINN
RONALD A. ROBERTS
May 14, 2003
Mr. Richard W. Lockner

K.rilich, La Porte, West & Lockner, P.S.
Tacoma, WA 98402
Re:
Dahl Dissolution
Dear Mr. Lockner:
I am in receipt of your letter dated May 9, 2003, enclosing certain discovery responses.
We had sent you formal discovery on February 27, 2003 and your letter fails to answer the
formal discovery or provide a majority of the requested documentation. My office has scheduled
a CR 26(i) discovery teleconference for Monday, May 19, 2003, at 10:30 a.m. I will initiate the
call and we can discuss the remainder of Mr .. Dahl's responses. Please contact me if you have
any questions or concerns.
PCB/jmw
cc:
Debbie Dahl
00250173.DOC
SEATTLE OFFICE: 2830 Two Union Square, 601 Union Street, Seattle, WA 98101, (206) 382-1830, FAX (206) 382-1920
02-3-02766-6
19197088
MTSTK
06-27-03
2
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IN THE SUPERIOR COURT OF THE STA TE OF WASHINGTON

8
9
NO. 02-3-02768-6
DEBORAH DAHL,
10
11
12
Petitioner,
vs.
JAMES DAHL,
13
Res ondent.
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I. RELIEF REQUESTED
Petitioner, Deborah Dahl, moves the court pursuant to PCLR 7(a)(5) for an order striking the
following pleadings filed by Petitioner:
1.
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MOTION TO STRIKE UNTIMELY

DOCUMENTS
Respondent Dahl's Response to Motion to Compel
II. STATEMENT OF FACTS

See Declaration of P. Craig Beetham filed herewith.
20
III. STATEMENT OF THE ISSUE
21
The following issues are presented for resolution by the court:
22
Petitioner's pleading referenced above was received at Petitioner's counsel's office vra
23
facsimile on June 26, 2003, at 11 :35 a.m. for a hearing on June 27, 2003. A copy of the date stamped
24
first page is attached hereto. The issue before the Court is under such circumstances, and PCLR
25
7(a)(5), is such pleading timely so as to be considered by the Court? Petitioner respectfully submits
26
that the answer is "NO" and the pleading should be stricken from consideration and the record.
MOTION TO STRIKE UINTIMELY DOCUMENTS - I
00254583.DOC
OR!GINAL

AnORNEYSAT-LAW
1200 WELl.S FARGO PLAZA
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 25J-272-S7J2
IV. EVIDENCE RELIED UPON

2
See Declaration of P. Craig Beetham attached hereto.
V. LEGAL AUTHORITY
3
4
PCLR 7(a) states in part:
(5) .... Any party opposing a motion shall file and serve responsive papers
in opposition to a motion no later than noon, two court days before the
date the motion is noted for hearing.
DATED this 261h day of June, 2003.

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MOTION TO STRIKE UINTIMELY DOCUMENTS - 2
00254583.DOC

ATIORNEVSATLAW
1201 PACIFIC AVENUE
PHONE 2S3572-4500
FAX 25J-272-S732
I
2
3
4
I, P. CRAIG BEETHAM, do hereby declare under penalty of perjury and in accordance

with the laws of the State of Washington as follows:
1. I am the attorney for Petitioner,
Deborah Dahl, in this matter and make this
declaration upon my own personal knowledge and belief of the matters herein.
2. A hearing has been scheduled for June 27, 2003 with the proper six day notice The
Motion was filed on June 10, 2003 and Respondent's counsel received the documents the same
day. I wrote Respondent's counsel on June 10th and indicated that I set the matter seventeen (17)
days out rather than the typical motion notice of six (6) to provide ample time to comply with the
requests.
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3. Respondent's response was due on June 25, 2003 before noon.
I received
Respondent's response on June 26, 2003, at 11 :35 a.m.
12
4. The papers are untimely under PCLR 7(a)(5), attached hereto as Exhibit A.
13
Responsive documents must be submitted two days in advance of the hearing to avoid this very
14
kind of pleading "ambush"; Petitioner does not have the opportunity to respond by strict reply in
15
a timely fashion. Further, Respondent has had since June 10, 2003, to draft his response to
16
Petitioner's motion. Further, Respondent has been stalling for MONTHS. The discovery was
17
sent February 27, 2003.
18
5. For the reasons stated above, the document filed by Respondent in response to
19
Petitioner's Motion should be stricken. However, my client would like to file a strict reply
20
declaration, albeit untimely itself under the circumstances, to address the scathing untruths told
21
in Respondent's attorney's affidavit.
22
6. Additional attorney's fees and costs in the sum of $500 should be awarded
23
Respondent on responding to the late pleadings. This is ridiculous to be requesting four (4) more
24
months for discovery when Respondent is over three (3) months late in responding to very
25
modest and simple discovery requests.
26
MOTION TO STRIKE UINTIMEL Y DOCUMENTS - 3
00254583.DOC

AITORNEYSAT-LAW
1201 PACIFIC AVENUE
PHONE 253-S72-4500
FAX 253-272-5732
7. By way of response to Mr. Lockner's affidavit, not his clients, Ms. Dahl has a number
2
of responses. Most of the "history" of the marriage and proceedings provided by Mr. Lochner is
irrelevant to Ms. Dahl's legitimate right to discovery, discovery pending since February 2003.
The only reason formal discovery was initiated is because Mr. Dahl would not respond properly
to our informal requests, requests made to keep costs down. I wrote in December of 2002
requesting document.
January 3, 2003 that he would provide such information. Letter is attached as Exhibit C. A
month went by with no response on discovery.
indicating we neither had nor received any documents,
Letter attached as Exhibit B. Counsel responded by way of letter dated
I wrote counsel again on February 3, 2003

also indicating Mr. Dahl, despite
10
receiving approximately $2,000 per month in unemployment at that time, had not been providing
1I
any child support as promised at one time. He paid $450 for the three (3) over a course of six (6)
12
months, this primarily at time when he was working at a high paying job. Letter is attached as
13
Exhibit D. Two CR 26(i) telephonic conferences were scheduled (the first one the attorneys
14
missed each other in calls). Still there was limited response. The CR 26i letters are attached as
15
Exhibits E and F respectively. Finally, on June 10th a motion to compel was filed. Still, I set
16
the matter out far enough, 17 days, to provide ample time to respond. Attached as Exhibit G is
17
my letter of June 10, 2003. Still no discovery was forthcoming until Respondent's
18
Response.
19
untimely
8. No formal response signed and dated by the Respondent has ever been provided, just
Counsel and I have had telephonic
20
a few documents under cover of letter dated May 9th.
2I
conversations such discovery was not sufficient. There is no response to Request for Production
22
No. I (paystubs) for his previous job, unemployment or his current job. Only the 2002 tax return
23
has been provided, not 2001. We have asked for two years of statements from all retirement
24
accounts, 401(k), etc., and only received a one year. We requested two years of bank statements,
25
and he has provided one - March of 2003. He never responded to RP's 6, 7, 8, and 9.
26
MOTION TO STRIKE UINTIMEL Y DOCUMENTS - 4
00254583.DOC

AITORNEVS-ATLAW
1201 PACIFIC AVENUE
TACOMA.WASHINGTON 98402
PHONE 2SJ.572-4SOO
FAX 2S3-272-S7J2
Ms. Dahl's discovery requests are probably the most modest set I ever sent out. To be
Requesting the Court's help on discovery for such limited requests six (6) months after first
requesting such information is ridiculous. Ms. Dahl wants to move forward with a proposal and
settlement, but cannot because Mr. Dahl will not provide discovery.
9. It is certainly news to Ms. Dahl that Mr. Dahl now has a job. He is still not paying
child support. She has had to go it alone financially with three children. She has had to take on
new work to pay the bills.
10. I am not sure what relevance counsel's plea for pity on Mr. Dahl's financial situation
has for a motion to compel. But it is not true. He does not pay child support. He never advised he
10
has a new job. He did not agree to impute income when he had no job; his unemployment
11
income from the State was approximately the same as imputing under the support tables. As he
12
had not provided Unemployment pay information we used the imputed figure. He had income. I
13
might add, in what seems to be a typical ploy, the temporary orders were forced by Ms. Dahl
14
having to bring a motion to the court. Only outside the courthouse door on the morning on the
15
hearing, coupled with Respondent not having filed any responsive papers for the hearing, was an
16
agreement reached on Temporary Orders. Mr. Dahl did not of this voluntarily and it took an
17
expensive motion to force even those attorneys.
18
11. Mr. Dahl's Response is untimely and should be stricken and terms awarded to Ms.
19
Dahl. Mr. Dahl's responsive is grossly misleading to the court, is dilatory in its requests, and he
20
should be sanctioned.
21
Dated this
'Z6' day of June, 2003, at Tacoma, Washington.
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MOTION TO STRIKE UINTIMELY DOCUMENTS - 5
00254583.00C

ATIORNEYSATLAW
1200 WELLS FARGO Pl.AZA
1201 PACIFIC AVENUE
PHONE 2S3S72-4SOO
FAX 2S3272-S7J2
EXHIBIT A
-"-
11-1
FS .$ ,.;,
SUPERIOR COURT RULES

..:::..::=-..:=::..:..::::.:.:......:::.:::..:::.=:.:~=-=-===--,..--------~
...-- ...;.-PCLR
~
....:=.:o~.7 38 ....- 255 3.
__;_
~'.}gQ-Od.~cause and subject ~ such conditions as justice

!V: reQU~S;
'. :i' (0 Discovery Not Limited/Additional Witness

: (dentified. This rule does not modify a party's respon. ~- sibility to timely supplement responses to discovery
requests or otherwise to complywith discovery before
;) the deadlines set by this rule or by other civil rules.
f:7
~~ [.Adopted effective July 1, 1996.]

.
.,,,i
.
.'.
proper prosecution. The Court may also, in its discretion, impose terms upon the offending party. No
motion will be heard unless there is on file proof of
service of sufficient notice of the hearing upon the
opposing party or there is an admission of such service by the opposingparty.
(4) Filing Motions. The moving party shall serve
and file all motion papers no later than six court days
before the date the party no.te~ the motion.. _.

(5) Opposing Papers. Any party opposinga motion
shall file and serve responsive papers in oppositionto
f {a) Enlargement. For shortening or enlarging
a motion not later than noon, two court days before
for filing of motions and briefs for the motion
the date the n:otion is noted for hearing.
calendar,
see:
(6) Reply.
Any papers in strict reply shall be
. r.
served and filed no later than 12:00 noon the day
(1) PCLR 7 for motionsgenerally; .
.H 1
before the hearing.
(~). PCLR 56 for motions for summary judgment;
(7) Bench Copies. The Court should be furnished
and.l),1
with a bench copy of all motion papers. The bench
(3)' PCLR 65 for applicationsfor injunctive relief.
copies shall be delivered either directly to the depart[Ad~~ted effective June 1, 1990; amended effective July 21
ment or to the officeof the Court Administrator. The
1996.]
copies are to be delivered no later than the date they
are required to be served on opposing parties. The
bench copies of papers in support or opposition shall
PCLR 7. MOTIONS
;j
be marked on the upper right corner of the first page
(a) Motions-When and How Heard-General
with the date of hearing and the name of the judge.
Policy. Except for motions in dissolution, paternity
(8) Confirmation of Motions. All motions must be
or.,post dissolution modificationsunder PCLR 7(f), or
confirmed by counsel for the moving party during the
'Unless otherwise directed with reference to a specific
week of the hearing, but not later than 12:00 noon two
matter by the judge to whom such matter has been
court days prior to the hearing. Failure to confirm
assigned, all motions, except motions during trial,
will result in the .striking of the motion from the
shall be heard on the departmental assignment and
calendar. Counsel shall confirm motions .by contactmotion calendars in each respective trial department.
ing the judicial assistant of the department to which
The judge hearing such matters shall determine the
the motion is assigned.
order in which they shall be heard. No contested
. summary judgment motions; motions to dismiss. or
(b) Procedure for Hearing. The causes on the
other such motions which might effectively terminate
motion docket for. each motion day will be called, and
a case will , be heard except by the assigned departthe moving party, if no one appears in opposition, may
ment.
take the order moved for, unless the court shall deem
it unauthorized. Motions may be continued by the
i1 (I) Recess Schedule. Motions and assignments regcourt for hearing at other specified times. Motions
ularly scheduled for a time when a department is at
requiring more than ten (10) minutes for argument
recess shall be heard in the manner and in accordance
shall be placed at the foot of the calendar unless the
wlth the schedule determined by th~ J:udges.
court otherwise directs.
. (2). Noting Motions.. Motions may be noted for
(c) Motions for Summary Judgment-Additional
hearing only by service and filing of a note of issue, in
Rules,
See PCLR 56.
.
a form approved by the court, containing all informa(d) Frivolous Motions. If the Court concludes
tion called for by such form. Such note must be filed
that a motion or a defense thereof is frivolous, terms
with the clerk not later than the close ofbusiness on
may be imposed by the Court.
.
'
the sixth court day before the day set for hearing.
For example, if the motion is noted for a Friday, it
. (e) Contested Pretrial Motions. Contested premust be filed by the close of business on the Thursday
trial motions, however designated, the purpose of
of the week before the hearing date unless there is an
which is to expand or restrict the issues or limit the
intervening court holiday; PROVIDED, that this rule
introduction of evidence (motion in limine), and moshall not relieve the moving party from any greater
tions for judgment on the pleadings should be prenotice or filing requirements established by law or
sented for resolution on a regular motion calendar
court rule.
before the day assigned for trial, unless otherwise
(3) Failure to File or Serve-Sanctions. If a moauthorized by the trial court. The failure to comply
tion is noted but not filed, the court may strike the
with this rule may result in the court's refusal to hear
same from the calendar, or may deny it for want of
such motion on the day of trial, or in the imposition of
923
'I~ '~i ::~..1 1
11
!.l ) , ' r
' ~ l ' : \;
~: ~
:I
'
lI
::
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PCLR 6: . TIME
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t i
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tjjne
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.'
EXHIBITB
LAW OFFICES OF
S. ALAN WEA VER

RICHARD D. TURNER
ROBERT BARONSKY
DONALD L. ANDERSON
JAMES M. HUSHAGEN
ROBERT G. CASEY
MARK l. ROSENBLUM
TERR.ENCE I. DONAHUE

120I Pacific A venue
Tacoma, WA 98402
(253) 572-4500
FAX (253) 272-5732
GREGORY J. MURPHY
GUY I. STERNAL
IOHNR.RUHL
CARL R. PETERSON
BRADLEY D. FRESIA
P. CRAIG BEETHAM
ANGaJA D HARLOW
DA VlD B. PETRJCH
RONALD J. TROMPETER
AMYC.LEWTS
JASON M. WHALEN
MJCHAEL S. DEIEO
CLEMENCIA CASTRO-WOOi.ER Y
STUART C. MORGAN
JENNIFER A WING
TRAcEY A. THOMPSON
LANCEP.BLA!R
GLEN E. 'JEMPLETON
CSIIJ.A MUHL
THOMAS P. ROWLAND
DANIEL W. CROWE
CARMEN R. ROWE
OF COUNSEL
JAMES F. HENR!OT
H. EUGENE Ql/lNN
RONALD A. ROBERTS
December 27, 2002
Via Facsimile
Krilich, La Porte, West & Lockner, P.S.
524 Tacoma A venue South
Tacoma, WA 98402
Re:
Dahl Dissolution
Dear Richard:
We are preparing to offer a settlement proposal to your client in the near future.
However, in reviewing
file, I have found that we do not have updated financial information
for your client. I would propose that we exchange any needed information informally rather than
sending out discovery requests. Please advise if you are in agreement and if so, forward the
following: (I) Husband's paystubs from the date of filing to present; (2) Southern Counties Oil
Company 40l(K) pension statements from the date of filing to present; (3) TOC Woodworkers
Contribution Plan from date of filing to present; (4) any bank accounts held in his name.
our
Please advise if there is any information you would like from my client to help us bring
this matter to an amicable resolution. I look forward to receiving the documentation requested.
Very truly yours,
Dictated but not Read
To Ex.pedite Delivery
P. Craig Beetham
PCB:jmw
cc:
Debbie Dahl
00241422.DOC
SEATILE OFFICE: 2830 Two Union Square, 601 Union Street, Seattle, WA 98101, (206) 382-1830, FAX (206) 382~1920
(
j
Transaction
Name
:
Fax Number:
Date&Time :
Last
HP Fax Series 1020
Report
ESC LAW FIRM

2532725732
Dec 27 2002 0Z:22pm
------------------------------------------------------------------------------------------------Last Fax
Date
Time
Type
!dent if icat ion
Duration
Pages Result
------------------------------------------------------------------------------------------------Ok
2533837244
00:01:17 1212
Dec 27 2002 02:21:~4pm Sent
-------------------------------------------------------------------------------------------------
EXHIBIT C
'\
.-
LAW OFFICES OF
KRILICH, LA PORTE, WEST & LOCKNER, P.S.

A PROFESSIONAL
SERVICE
CORPORATION
524 TACOMA AVENUE SOUTH

TACOMA, WASHINGTON 98402-5416
PHIL BRENNAN
THOMAS G. KRILICH
DENNIS J LA PORTE
RICHARD W, LOCKNER
PAULA TUCKFIELD OLSON
THOMAS J. WEST
TAC OMA (253 > 3 BJ .4 704

SEATTlE (253) 874-2148
FACSIMILE (253) 383-8053
Sender's E~Mail: [email protected]
January 3, 2003
P. Craig Beetham
1201 Pacific A venue, Suite 1200
Tacoma, WA 98402
RE:
Dahl v. Dahl
Our File No.: 4808-16947
Dear Mr. Beetham:

Thank you for your correspondence dated December 27, 2002. I have discussed the same with
my client and he is making an earnest effort to obtain the requested information and expedite it to my
attention. I would ask that you likewise forward similar updated information to my attention consistent
with our agreement during the informal mediation held in your office.
It is my understanding my client has vacated the family premises and is currently residing on
Vashon Island. I have reinforced with my client, as I hope you have with yours, to avoid placing the
children in a position adverse to their relationship with their parents. I do appreciate your professional
courtesies in helping to resolve this unfortunate matter on an amicable basis. If you have any additional
questions or comments in the interim, kindly contact me personally at my office.
~?
__
Richard W. Lockner
RWL:s
cc:
James Dahl
---..,
EXHIBITD
,/
LAW OFFICES OF
S. ALAN WEAVER
RICHARD D. TURNER
ROBERT BAllONSKY
DONALD L. ANDERSON
JAMES M. HUSHAGEN
ROBERT G. CASEY
MARK J, ROSENBLUM
, TERRENCE l. DONAHUE
GUY J. STERNAL
JOHNR.RUHL
CARL R. PETERSON
BRADLEY D FRESIA
P. CRAIG BEETHAM
ANGELIA 0. HARLOW
DA V!D B. PETRICH
RONALD 1. TROMPETER
AMYC. LEWIS
JASON M .' WHALEN
MICHAEL S. DELEO

1201 Pacific Avenue
Tacoma, WA 98402
(253) 572-4500
FAX (253) 272-5732
Cl..EMENCIA CASTRO-WOOLERY
STUARTC. MORGAN
JENNIFERA. WING
TRACEY A. THOMPSON
LANCE P. BLAIR
GLEN E. TEMPLETON
CSU.LA MUHL
THOMAS P. ROWLAND
DANIEL W, CROWE
CARMEN R. ROWE
OF COUNSEL
JAMES F. HENRIOT
H. EUGENE QUINN
RONAID A. ROBERTS
February 3, 2003
Via Facsimile
Tacoma, WA 98402
Dear Mr. Lockner:
It has come to my client's attention that Jim Dahl.has been laid off from his employment
as of last Friday, January 31, 2003. Jim informed Debbie of this layoff and also advised her that
she and the children are no longer covered by health insurance. Debbie is on a temporary basis
at her job and is ineligible for health insurance coverage. I can only believe that Jim has the
opportunity to have Debbie and the children insured under Cobra provisions from his former
employer. I would ask that he look into this and reinstate insurance on Debbie and the children
immediately. This matter was filed in August, 2002, with a hearing on temporary orders stricken
to try to "work things out" amongst the parties. Jim has not been financially helping Debbie in support of the children for the last five months. He has paid a total of $450.00 to Debbie directly
for the children's expenses. Debbie has been most gracious in this matter so far. Because of
this, we would ask that proof of reinstatement of Debbie and the children be provided to our
office within the next ten (l 0) days.
We requested of you on December 27, 2002, informal discovery from your client in order
to draft a settlement proposal. To date, we have not received any documentation. I am enclosing
documentation we have gathered from our client for your review. I look forward to receiving
your documents without the necessity of formal discovery requests in the near future.
SEA TILE OFFICE:
2630 Two Union Square, 601 Union Street, Seattle, WA 98101, (206) 382-1830, FAX (206) 382-1920
(
J

February 3, 2003
Page2
Very truly yours,
P.
PCB:jmw
Enclosures
cc:
Debbie Dahl
00243897.DOC
EXHIBIT E
,.
r:
S. ALAN WEAVER
RICHARDO. TURNER.
ROBERT BMONSKY
DONA!.D L. ANDERSON
JAMES M, HUSHAGEN
ROBERTG. CASEY
MARl<:J. ROSENBLUM
TERRENCE J, DONAHUE
GuY I. STERNAL
JOHNR.RUHL
CARL R. PETERSON
P. CRAIG BEETHAM
ANGELIA. D. WESCH
DA. VID B. PETRICH
RONALD J. TROMPETER
A.MY C. LEWlS
IASON M. WHALEN
MICHA.EL S. DELEO
LAW OFFICES OF

1201 Pacific Avenue
Tacoma, WA 98402
(253) 5724500
FAX (253) 272-5732
CLEMENCIA. CASTRO-WOOLERY
STUART C. MORGAN
JENNIFER A. WING
LANCEP.lll..AIR
GLEN E.1EMPLETON
CS!LLAMUHL
THOMAS P. ROWLAND
DANIEL W. CROWE
CARMEN R. ROWE
OF COUNSEL
JAMES F. HENRIOT
H. EUGENE QUINN
RONALD A. ROBERTS
April 24, 2003

Via Facsimile (253) 383-8053
Krilich, La Porte.West & Lockner, P.S.
Tacoma, WA 98402
Re:
Dahl Dissolution
Dear Mr. Lockner:

This letter confirms the CR 26(i) discovery teleconference scheduled for Monday, April
28, 2003, at 4:00 p.m. Our office will initiate the call. If you have any questions or concerns
prior to this conference, please do not hesitate to call.
Sincerely,
ChL,1.~
Julie M. Worr~l
Paralegal to P. Craig Beetham
cc:
Debbie Dahl
00250173.DOC
SEATILE OFFICE: 2830 Two Union Square, 601 Union Street, Seattle, WA 98101, (206) 382-1830, FAX (206) 382-1920
(
Last Transaction
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:
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I.
EXHIBITF
LAW OFFICES OF
S. ALAN WEA VER

RICHARD D. TURNER
ROBERT BARONSKY
DONALD L. ANDERSON
JAMES M. HUSHAGEN
ROBERTG. CASEY
MARK J. ROSENBLUM
TERRENCE J. DONAHUE
GUY J. STERNAL
IOHNR.RUHL
CARL R. PETERSON
P. CRAIG BEETHAM
ANGELIA D. WESCH
DAVIP 11. PETRICH
RONALDJ.Tll.OMPETER
AMYC.LEWIS
JASON M. WHALEN
MICHAEL S. DELEO

1201 Pacific Avenue
Tacoma, WA 98402
(253) 572-4500
FAX (253) 272-5732
CLEMENCIA CASTll.0-WOO~Y
STUART C. MORGAN
JENNIFER A. WING
LANCE P. BLAIR
GLEN E. lllMPUITON
CS!LLAMUHL
THOMAS P. ROWLAND
DANIEL W. CROWE
CARMEN R. ROWE
OF COUNSEL
JAMES F. HENRJOT
H. EUGENE QUINN
RONALD A. ROBERTS
May 14, 2003

Tacoma, WA 98402
Re:
Dahl Dissolution
Dear Mr. Lockner:

I am in receipt of your letter dated May 9, 2003, enclosing certain discovery responses.
We had sent you formal discovery on February 27, 2003 and your letter fails to answer the
formal discovery or provide a majority of the requested documentation. My office has scheduled
a CR 26(i) discovery teleconference for Monday, May 19, 2003, at 10:30 a.m. I will initiate the
call and we can discuss the remainder of Mr. Dahl's responses. Please contact me if you have
any questions or concerns.
PCB/jmw
cc:
Debbie Dahl
00250173.DOC
SEA ITLE OFFICE: 2830 Two Union Square, 601 Union Street, Seattle, WA 98101, (206) 382-1830, FAX (206) 382-1920
.,,,
. -"1~:
'.-..
I" .
EXHIBITG
.... '
.~ '.:,:
. ,.
,
....
S.ALANWEAVER
RICHARD D. TURNER
ROBERT BARONSKY
DONALD L. ANDERSON
JAMES M. HUSHAGEN
ROBERT G. CASEY
MARl<. J. ROSENBLUM
TERRENCEJ. DONAHUE
GUY J. STERNAL
JOHNR.RUHL
CARL R. PETERSON
P. CRAIG BEETHAM
ANGEUAD. WESCH
OA VJD B. PETRICH
RONALDJ.TROMPETER
AMYC.LEWJS
JASON M. WHALEN
MICHAELS. oeLEO
LAW OFFICES OF

1201 Pacific Avenue
Tacoma, WA 98402
(253) 572-4500
FAX (253) 272-5732
CLEMENCIA CASTRO-WOOLERY
STUARTC.MORGAN
IENN!l'ERA. WING
LANCE P. BLAIR
GLEN E. TEMPLETON
CS!LLA MUlfL
THOMAS P. ROWLAND
DANIE!.. w. CROWE
CARMEN R ROWE
OF COUNSEL
JAMES F. HENRIOT
H EUGENE QUINN
RONALD A ROBERTS
June 10, 2003

VIA FACSIMILE
Tacoma, WA 98402
Re:
Dahl Dissolution
Dear Mr. Lockner:

Enclosed please find a Note for Docket, Motion to Compel and Certificate of Compliance
with CR 26(i) with regard to Mr. Dahl's responses to discovery requests. I scheduled this motion
for June 27, 2003 and would hope that we can avoid this formality by receiving all of the
requested information prior to that date.
On another matter, Debbie has not received any child support payments from Jim
pursuant to the Order of Child Support. While the Order does state that Jim will make a good
faith effort to make these monthly payments while unemployed, he has made no effort to
financially support his daughters. If Debbie does not receive a payment by the end of this week,
I will be obtaining an ex parte order to show cause re contempt this Friday and will advise you of
the time and courtroom.
If you have any questions or concerns, please do not hesitate to contact me.
Sincerely,
PCB/jmw
Enclosures
cc:
Debbie Dahl
00250173.DOC
SEATTLE OFFICE: 2830 Two Union Square, 601 Union Street. Seattle. WA 98101, (206) 3821830, FAX (206) 382-1920
LAW OFFICES OF
EISENHOWER& CARLSON,PLLC
1201 Pacific Avenue
Tacoma, WA 98402
(253) 572-4500
FAX (253) 272-5732
Fax Cover Sheet

June 10, 2003
To:
Company:
Telephone No.:
Fax No.:
Krilich, La Porte, West &

Lockner, P.S.
(253) 383-4704
(253) 383-8053
From:
P. Craig Beetham
Number of Pages: 9
(including this page)
Regarding:
Dahl
ClienVMatter #:
Comments:
Letter; Note for Docket; Motion to Compel; Certificate of Compliance
SEATILE OFFICE: 2830 Two Union Square, 601 Union Street, Seattle, WA 98101, (206) 382-1830, FAX (206) 382-1920
The infonnation contained in this facsimile is confidential and may also be privileged. The information is intended only for the use of the individual or entity to whom it is addressed. If you are not the
intended recipient, or the employee or agent responsible for delivering it lo the intended recipient, you arc hereby notified that any use, dissemination, distribui ion or copying of this communication is
strictly prohibited. lfyou have received this facsimile in error, please immediately notify us by a collect telephone call to the telephone number listed above, and return the original message to us at the
address above via the US Postal Service. Thank you.
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02-3-02768-6
19197089
RSPMT
06-27-03
1
2
IN COuNrf
.M.
JUN 2 6 2003
BY
~
.M.
DE
SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY

NO. 02-3-02768-6
DEBORAH DAHL,
RESPONDENT DAHL'S RESPONSE TO

MOTION TO COMPEL
Petitioner,
9
10
OF ICE
ERCE COUNTY, WASHING ON

KEVIN STOCK, County Cl k
b't:li&s
v.
JAMES DAHL,
11
Respondent.
12
13
COMES
NOW
the respondent
James
R. Dahl,
by and through
his
14
undersigned
attorney, and hereby submits the following
response to plaintiffs
15
motion to compel discovery.
The basis of respondent's
response is set forth in the
16
sub-joined affidavit of Richard W. Lockner.
17
DA TED this
-1,,h
day of June, 2003.
18
KRJLICH, LA PORTE, WEST
.(~lP.S.
19
20
Richard W. Lockner, WSB #19664
21
22
23
AFFIDAVIT
ST ATE OF WASHING TON )
Krilich, La Pone,
(253) 383-4704
) SS.
COUNTY OF PIERCE
3
4
5
RICHARD W. LOCKNER, being first duly sworn deposes and says:

I am the attorney of record for the respondent James Dahl with respect to a
dissolution proceeding initiated by petitioner. Three (3) daughters were born as a
result of the marriage and neither child support, residential custody, nor parenting
plan arrangements are at issue. In fact, respondent agreed to entry of a temporary
support order based on imputed income, notwithstanding the recent loss of his long
term employment. To accommodate petitioner, respondent agreed to allow her and
10
the children to stay in the family residence while he moved to an unfinished, non-
11
12
insulated cabin on Vashon Island with unfinished interior walls and borderline
habitability. The parties have significant debt contemplated to be satisfied by the
13
refinance or sale of rental property.

14
The principal issue in this case is division of the assets and liabilities of the
15
16
17
parties, specifically, the parties retirement accounts, and, division of three (3) homes,
initially the separate property of the respondent, with subsequent issues of
18
community property commingling. The parties and their attorneys have met
19
informally in an effort to mediate resolution of asset/debt allocation. Petitioner's
20
motion concerns discovery principally related to obtaining respondent's pay stubs
21
from the date of filing to present, information regarding his 40 I (k) pension
22
statements from Southern Counties Oil Company from date of filing to present,
23
Krilich, La Porte,
West & Lockner, P .S.
{253) 3834704
3324 b/39/2B93 B9191
similar information regarding TOC Woodworker's
filing to present, and information regarding bank accounts held in his names.
3
4
Contribution Plan from date of
On or about May 9, 2003, Respondent forwarded to petitioner's counsel the

following:
5
6
1.
Respondent's 2002 W-2 and Earning Summary;
2.
Respondent's prepared spreadsheet regarding assets and debts;
3.
Information received from Southern Counties Oil Company 401(k)
8
9
plan regarding total value; and
4.
10
11
Information received from TOC Woodworkers, l.A.M. Benefits plan.
(attached and incorporated herein as exhibit 1 ).
12
Petitioner's counsel did not believe this response fulfilled petitioner's request
13
for information.
14
respondent requesting he contact me for purposes of discussing this issue. I also left
15
voice mail messages for respondent on his cell phone number. Respondent contacted
16
your affiant on the late evening of Wednesday, June 25, 2003. Respondent advised
17
18
he had recently
On or about May 19, 2002 I forwarded correspondence
obtained part time employment
and is training
to
for fulltime
employment at the rate of $15.00 per hour.
19
In response to petitioner's request for information, similar discovery requests
20
were forwarded to petitioner in late May of 2003, alleged to have been received on or
21
22
23
about June 9, 2003 with petitioner advising her responses would not be due until July 9,
2003.
Respondent respectfully submits that if plaintiff would like additional

Krilich, La Porte,
(253) 383-4704
information from those entities holding assets on behalf of respondent or the marital
community, that stipulations authorizing release of the same will be executed. Further,
respondent respectfully requests that this court set this matter over for four (4) weeks to
allow both parties to obtain and/or supplement financial information for purposes of
5
6
accommodating a mutually agreed division of assets and debts.
Respondent
respectfully requests that this court not impose requested terms or sanctions at this time
7
based on respondent's current financial situation, his acquiescence on major issues
8
9
10
regarding his wife, children, and the family residence, and, the fact that the parties
community debts are contemplatedto be satisfied by sale of a rental home.
11
12
13
Richard W. Lockner
14
AND SWORN to before
IJI~-1,
me this _f71V
__ - day of
15
16
17
18
19
20
Washi gto , residing at b. erson Island.

My Col mission expires 11/18/05.
Stacy L. Rex
21
22
23
Krilich, La Porte,
(253) 38).4704
LAW Oi=FICES
OF
KRIUCH. LA PORTE. WEST & LOCKNER. P.S.

PHii,, BR.ENN.,l,I~
THOMAS G. KRILICH
OElilNIS J. l4. ?ORiE
RICHARO \V. LOCKNER
PALILA TLICKFIELD OLSON
THOMAS J. WEST
52.; TACO}.fA .~ YH~'E SOCTH

TACO}.!A, \\'ASf!INGTON 98~02-5416
TACOMA (Z53) 383-HO<
SE:..T'rtE i253} 8J.:..2u&
FACSIMILE (ZS3) 3838053
May 9, 2003
P. Craig Beetham
1201 Pacific A venue, Suite 1200
Tacoma, WA 98402
RE:
Dahl v. Dahl
Our File No.: 4808-1694 7
Dear Mr. Beetham:

Pursuant to our conversations, enclosed for your review please find the following:
1.
2.
3.
4.
Jim Dahl's 2002 W-2 and Earning Summary;

Jim Dahl Spreadsheet regarding assets and debts;
Puttnam Account Information; and
TOC Woodworkers, I.A.M. Benefit Plans information.
I spoke with my client who continues to express optimism with respect to his job search, but has
not been hired as yet. I will apprise you once this has occurred.
As we discussed, my client's current financial status precludes his ability to meet the obligations
as set forth in under the temporary order. Both our respective clients are financially strapped, and,
financial relief likely rests in the rental property. Following your review and receipt of the enclosed
information, kindly advise whether you need any additional information, I would also appreciate your
responding to our request to have your client submit her proposed settlement for review.
Thank you for your time and attention to this matter.
Richard W. Lockner
RWL:s
Enclosures
cc:
James Dahl
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Benefits Portal
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https://www.ibenefitcenter.com/ec/portal/portal/pgWelcome?GXHC_GXj st=fc7aac63662... 3/24/2003
roe - WOODWORKERS, l.A.M.

BENEFIT PLANS
ru;
lllANAGEMEHT
SERVICES
2929 N.W. 31st AVENUE PORTLAND, OREGON 97210 PHONE 503 222-9603
ADMINISTERED BY:
ASSOCIATED ADMINISTRATORS. INC.
UNION TRUSTEES
STEVE WILSON
MARTY DEMARIS
JOHN HILKEY
CHUCK MACRAE
EMPLOYER TRUSTEES
JOSEPH A. BRISLIN
HANK SNOW
RANDY SPRINGER
RODGER M. GLOS
March 4, 2003
James Dahl
25812-120th Lane SW
Vashon, WA 98070
Re: TOC-Woodworkers. JAM Pension Plan
SSN. 539-56-8378
Dear Mr. Dahl:
Pursuant to your recent request we have reviewed the records in the Trust Office and
the results are as follows:
Plan Participation: 1976 - I 986
Date of Birth: 1/54
Years of Total Credited Service: 9

Years ofVesting Service: 9
Corresponding monthly benefit at age 65: $163.00
The records of the TOC-Woodworkers, IAM Pension Plan shows that you were
vested by virtue of the termination of the Plan on May 31, 1986. You will be entitled
to a monthly benefit from the Plan at age 65. However, if you remain employed by a
participating employer under the TDC-Woodworkers, IA.M Pension Plan and the
TDC-Woodworkers Defined Contribution Plan you may be entitled to full benefits at
age 62 or a reduced benefit between the ages of 55 and 62. If you are not employed
by an employer under the TOC-Woodworkers Defined Contribution Plan at the time
ofretirement you will be entitled to your full monthly benefit at age 65.
We recommend that you make application for retirement at least 60 days prior to the
date you wish to have your benefits commence. Application forms can be obtained
from this office or your local union office.
The information provided at this time is based solely on the records in the Trust
Office. This information is not binding on the Pension Board or this office. If it
should develop that your eligibility and credits are other than as reported here, the
decision of the Pension Board will control.
TOC-Woodworkers, IAM Pension

James Dahl
Page Two
If we can be of assistance to you in the future, or if you have questions pertaining to

the information in this letter, please let us know.
Sincerely,
TOC-WOODWORKERS, lAM BENEFIT PLANS
~~~
Patti Rankin
Pension Coordinator
cc: Woodworkers Local Lodge Wl-157
TOC - WOODWORKERS, l.A.M.

BENEFIT PLANS
I lI
j.
MANAGEMENT
SERVICES
2929 N.W. 31st AVENUE PORTLAND, OREGON 97210 PHONE 503 222-9603
ADMINISTERED BY:
ASSOCIATED ADMINISTRATORS, INC.
UNION TRUSTEES
STEVE WILSON
MARTY DEMARIS
JOHN HILKEY
CHUCK MACRAE
March 19, 2003
EMPLOYER TRUSTEES
JOSEPH A. BRISLIN
HANK SNOW
RANDY SPRINGER
RODGER M. GLOS
James R. Dahl
25812 12oth Lane s.w.
Vashon, WA 98070
Re:
TOC-Woodworkers, IAM Defined Contribution Plan

SS#530-56-8378
Dear Mr. Dahl:

Pursuant to your request, we are writing to inform you
ofyour retirement plan under the TOC-Woodworkers, IAM
Defined Contribution Plan.
The information below indicates your benefits under the
TOC-Woodworkers, IAM Defined Contribution Plan which
includes all contributions through November 1996 and
net earnings through December 2002.
Total Contributions Remitted to date:
$33,059.13
Total Net Earnings:
$65,694.53
Total Account Balance:
$98,753.66
Under the TOC-Woodworkers, IAM Defined Contribution

Plan, you are fully vested with 5 years of Vesting
Service and will be entitled to a future benefit from
the Plan. Our records indicate that you have a total of
18 years of Vesting Service. To be entitled to a
benefit, you must be 55 years of age and no longer
active under the Plan. If you become totally and
permanently disabled, you may also qualify with no ag~
restriction.
We recommend that you make application for retirement
at least 60 days prior to the date you wish to have
your benefits commence. As per your request, we have
enclosed an application to apply for your retirement
benefits.
'
James Dahl
March 19, 2003
Page Two
The information provided at this time is based solely
on the records in the Trust Office. This information
is not binding on the Pension Board or this office. If
it should develop that your eligibility and credits are
other than as reported here, the decision of the
Pension Board will control.
Should you have any questions or if we can be of any
assistance, please feel free to contact our office.
Sincerely,
TOC-WOODWORKERS, IAM BENEFIT PLANS
<(!)0~~
CJ~nice Oriver
Pension Coordinator
Jd
Enc.
cc:
Woodworkers Local Lodge Wl-157
fl LED
DEPT. 10
\N OPEN coUR
JUN 2 7 2003
Pierce coun~
IN THE SUPERIOR COURT, PIERCE COUNTY, WAS

DEBORAH J DAHL
WGT~ni;
Cause Number:02-3-02~_.
Petitioner(s)
MEMORANDUM OF JOURNAL ENTRY
vs.
Page 1 of 2
JAMES R DAHL
Respondent(s)
Judge: D. Gary Steiner
Court Reporter: ANGELA MCDOUGALL
Judicial Assistant: LINDA SCHRAMM
DAHL, DEBORAH J
P. CRAIG BEETHAM
Attorney for Plaintiff/Petitioner
DAHL, JAMES R
DAHL, AMANDA
DAHL, SARAH J
DAHL, ELIZABETH R
Proceeding Set: Motion to Compel

Proceeding Outcome: Motion Hearing Held
Outcome Date: 0612712003 9:41
Resolution:
Clerk's Scomis Code: MTHRG

Proceeding Outcome code: MTHRG
Resolution Outcome code:
Report run date/time: 06/27/03 9:55 AM

lxcalcivil.pbl.d_civiUoumal_report_cover
IN THE SUPERIOR COURT, PIERCE COUNTY, WASHINGTON

Cause Number: 02-3-02768-6
DEBORAH J DAHL
vs.
Page: 2 of 2
Judge: D. Gary Steiner
JAMES R DAHL

Start Date/Time: 06/27/03 9:42 AM
MINUTES OF PROCEEDING
Court Reporter:ANGELA MCDOUGALL
June 27, 2003 09:41 AM

Motion to Compel; Present for hearing, Attorney Richard Lockner present, Csila Muhl
present on behalf of Mr Beetham. 09:42 AM Colloquy re_: untimeliness of the motion set.
09:43 AM Ms Muhl addresses the Court. 09:50 AM Colloquy. 09:53 AM Court gives
ruling. 09:54 AM Order to be prepared. 09:55 AM Matter concluded.
End Date/Time:
JUDGE D. Gary Steiner Year 2003
Page: __
l II ll I ll 1111111
02-3-02760-6
19201891
JD
oe.so-os
~ .,.~~iLED
n::or
1...1!_\
10
.J
IN OPEN COUR
JU;~ Z 7 2003
.6
7
IN THE SUPERIOR COURT OF THE STATE OF WASH

8
NO. 02-3-02768-6
DEBORAH DAHL,
10
Petitioner,
11
12
VS.
JAMES DAHL,
13
Res ondent.
14
15
16
17
18
19
20
ORDER AND JUDGMENT

COMPELLING ANSWERS TO
REQUESTS FOR PRODUCTION AND
FOR ADDITIONAL RELIEF
JUDGMENT SUMMARY
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Judgment Creditor:
Deborah Dahl/P. Craig Beetham
Judgment Debtor:
James Dahl
Principal Judgment Amount:
$0
Interest to Date of Judgment:
$0
Attorney Fees:
$ ,.,2QC). O 0
Costs:
$0
Other Recovery Amounts:
$0
Principal Judgment Amount Shall Bear Interest at 12% Per Annum.
Attorney Fees, Costs and Other Recovery Amounts Shall Bear Interest at 12%
Per Annum.
Attorney for Judgment Creditor:
P. Craig Beetham
Attorney for Judgment Debtor:
Richard Lockner
21
22
THIS MATTER, having come on regularly for hearing on the motion of the Petitioner, and
23
the Court having heard the arguments of counsel and having examined the records and files
24
herein, and being otherwise fully advised in the premises; now, therefore, it is hereby
25
ORDERED that the Respondent, James Dahl, serve upon the Petitioner's attorney the
26
following information on or before.JI,
ly 28 2003:
ORDER ON MOTION TO COMPEL - l

00254305.DOC
-1c)~,~1N.
~1
), . ii.'~ ~'""i
-~ ~"'"~

ATIORNEYSATLAW
1201 PACIFIC AVENUE
PHONE 2SJ-S724SOO
FAX 2532725732
J.
Answers and Documentation in Response to Petitioner's First

Set of Requests for Production Propounded to Respondent
2
It is further
3
ORDERED that a judgment is awarded against the Respondent pay Petitioner's reasonable
4
attorney's fees in the sum of
5
compel. ~ D-V'l
. .
.:(?et< Q 0. <:>
~Ot\Od
d I, 000
for being caused to bring the motion to
UL
o.J:l ' ~
~5
I~
\J rio+ p~
Db
;:(u.1~ ~8,H.l8.
DONE IN OPEN COURT this~
day of ~
, 2003.
&'7_
8
9
10
11
Presented by:
12
13
15
16
Approved as to form:
17
18
KRILICH, LA PORTE, WEST & LOCKNER, P.S.
19
20
21
22
23
24
25
26
ORDER ON MOTION TO COMPEL - 2

00254305.00C

ATTORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-5732
02-3-02768-6
19369948
NTAB
07-29-03
3
4
5
SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY
6
7
8
NOTICE OF UNA V AJLABILITY
Petitioner,
9
10
NO. 02-3-02768-6
DEBORAH DAHL,
V.
JAMES DAHL,
11
Respondent.
12
TO;
CLERK OF THE ABOVE ENTITLED COURT;
AND TO:
PETITIONER
13
ABOVE
NAMED
AND HER
ATTORNEY
OF
14
RECORD:
15
Please take notice that Richard W. Lockner, counsel for the respondent, will be
16
out of the office from August 4, 2003 through August 11, 2003. You are requested to
17
refrain from scheduling hearings, motions or depositions in the above entitled action in
18
his absence.
19
2&
DATED this
20
day of
-:::Jj \ 7
, 2003.
KRILICH, LA PORTE, WEST
21
22
23
~R,P.S.
B~
Richard W. Lockner,WSB #19664
Krilich, La Pone,
(253) 383-4704
1
02-3-02768-6
19369972
IN Cou~n{ILEo
STFJG
'S OFF/CE
3
4
5
6
7


10
NO. 02-3-02768-6
JUDGMENT NO. 03-9-07824-8
DEBORAH DAHL,
11
12
13
Petitioner,
SATISFACTION OF JUDGMENT
VS.
JAMES DAHL,
[Clerk's Action Required)

Res ondent.
14
15
The undersigned attorneys for Petitioner in the above-entitled action hereby certify that
16
the Petitioner's Judgment heretofore entered in the above-entitled action in favor of Petitioner
17
and against the Respondent, James Dahl, on June 27, 2003, has been satisfied in full, and the
18
Clerk of the Court is authorized to enter a satisfaction in full of the judgment on the execution
19
docket of the Court.
20
DATED this
22_ day of July, 2003.
21
,PLLC
22
23
24
25
-Notary Acknowledgement Appears on Page 2-
26
SATISFACTION OF JUDGMENT-
00256568.DOC
ORIGINAL
ATIORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-5 732
ST ATE OF WASHINGTON
2
)
) SS.
County of Pierce
3
On this the
& Cff& day of July, 2003, before me, a Notary Public in and for the State of
4
Washington, appeared P. Craig Beetham, to me known to be one of the attorneys for the
5
6
7
Petitioner, who acknowledged that he executed the above Satisfaction of Judgment as to the
Petitioner, Deborah Dahl, as his free and voluntary act, and that he was authorized so to do on
behalf of the Petitioner.
8
9
10
Name of Notary Public

NOTARY PUBLIC, State of Washington
8I;,i.1-f 03.
My Appointment Expires
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
SATISFACTION OF JUDGMENT-2
00256568.DOC

ATTORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-5732
-.,
. '1II,r
\11\\\\l~~\\\\~l~\\lli~\I\\\
02-3-02768-6
19369981
DSW
07-29-03
3
4
5
6
7

8
9
NO. 02-3-02768-6
DEBORAH DAHL,
Petitioner,
10
11
12
vs.
JAMES DAHL,
13
14
15
16
Res ondent.
Petitioner, pursuant to PCLR 5(b), discloses the following persons who have relevant
factual or expert knowledge whom the Petitioner reserves the option to call as witnesses at trial.
1.
Petitioner discloses the following lay witnesses:
17
a.
Deborah Dahl, Petitioner
18
b.
James Dahl, Respondent
19
PETITIONER'S DISCLOSURE OF
PRIMARY WITNESSES
2.
Petitioner discloses the following expert witnesses:
20
a.
21
22
23
24
W. Cary Deaton
RSM McGladrey
1145 Broadway Plaza, Suite 900
Tacoma, WA 98402-3523
(253) 572-7111
Mr. Deaton may testify as to the valuation of the parties' financials.
25
26
DISCLOSURE OF PRIMARY WITNESSES - I

00256457.DOC

ATTORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 2SJ-S72-4SOO
FAX 2SJ.27257J2
b.
3
4
Timothy Richmond
RICHMOND COMPANY
7522 28th St. W.
University Place, WA 98466
(253) 565-8107
Mr. Richmond may testify as to the value of the parties' real property(ies).
5
Petitioner will timely supplement this disclosure of primary witnesses as discovery
6
continues if further potential witnesses are discovered.

7
DATED this 28th day of July, 2003.
8
9
10
11
, WSBA # 20139
P titioner
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
DISCLOSURE OF PRIMARY WITNESSES- 2
00256457.DOC

AITORNEYS-ATLAW
1201 PACIFIC AVENUE
TACOMA. WASHINGTON98402
PHONE 2SJ-5 72-4500
FAX 253-272-5732
FILED
3
A.M.
AUG -
P.M.
N
~
5
6
7

8
9
NO. 02-3-02768-6
DEBORAH DAHL,
10
I1
12
Petitioner,
vs.
JAMES DAHL,
13
14
PETITIONER'S SUPPLEMENTAL
DISCLOSURE OF PRIMARY
WITNESSES
Res ondent.
Petitioner, pursuant to PCLR 5(b ), supplements her disclosure of the following persons
15
who have relevant factual or expert knowledge whom the Petitioner reserves the option to call as
16
witnesses at trial.
17
1.
18
Petitioner discloses the following lay witnesses:

a.
19
20
Ms. Grier may testify as to the parties' relationship and parenting skills with the children.
21
b.
22
23
24
Chris Grier
I 223 Palm Drive
Fircrest, WA 98466
Patricia DePalma
6602 59th Street Court W.
Ms. DePalma may testify as to the parties' relationship and parenting skills with the
children.
25
26
DISCLOSURE OF PRIMARY WITNESSES - I

0025695 I.DOC

ATTORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 253-572-l 500
FAX 253272-5732
c.
2
Patti McCJean
3935 Mason Loop Road, #C
Tacoma, WA 98409
3
4
Ms. McClean may testify as to the parties' relationship and parenting skills with the
children.
d.
6
7
Theresa Benning
15812 NE Leary Way
Redmond, WA 98052
Ms. Benning may testify as to the parties' relationship and parenting skills with the
children.
8
e.
Mary Schrimshire
3623 E. 32nd
Spokane, WA 99223
10
11
Ms. Schrimshire may testify as to the parties' relationship and parenting skills with the
children.
12
f.
13
14
Valerie Furness
1443 Heatherwood West
Tacoma, WA
Ms. Furness may testify as to the parties' relationship and parenting skills with the
children.
15
g.
16
Carol Dameron
4200A Muledeer Drive
USAF A, Colorado 80840
17
18
Ms. Dameron may testify as to the parties' relationship and parenting skills with the
children.
19
h.
20
21
Sherryl Brown
2358 W. 2200 South
Syracuse, Utah 84075
Ms. Brown may testify as to the parties' relationship and parenting skills with the
children.
22
23
24
Petitioner will timely supplement this disclosure of primary witnesses as discovery

continues if further potential witnesses are discovered.
25
26
DISCLOSURE OF PRIMARY WITNESSES - 2

00256951.DOC

ATIORNEYSATl.AW
1201 PACIFIC AVENUE
PllONE 253572-4500
FAX 253.272.5732
DATED this
4th day
of August, 2003.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
DISCLOSURE OF PRIMARY WITNESSES - 3

00256951.DOC

ATIORNEYS-AT LAW
1201 PACIFIC AVENUE
TACOMA, WASIHNGTON 98402
PHONE 253-572-4500
FAX 253-272-57}2
. II ~\\11 ~
02-3-02768-6
m~ i~ i \ ~ \I ~ ~
19764844
NTSBC
10-03-03
3
4
5
SUPERIOR COURT OF WASHING TON FOR PIERCE COUNTY
6
7
8
Petitioner,
9
10
NO. 02-3-02768-6
DEBORAH DAHL,
SUBSTITUTION OF COUNSEL
v.
JAMES DAHL,
11
Respondent.
12
TO:
DEBORAH DAHL, Respondent, and
TO:
P. CRAIG BEETHAM, her attorney.
13
14
COMES NOW Scott Candoo, and hereby notifies all encaptioned
15
parties that Scott Candoo has been retained by the respondent in the above-entitled
16
17
18
19
20
21
cause and substitutes for respondent's former attorney of record, Richard W. Lockner.
Scott Candoo respectfully requests that all correspondence regarding this matter be
directed to him at his address stated below.
Scott Candoo
2115 N 30th, #202
Tacoma, WA 98403
22
23
Substitituion of Counsel - I
ORIGINAL
Krilich, La Porte,
(253) 383-4 704
1?366
10/3/2063
r:
r:
DATED this
t~
day of September, 2003.
3
By:~
4
5
DATED this
~r,
WSB#J966'1-
'] c::;
day~
6
7
By:
Scott A. Candoo, WSB #7815
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Substitituion of Counsel - 2
Krilich, La Porte,
524 Tacoma 1\ venue South
{253) 383-4704
8fifiS2
18997 11/13/2003 00093

.
IN THE SUPERIOR COURT OF WASHINGTON, COUNTY OF PIER
CauseNo. 02-3-02768-6
DEBORAHJ DAHL,
Petitioner(s) ,
SETTLEMENTCONFERENCESTATUS
VS.
[ ~LO
[ ] CASE SETTLED
SettlementConferenceRequestedby: Craig Beetham
I ] NOT HELD
Lisa572.4500
Assignedto Judge/Commissioner:
R.,..,O=S:<!..A!!.:N!.!..:N!.!::E~B~U~C~K~N!.!::E~R'--------------This case is set for TRIA~i :partment
Scheduledfor hearing
CONTINUEDto
10 on 12/15/2003 9:3?:00 AM
@ /:l_
(date) at
(date) at
/,'l
g. 36 ~
"(time).
(time).
.t7 //
Partiesand Counsel Present:___,,~:::___.;.__
Judge/Cet11111issieAer
NOTES:~---------------------------~
HOLD FORM UNTIL HEARING

HELD OR CANCELED
Rev. (7/01)
02-3-02768-6
20006374
NTER
11-17-03
JN couNrf IL E 0
CLERK'S
Nov 1 4
A.M.
OFFICE
200J P.1,t,
c , WASHtNGr
, ColJnty Cl ON
DEP8f~
';IERCE COUN
slVtN S1i
6
7

8
The Honorable Judge D. Gary Steiner
9
DEBORAH DAHL,
NO. 02-3-02768-6
10
Petitioner,
11
12
NOTIFICATION OF INTENT TO
SUBMIT DOCUMENTARY EVIDENCE
UNDERER904
vs.
JAMES DAHL,
Trial Date:
13
December 15, 2003

9:30 a.m.
Respondent.
14
NOTICE IS HEREBY GIVEN that Petitioner, Deborah Dahl, by and through her
15
attorneys of record, Eisenhower & Carlson, PLLC, and P. Craig Beetham, and submits the
16
following disclosure of documents pursuant to ER 904.
These documents are being offered
17
under Evidence Rule 904 and shall be deemed authentic and admissible
without further
18
testimony or further identification, unless objection is served within 14 days of the date of notice,
19
pursuant to ER 904( c ).
20
Following are documents intended for introduction at trial:
21
22
~.m~ $!~0.:<l@l!liN1IID8ffiS,'1RR0MIDED1t:B:f:'JU-~;'i!~i:r,;~'*K0;'11~~iE~IBI.ffS~'ii1i~"'fi'l~'!111!111
-=:,;,,;,-;'.,.\:(t_"''i~:L.f',')l';.~.,.oj
2000 Income Tax Return
2.
Gary's Business Service, Inc.

8416 Pacific A venue
Tacoma, WA 98444
(253) 535-2711
24
26

8416 Pacific Avenue
Tacoma, WA 98444
(253) 535-2711
23
25
~t~~l -
1.
NOTIFICATION OF INTENT TO SUBMIT AS

DOCUMENTARYEVIDENCE-1
00263621.DOC
ORIGINAL
,e,;.,.j::
;.c'
'\.-
':; ~~i
'.
- ,,
n.

ATIORNEYS-AT-LAW
1200WELLS FARGO PLAZA
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-5732
NO.

8416 Pacific Avenue
Tacoma, WA 98444
(253) 535-2711
4.
PNEC Corporation
1800 W. Katella Ave. #400
Orange, CA 92867
(714) 744-7140
Husband's Pay stubs 01/03 - 02/03
5.
State of Washington
Employment Security Dept.
3738 Pacific Avenue
Lacey, WA 98503
(360) 407-5100
USF Reddaway
P .0. Box 1035
Clackamas, OR 97015

(Unemployment)
7.
Melaleuca, Inc.
Address Unknown
Husband's Pay stubs 04/03 -07/03
8.
Group Health Cooperative

521 Wall Street
Seattle, WA 98121
Wife's Pay stubs 02/02 - 08/02; 11/02 12/02;
9.
Multicare
P.O. Box 5299
MIS: H4-PY
Tacoma, WA 98415-0299
Wife's Pay stubs 02/02 - 08/02; 11/02 12/02; 09/03 - 10/03
10.
University of Washington
Payroll
3903 Brooklyn A venue NE
Seattle, WA 98105
206-543-9202
Wife's Pay stubs 12/02 - 10/03
11.
Sound Credit Union

1331 Broadway Plaza
P.O. Box 1595
Tacoma, WA 98401
(253) 383-2016
Westop Credit Union Account No. 4848

(changed to Sound Credit Union Account
No. 144150) (4/01-6/03) (joint)
12.
Columbia State Bank - Fircrest

2401 Mildred Street West
Tacoma, WA 98466
6
7
8
9
10
6.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
EXHIBITS:
3.
DOCUMENTS PROVIDED BY:
Husband's Pay stubs 07/03; 10/03
Columbia State Bank Checking and PRA

Loan Account No. 1000095644 (8/01; 4102;
10/02; 12/02-1 /03; 3/03; 5103- 7103) (joint)
26

DOCUMENTARY EVIDENCE-2
0026362 I .DOC

AITORNEYS.AT-LAW
1201 PACIFIC AVENUE
TACOMA, WASHJNGTON 9S402
PHONE 253-572-4500
FAX 2SJ-272S732
1
2
fNO.
13.

Washington Mutual
P.O. 91006
Seattle, WA 98111
Washington Mutual
James Center Financial Center
6916- 19th Street W.
University Place, WA 98466-5543
(253) 305-5390
Washington Mutual Checking Account No.

179-413033-5 (2/02-11 /02; 4/03- 7/03)
15.
Washington Mutual
James Center Financial Center
6916 - 19th Street W.
University Place, WA 98466-5543
(253) 305-5390
Washington Mutual Checking Account No.

516-300114-3 (3/02) (rental property joint)
16.
Washington Mutual Home Loans

Loan Servicing Dept.
P.O. Box 834-KEY2004
Seattle, WA 98111
(800) 282-4840
Loan Information on 916 Manor Drive,

Fircrest (Primary Residence)
17.

Seattle, WA 98111
(800) 282-4840
Loan Information and 1994 refinance on

228 Contra Costa Avenue, Fircrest (Rental)
18.

Seattle, WA 98111
(800) 282-4840
Loan Information/ Appraisal/Tax

Assessments/2001 refinance on 25812 120th
Lane SW, Vashon (Beach)
19.
Multicare Health System

Lincoln Alliance Processing Agent
3800 N. Wilke Road, Suite 250
Arlington Heights, IL 60004
Multi care 403(b) Employee Savings Plan

(Wife) (5/02; 6/03)
20.
Putnam Investments
Address Unknown
(800) 700-8352
Southern Counties Oil Company 401(K)

Plan (Husband) (1102-3/02; 7/02-9/02; 3/03)
14.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Washington Mutual Checking and LOC

Account No. 387-4476390 (6/01-7/03)
(joint)
4
5
EXHIBITS:
21
(joint)
22
23
24
25
26

DOCUMENTARY EVIDENCE - 3
00263621.DOC

A ITORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 25J-27l-57J2
NO.
21.
TOC- Woodworkers, I.A.M.

Benefit Plans
2922 NW 3151 A venue
Portland, OR 97210
(503) 222-9603
TOC - Woodworkers, IAM Defined

Contribution Plan (Husband) (5/01; 3/03)
22.
Rainier Pacific Bank

P.O. Box 11628
Tacoma, WA 98411-6628
(253) 926-4000
Rainier Pacific Boat Loan Account No.

114 792 (2/02; 5102; 9/02)
23.
JCPenney
P.O. Box 981131
El Paso, TX 79998
(800) 527-0881
Credit Card Debt:

JCPenney 12/02 $0 balance (Wife)
24.
Capital One Services

P.O. Box 85015
Richmond, VA 20285-5015
(800) 903-363 7
Credit Card Debt:

Capital One Mastercard (12/02) ($2,195
balance) (Wife)
25.
Chevron Credit Bank, N .A.

Address Unknown
(800) 222-0585
Credit Card Debt:

Chevron (12/02) ($920 balance) (Wife)
26.
State Highway Employee Visa

P.O. Box 8003
Arvada, CO 80001-8003
(800) 247-4222
Credit Card Debt:

State Highway Employee Visa (12/02)
($4,600 balance) (Wife)
27.
Old Navy
P.O. Box 103090
Roswell, GA 30076
(877) 222-6868
Credit Card Debt:

Old Navy (12/02) (-0- balance) (Wife)
28.
Bank of America
P.O. Box 53132
Phoenix, AZ 85072-3132
(800) 732-9194
Credit Card Debt:

Bank of America Visa #4888603203622089
(9/02-5/03) (Husband)
29.
Bank of America
P.O. Box 5270
Carol Stream, IL 60197-5270
(800) 732-9194
Credit Card Debt:

Bank of America Visa #4888603201510898
(9102-5103) (Husband)
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
EXHIBITS:
25
26

DOCUMENTARY EVIDENCE-4
00263621.DOC

ATIORNEYSATLAW
1201 PACIFIC AVENUE
PHONE zss-sra-ece
f AX 253-2725732
NO.
30.

Capital One Services
P.O. Box 85015
Richmond, VA 20285-5015
(800) 903-3637
EXHIBITS:
Credit Card Debt:
Capital One (10/00-8/03) (Husband)
31.
Columbia State Bank - Fircrest

2401 Mildred Street W.
Tacoma, WA 98466
(253) 566-1172
Credit Card Debt:

Columbia Bank PRA Loan (7/02; 8/02;
10/02; 12/02; 3/03; 6/03) (Husband)
32.
Deborah Dahl
c/o Eisenhower & Carlson, PLLC
Wells Fargo Plaza, Suite 1200
1201 Pacific Avenue
Tacoma, WA 98402
(253) 572-4500
Handwritten List by Wife of

Assets/Liabilities
33.
ADP Benefit Services

P.O. Box 2968
Alpharetta, GA 30023-2968
(800) 526-2720
Husband's Cobra Election Documentation

from PNEC/Southem Counties Oil
34.
James Dahl
c/o Scott Candoo
2115 North 30th, Suite 202
Tacoma, WA 98403
(253) 272-7274
1201 Pacific Avenue
Tacoma, WA 98402
(253) 572-4500
Husband's Employment Search
Dan Engell, Associate Broker

Coldwell Banker Hawkins-Poe
5929 Westgate Blvd., Suite A
Tacoma, WA 98406
(253) 752-7818
Estimate of Current Market Value of 228

Contra Costa Avenue, Fircrest (Rental)
3
4
5
6
7
8
9
10
11
12
13
14
15
16
35.
17
18
19
20
21
22
36.
Wife's Attorney's Fees from 05/28/02

through 10/31103
DATED this 14th day of November, 2003.
23
24
25
26

DOCUMENTARY EVIDENCE - 5
00263621.DOC

A TTO~YSATl.A W
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-5732
19189 11/13/288~
.JI
FILED
IN COUNTY CLERK'S Of F\C
A.M.
I rn 111111111111 U
02-3-02760-6
20009265
PLLW
NOV 1 7 2003
P.M.

BY
L{
DEPUTY
11-18-03
4
5
6
7

8
The Honorable Judge D. Gary Steiner
9
DEBORAH DAHL,
10
11
12
NO. 02-3-02768-6
Petitioner,
PETITIONER'S TRIAL WITNESS AND
EXHIBIT LIST PURSUANT TO PCLR 1
AND PCLR 3(b)(2)
VS.
JAMES DAHL,
13
Trial Date:
Respondent.
14
December 15, 2003

9:30 a.m.
Petitioner, Deborah Dahl, by and through her attorneys of record, Eisenhower & Carlson,
15
PLLC and P. Craig Beetham, pursuant to PCLR 3(b)(2), discloses the following persons who
16
have relevant factual or expert knowledge whom the Petitioner reserves the option to call as
17
witnesses at trial:
18
19
20
21
22
23
24
25
A. Deborah Dahl
c/o P. Craig Beetham
Tacoma, WA 98402
(253) 572-4500
B. James Dahl
c/o Scott Candoo
2115 North 30th, Suite 202
Tacoma, WA 98403
(253) 272-7274
Respondent is expected to testify as to the

parties' relationship and parenting skills with
the children.
26

EXHrBIT LIST
00263861.DOC

"".
-I
ORIGINAL
AITORNEYS-ATLA W
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-5732
08843
i9189 ii/18/200~
2
3
4
C. Patti McClean
3935 Mason Loop Road, #C
Tacoma, WA 98409
D. Theresa Benning
15812 NE Leary Way
Redmond, WA 98052
Ms. Benning is expected to testify as to the

the children.
E.
Patricia DePalma
6602 59th Street Court W.
Ms. DePalma is expected to testify as to the

the children.
F.
Chris Grier
1223 Palm Drive
Fircrest, WA 98466
Ms. Grier is expected to testify as to the

the children.
7
8
9
JO
11
12
G. W. Cary Deaton
Dock Street Litigation and Valuation, LLC
535 East Dock Street, #209
Tacoma, WA 98402
(253) 573-9500
Mr. Deaton may testify as to the valuation of

the parties' financials.
H. Mr. Timothy R. Richmond

RICHMOND COMPANY
7522 28th St. W.
253 565-8107
Mr. Richmond may testify as to the value of

the parties' real property(ies).
13
14
15
16
EXHIBITS
17
Pursuant to PCLR 3(b)(2), Petitioner hereby submits the following exhibits to be used at
18
19
20
21
22
23
24
trial:
l-..Q!'!I ~~,;~~
. ~'!:~:11~~~i~:~'~;.-,:.
'E~H)I1B1ms=-~
"
......)("'t~ii6i'-;';,
lillf:. '
..... '
' ' c '' . 11
I.
2.
3.
4.
Husband's Pay stubs 01/03 -02/03
5.
Husband's Pay stubs 02/03 - 06103 (Unemployment)
6.
Husband's Pay stubs 07/03; 10/03
7.
25
26
PETITIONER'S TRIAL WITNESS ANO

EXHIBIT LIST
00263861.DOC
~.~fiF~: ~.-):.;iii~:t~
1

-2
ATIORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 2S3-S72-4SOO
FAX 2SJ-272-H32
00044
,:i::J:.
t:~<'
'~!l~lfn::w>
(H'-'
.:
",
"".<
EXHTB.UI'S:"W'.
NO~
8.
Wife's Pay stubs 02/02 - 08/02; 11/02 - 12/02;
9.
Wife's Pay stubs 02/02 - 08/02; 11/02 - 12/02; 09/03 - 10/03
10.
Wife's Pay stubs 12/02 - 10/03
11.
Westop Credit Union Account No. 4848 (changed to Sound Credit Union Account
No. 144150) (4/01-6/03) (joint)
12.
Columbia State Bank Checking and PRA

Loan Account No. 1000095644 (8/01; 4/02; 10/02; 12/02-1103; 3/03; 5/03-7/03)
)!{\';
r,
.:'; \~:-.w::J
.... !
'+:
>
i- -")~ .:
-- ..
'
>
:~ ~
'"':\'':\~:'~~
3
4
5
6
7
8
(joint)
13.
Washington Mutual Checking and LOC Account No. 387-4476390 (6/01-7/03) (joint)
9
14.
Washington Mutual Checking Account No. 179-413033-5 (2/02-11/02; 4/03-7/03)

(joint)
15.
Washington Mutual Checking Account No. 516-300114-3 (3/02) (rental property

joint)
13
16.
Loan Information on 916 Manor Drive, Fircrest (Primary Residence)
14
17.
Loan Information and 1994 refinance on 228 Contra Costa A venue, Fircrest (Rental)
15
18.
Loan Information/Appraisal/Tax
SW, Vashon (Beach)
19.
Multicare 403(b) Employee Savings Plan (Wife) (5/02; 6/03)
20.
Southern Counties Oil Company 401(K) Plan (Husband) (1102-3/02; 7/02-9/02; 3/03)
21.
TOC - Woodworkers, IAM Defined Contribution Plan (Husband) (5/01; 3/03)
22.
Rainier Pacific Boat Loan Account No. 114 792 (2/02; 5/02; 9/02)
23.
Credit Card Debt:

JCPenney 12/02 $0 balance (Wife)
24.
Credit Card Debt:

Capital One Mastercard (12/02) ($2,195 balance) (Wife)
25.
Credit Card Debt:

Chevron (12/02) ($920 balance) (Wife)
26.
Credit Card Debt:

State Highway Employee Visa (12/02) ($4,600 balance) (Wife)
10
11
12
16
17
18
Assessments/2001 refinance on 25812 120u' Lane
19
20
21
22
23
24
25
26

EXHIBIT LIST
00263861.00C
-3
ATTORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-57)2
'.
19189 11~18/2003 00046
1
2
3
~r\i$~tm!Jl!l~lij,iiffm~!~~!M/l~E~IBITS
~.m'f~ ~'"!l ir.!i!!'mtr~:~,1~~Q~~;i~.j\f
r~.. l<1 ~'1.:1!~'1kr.
.b
t_.,
1
,,.tf<hr
,[ . r1~:~.~
ifi_';~-.
ri.JJ,
!11.1''.f''I> .' .'
'
.,
'
28.
Credit Card Debt:

Bank of America Visa #4888603203622089 (9/02-5/03) (Husband)
29.
Credit Card Debt:

Bank of America Visa #4888603201510898 (9/02-5/03) (Husband)
30.
Credit Card Debt:

Capital One (10/00-8/03) (Husband)
31.
Credit Card Debt:

Columbia Bank PRA Loan (7/02; 8/02; 10/02; 12/02; 3/03; 6/03) (Husband)
32.
Handwritten List by Wife of Assets/Liabilities
33.
Husband's Cobra Election Documentation from PNEC/Southem Counties Oil
34.
Husband's Employment Search
35.
Wife's Attorney's Fees and Costs from 05/28/02 through 10/31/03
36.
Estimate of Current Market Value of 228 Contra Costa Avenue, Fircrest (Rental)
7
8
27.
-e
Credit Card Debt:

Old Navy (12/02) (-0- balance) (Wife)
J~I
9
10
11
12
13
14
15
The above documents have been previously produced or are in the possession of the
Defendants.
16
17
18
19
20
21
22
23
Petitioner reserves the right to call any witnesses identified in Respondent's Disclosure of
Witnesses, Experts and Exhibits, and to offer as an exhibit any document disclosed by
Respondent; Petitioner also reserves the right to supplement this witness list with names of
additional witnesses who may become known to Petitioner between now and the time of trial;
Petitioner also reserves the right to supplement this exhibit list with documents that may become
known between now and the time of trial.
DATED this
.r:
day of November, 2003.

24
25
26
SBA #20139

EXHIBIT LIST
00263861.DOC
-4
ATIORNEYS-AT-LAW
1201 PACIFIC AVENUE
PHONE 2S3-S72-4SOO
FAX 253-272-5732
19312 11/2012003 000G3
FILED
02-3-02768-6
20028494
In Re Marriage of:
3
Deborah Dahl
Petitioner
4
and
5
6
A.M.
11-20-03
NOV 1 9 2003
THE SUPERIOR COURT OF THE ST A TE OF WASHINGTON

1
2
SCR
James Dahl
Respondent
~--------------~)
TO:
)
)
No. 02 3 02768 6
SETTLEMENT CONFERENCE REPORT
)
)
)
)
)
The Clerk of the Court

Judicial Clerk to Judge Steiner
10
11
The above-named parties attended a facilitated settlement conference at the Pierce County Center
for Dispute Resolution held on November 18, 2003
Petitioner's Attorney: P. Craig Beetham
Respondent's Attorney: Scott Candoo
12
13
MEDIATOR:
r present
;z::. present
__ not present
__ not present
Terrance McCarthy
The outcome of the Settlement Conference was:
14
15
Lwritten
agreement on terms with a copy to attorneys and parties.
16
17
18
Respectfully submitted on November,!~
19
..JC:...-----'--~~~"77~=-~=-----~
Pierce County Center for Dis
Case 031118856
20
21
22
23
24
SETTLEMENT CONFERENCE REPORT
PIERCE COUNTY CENTER FOR DISPUTE RESOLUTION
917 PACIFIC AVENUE, SUITE 206

TACO~A, WA 98402
PHONE: (253) 572-3657 /FAX: (253)572-3579
P.M.
19556 11~26/20
02-3-02768-6
20062853
11-25-03
NTSSTD
f \ l. ~J>K'S Off\CE.
ltl COUNTY CL
NOV 2 6 1003 P.ta.
y WASHINGTON
UN >L 'count)' Cler\J11("
:T "'
OEP I
~M.
5
6
7

8
9
NO. 02-3-02768-6
DEBORAH DAHL,
10
11
12
Petitioner,
vs.
JAMES DAHL,
13
14
NOTICE OF SETTLEMENT OF ALL

CLAIMS AGAINST ALL PARTIES
DOCKET CODE: NTSSTD
Res ondent.
Notice is hereby given that all claims against all parties in this action have been resolved.
15
Any trials or other hearings in this matter may be stricken from the court calendar. This notice is
16
being filed with the consent of all parties.
17
18
19
If an order dismissing all claims against all parties is not entered within 90 days after the
written notice of settlement is filed, the case shall be dismissed by the court.
DA TED this
?.(
20
21
CERTIF~CATE OF ~MAil~
22
PERSONAL SERV~CE
23
24
25
26
IGINAL.
NOTICE OF SETTLEMENT - 1
00264575.DOC
EISENHOWER & CARLSON, PL.LC

A TTORNEYSATLAW
1201 PACIFIC AVENUE
Pll0Nll 2Sl-572-4500
FAX 253-272-57)2
3 00867
19636
02-3-02768-6
20075644
CME
12/1/2083
12-01-03
NOV 2 ~ 2003
s:.~Ji:;;.
IN THE SUPERIOR COURT, PIERCE COUNTY, WASHING
DEBORAH J DAHL
MEMORANDUM
Petitioner(s)
vs.
OF JOURNAL ENTRY
Page 1 of 1
JAMES R DAHL
Respondent(s)
Judge: D GARY STEINER
Court Reporter: ANGELA MCDOUGALL
DAHL, DEBORAH J
P. CRAIG BEETHAM
DAHL. JAMES R
Scott Alexander Candoo
DAHL, AMANDA
DAHL, SARAH J
DAHL, ELIZABETH R
Proceeding Set: Trial

Proceeding Outcome: Cancelled/Stricken
Outcome Date: 11/26/2003 9:47
Resolution:
Clerk's Scomis Code: HSTKNA
Proceeding Outcome code: CANC

Amended Resolution code:
Report run date/time: 11126103 9:47 AM

lxcalcivil.pbl.d_civil_jouma/_reporl_ cover
00055
9219
12/19/2
\11\\~\l~~l\~\ \~U~l\~~l\I\
02-3-02768-6
20191687
NTAB -
12-18-03
5
6
7
8

NO. 02-3-02768-6
9
DEBORAH DAHL,
Petitioner,
10
11
12
OF COUNSEL
vs.
JAMES DAHL,
13
Res ondent.
14
TO:
CLERK OF THE COURT
15
AND TO:
SCOTT CANDOO, attorney for Respondent
16
YOU AND EACH OF YOU please take notice that attorney P. Craig Beetham will be
17
unavailable from December 24, 2003 through January 2, 2004 and will be returning to the office
18
on January 5, 2004.
19
PLEASE REFRAIN from filing .or attempting to serve, any motions or other forms of
20
expedited pleading practice that would conflict with the undersigned's
21
period specified.
unavailability for the
22
23
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26
.--'"'---
NOTICE or UNAVAILABILITY or c~
00265683.DOC
\NA l \ EISENHo~::=v~::~;oN, PLLc

1201 PACIFIC AVENUE
PHONE 253-572-4500
FAX 253-272-57l2
03 00063
9219
12/19/2
./
DATED this
JC
day of December, 2003.
2
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NOTICE OF UNAVAILABILITY OF COUNSEL - 2
00265683.DOC

ATTORNEYS-AT-LAW
1201 PACIFIC AVENUE
TACOMA. WASHINGTON98402
PHONE 25J .5 72-4500
FAX 25J-272-S732
03 00069
10341
02-3-02768-6
20344999
1/21/2004
01-21-04
NTIS
\M eouN.J
J\;M.
b\:.!t&s ol'PICE
JAN '2 fl 2004
P.M.
PIERCE COUNTY, WASHli<fT~N

JeJIN STOCK,~unty~UIY

DAHL, DEBORAH J
Plalntlff(s),
Case No. 02-3-02768-6
vs.
DAHL, JAMES R
Defendant(s).
NAME
P. CRAIG BEETHAM
WSB# 20139
ADDRESS
We 11 s Fargo Plaza/ 1201 Pacific Ave Ste 1200
(Please note addltlonal
PHONE (253) 572-4500
~~~~~~~~~-
attcmeys on an attached page)
Dissolution - Entry of Final Documents

Dated: January 14, 2004
-~~~~~~~~~
NAME

~~~~~~~~~~~~~~~-
WSB# 7815
ADDRESS
2115 N 30th St Ste 201
~~~~~~~~~~~~~~~-
TAC 0 MA WA 98403-3397
~~~~~~~~~~~~~~~-
PHONE (253) 272-7274
ORIGINAL
FORMS\MOTIONNOTE3-2001.DAC
00020
02-3-02768-6
20449329
AST
02-06-04
IN THE SUPERIOR COURT OF WASHINGTON, COUNTY OF PIERCE

DEBORAH J DAHL
No. 02-3-02768-6
Petitioner(s)
Request for Reassignment
vs.
JAMES R DAHL
[ v(
Respondent(s)
Plalntiff/Petitioner's Attorney
P. CRAIG BEETHAM
] For Trial
For Motion Only
Defendant/Respondent's Attorney
For due cause shown (Continuing Case/Other) the above entitled action is referred to Administration
from Dept.
for reassignment.
Case shall trail. [
] Yes [
] No
Date: January 30, 2004

Judge/Judicial Assistant
entitled, action is reassigned for h_earir:g to Dept. No.
. I
, Judge
, this ::.
day of
,
206.Q, at
/-;J.... : ~-o a:m~
All parties are to report directly and immediately t the
above numbered department if reassignment is for immediate trial.
(..Y'The abye
.,!l./'lM.-&- ~
( ) Case is to remain in Dept. No.

, Judge.
assigned to a visiting judge (VISt) on __ day of
be entered in notefield of case heading in SCOMIS.
__,....,.- for monitoring purposes, but

, 20_. VISITING JUDGE should
( ) All parties DID I DID NOT comply with Rule 40 (e)(3) by waiting until properly excused. PRIORITY
SETTING IS / IS NOT RECOMMENDED.
Case trailed for: [
/
(~Court
//
file and all parties present in Dept./1---
( ) For due cause shown (Continuing Case/Other)

Administration from
Dept.
for
of
, 20
, at
Printed: January 30, 2004

lxreport.pblld_civil_resssignment_repott {rev. 1123102
Calen arCoordinator
at
a.m./p.m.
the above entitled action is referred to
Dated
this
day
_
I l I\ 111111111 ~ I
02-3-02768-6
20738565
DCD
03-28-04
2
3
4
5
flLED
DEPT. 10
6
N OPEN COUR

COUNTY OF PIERCE
8
9
10
13
NO. 02-3-02768-6
DEBORAH J. DAHL
DECREE OF DISSOLUTION
11
12
MAR 2.., 2004
(DCD)
Petitioner,
and
JAMES R. DAHL
Respondent.
14
I. JUDGMENT/ORDER
15
16
1.1
1.2
REAL PROPERTY JUDGMENT SUMMARY:

Real Property Judgment Summary is set forth below:
19
20
ORDER SUMMARY:
Does not apply.
17
18
RESTRAINING
SUMMARIES
Assessor's property tax parcel or account number:
21
or
22
23
24
Legal description of the property awarded (including lot, block, plat, or section, township, range,
II
DECREE (DCD) (DCLSP) (DCINMG) - Page 1 of 6
WPF DR 04.0400 (7/2003) - RCW 26.09.030; .040; .070
FamilySoft FonnPAK 2003
f"1 R J G f
ts1
NA L
SCOIT CANDOO
Attorney at Law
2115 N. 30th Street, Suite 201
Tacoma, WA 98403
(253)272-7274 - Office
county and state):

1. 916 Manor Drive, Fircrest, Washington. Legal Description:
N.W. 142002 Linden Manor 3rd.
2. 25812 - 120th Lane S.W., Vashon, Washington. Legal Description:
South 115 feet of the North 850 feet of the East 10.20 acres of government lot 1,
Section 25, Township 22 North, Range 2 East W.M.; Together with second class tide
lands situate in front of, adjascent to, or abutting upon said premises as conveyed by
the State of Washington under Deeds recorded under King County recording Nos.
7507110567 and 7507110568. Situate in the County of King, State of Washington.
5
6
3. 228 Contra Costa Ave., Tacoma, Washington. Legal Descrtption:
Lots 11, 12, and 13, in block 5 of Regent's Addition, as per plats, recorded in
volume 8 of plats, page 73, records of Pierce County Auditor.
10
See Page
for full legal description.
11
12
1.3
Does not apply. Refer to judgment set forth in Order of Child Support, filed herewith.
13
14
MONEY JUDGMENT SUMMARY:
END OF SUMMARIES
II. BASIS
15
16
Findings of Fact and Conclusions of Law have been entered in this case.
Ill. DECREE
17
18
19
IT IS DECREED that:
3.1
The marriage of the parties is dissolved.
20
21
22
23
24
STATUS OF THE MARRIAGE.
3.2
PROPERTY TO BE AWARDED THE HUSBAND.

The husband is awarded as his separate property the following property (list real estate,
furniture, vehicles, pensions, insurance, bank accounts, etc.):
1. Real Property located at 25812 120th Lane S.W., Vashon, Washington 98070.
II

WPF DR 04.0400 (7/2003) - RCW 26.09.030; .040; .070 (3)
SCOTI CANDOO
Attorney at Law
2115 N. 30th Street, Suite~
Tacoma, WA 98403
(253)272-7274 - Office
2. Lien on real property located at 228 Contra Costa, Tacoma, Washington in the sum
of $25,000.00.
1
2
This property is to be sold by listing and should the equity be less than $73,000,
then and in that event, the $25,000 shall be reduced at rate of 50 cents for every dollar
less than the $73,000. Conversely, should the property net greater than $73,000, the
Husband's amount shall be the $25,000 plus 50 cents for every dollar greater.
3
4
3. 1992 Chevrolet Silverado.
4. 1989 Bonneville.
5. 1980 Toyota Celica.
6. 2002 Sea Swirl Boat.
7. Westop Credit Union Account.
8. Columbia State Bank Account.
10
9. Washington Mutual Bank Account #6390.
11
10. Southern Oil 401 (k).
12
11. 68.5% of Woodworkers' IAM Pension Plan.
13
12. 50% of Wookworkers' Defined Benefit Plan.
14
13. Ameris Life Insurance Policy cash value received of $7,000.
15
14. Personal property presently in his possession.
16
15. Any and all other retirement benefits that have been disclosed accruing to him by
virtue of his employment.
17
18
19
20
21
22
23
24
3.3
PROPERTY TO BE AWARDED TO THE WIFE.

The wife is awarded as her separate property the following property (list real estate,
furniture, vehicles, pensions, insurance, bank accounts, etc.):
1. Real Property located at 916 manor Drive, Fircrest, Washington.
2. Real Property located at 228 Contra Costa Ave., Tacoma, Washington, subject to the
requirement that said property be listed and sold and all proceeds to Wife, except for
those awarded above to Husband.
3. 2001 Chevrolet Tahoe.
DECREE (DCD} (DCLSP) (DCINMG) - Page 3 of 6
WPF DR 04.0400 (7/2003) - RCW 26.09.030; .040; .070 (3)
SCOTI CANDOO
Attorney at Law
2115N. 30th Street, Suite~
Tacoma, WA 98403
(253)272-7274 - Office
FamilySofi FonnPAK 2003
4. Washington Mutual Account #0335.
5. Multicare 403(b) Plan in her name.
6. Her IRA.
7. 31.5% of Woodworkers'
8. 50% of Woodworkers'
10. All other retirement benefits that have been disclosed accruing to her by virtue of
her employment.
Other:
Because Wife is awarded the rental and responsible for the mortgage on the rental
pending sale, she shall be entitled to all rental receipts pending said sale.
10
3.4
12
LIABILITIES TO BE PAID BY THE HUSBAND.

The husband shall pay the following community or separate liabilities:
13
1. Mortgage of real property located at 25812 120th Lane S.W., Vashon, Washington.
14
2. Bank of America Visa (1).
15
3. Bank of America Visa (2).
16
4. Capital One account(balance
17
as of 9/02)
$15,299
5. Columbia Bank PRA
18
6. Westop Credit Union loan
19
7. Rainier Pacific boat loan
20
8. Washington
21
$9,595
Mutual PLC
9. Debt to Respondent's mother
22
$12,000
Unless otherwise provided herein, the husband shall pay all liabilities incurred by him
since the date of separation.
23
24
Defined Benefit Plan.
9. Personal property presently in her possession.
11
IAM Pension Plan in Husband's name.
II
WPF DR 04.0400 (7/2003) - RCW 26.09.030; .040; .070 (3)
SCOTI CANDOO
Attorney at Law
2115 N.
30th Street, Suite g_Q!
Tacoma, WA 98403
(253)272-7274 - Office
3.5
The wife shall pay the following community or separate liabilities:
1. Mortgage on Manor Drive.
2. Mortgage on Contra Costa.
3. JC Penney account.
4. Colleague Services VISA.
5. Capital One Mastercard(balance
3.6
12
14
3.7
3.8
CONTINUING
RESTRAINING
ORDER.
Does not apply.
18
3.9
JURISDICTION
OVER THE CHILDREN.
The court has jurisdiction over the children as set forth in the Findings of Fact and
Conclusions of Law.
20
3.10
22
PARENTING PLAN.
The parties shall comply with the Parenting Plan signed by the court on
The Parenting Plan signed by the court is approved and incorporated as part of this
decree.
23
24
SPOUSAL MAINTENANCE.
Does not apply.
16
21
HOLD HARMLESS PROVISION.

Each party shall hold the other party harmless from any collection action relating to
separate or community liabilities set forth above, including reasonable attorney's fees
and costs incurred in defending against any attempts to collect an obligation of the other
party.
13
19
$3,000.00
Unless otherwise provided herein, the wife shall pay all liabilities incurred by her since
the date of separation.
10
17
$2,197.00
7. Chevron debt
15
as of 11-02)
6. SLM Financial
11
LIABILITIES TO BE PAID BY THE WIFE.
II
WPF DR 04.0400 (7/2003) - RCW 26.09.030; .040; .070 (3)
SCOTI CANDOO
Attorney at Law
Tacoma, WA 98403
(253)272-7274 - Office
3.11
CHILD SUPPORT.
Child support shall be paid in accordance with the order of child support signed by the
court on 1J.'.,. v (.This order is incorporated as part of this decree.
2
3
4
3.12
ATTORNEY'S FEES, OTHER PROFESSIONAL FEES AND COSTS.
3.13
NAME CHANGES.
Does not apply.
3.14
For purposes of paragraph 3.2 and calculation of equity, said calculation shall include
"out-of-pocket" expenses that the parties or either of them expen
reparing the home for
OTHER.
1'/'
sale.
-f/f'~
/:
//,,.,.,,_._
J H'- o <f
9
FILED
10
Dated:
3 "" 240 - o cf
11
DEPT. 10
JUJuidcdgreeJ.~t((;f!~rr---ftN
OPEN COOR
Mf.r.t 2 5 200~
12
Approved for entry:

Notice of presentation waived:
13
County Cler1<
14
15
16
sco~
W.S.B.A. #7815
17
18
19
.la_
4-CtcLL
JAMES R:om
Respondent
Craig Beetham
W.S.B.A. #20139
Attorney for Petitioner
J<.<
dterr~L
DEBORAH J. DAHL
Petitioner
'.
20
21
22
23
24
WPF DR 04.0400 (7/2003) - RCW 26.09.030; .040; .070 (3)
SCOTT CANDOO
Attorney at Law
2115 N. 30th Street, Suite ~
Tacoma, WA 98403
(253)272-7274 - Office
....'
..
..
-:'.'
3.11
CHILD SUPPORT.
Child support shall be paid in accordance with the order of child support signed by the
court on 7 -~Gt o
This order is incorporated as part of this decree.
--
3
4
3.12
ATTORNEY'S FEES, OTHER PROFESSIONAL FEES AND COSTS.
3.13
NAME CHANGES.
Does not apply.
3.14
OTHER.
NIA
8
9
Dated: ] r)..,
oc.f
Judge/Commissioner
10
11
Presented by:
12
Approved for entry:

13
14
15
16
17
18
W.S.B.A. #7815
L/JM
AMES R. DAHL
Respondent
19
20
21
22
23
24
WPF DR 04.0400 (7/2003) - RCW 26.09.030; .040; .070 (3)
. SCOTI CANDOO
Attorney at Law
Tacoma, WA 98403
(253)272-7274 - Office
02-3-02766-6
20576007
__ -J'e\~a o~f\Cf.
NT\S
'"GOU~
"lA
rt.9
" i 7.~M
/J
?.~.
o~
'N~sr\\N.G~~
E~tt~%l~~'(
~\~~
PIERCE COUNTY SUPERIOR COURT, STATE O:WASHINGTON
DAHL, DEBORAH J
Plalntiff(s),
Case No. 02-3-02768-6
vs.
DAHL, JAMES R
Defendant(s).
NAME
_P_. _C_RA_l_G_B_E_E_T_H_A_M
WSB# 20139
ADDRESS
Wells Fargo Plaza/ 1201 Pacific Ave Ste 1200
---------------note
PHONE (253) 572-4500
(Please
addlllonal attorneys on an attached page)
Formal Proof
March 12, 2004
at 9:00 am
Nature of case: Formal Proof/Presentation

Dated: February 27, 2004
NAME
ADDRESS

---------------2115 N 30th St Ste 201
---------------TACOMA WA 98403-3397
----------------
WSB# 7815
----------

PHONE (253) 272-7274
FORMS\MOT10NNOTE3-2001.DAC
02-3-02768-6
20651134
NTI S
03-11-04
IN
coumf 'dr.fR~'s OFFICE
A.M.
MAR 1 1 2004
P.M.
ASHINGTON
ounty Cieri<
_.,.,.__DEPUTY
___

)
)
)
)
)
)
)
)
)
)
)
DAHL, DEBORAH J
Plaintiff(s),
vs.
DAHL, JAMES R
Case No. 02-3-02768-6

Defendant( s).
NAME
_S_C_O_TT_A_L_EX_A_N_D_E_R_C_A_N_D_O_O
~WSB#_7~8_1~5
ADDRESS
2115 N 30th St Ste 201

---------~---~~-
_T_A-'-C-'-O_M_A_W_A_9_8_4_03_-_33_9_7
PHONE (253) 272-7274
(Please note additional attomeys on an attached page)
Formal Proof/Presentation of final pleadings

The hearing is requested to be held during the regular motion calendar on:
March 26, 2004
at9:00 am
Nature of case: Dissolution with Children

Dated: March 10, 2004
NAME
P. CRAIG BEETHAM
ADDRESS

---------~----~-
ORNEY FOR Petitioner

PHONE (253) 572-4500
FORMS\MOTIONNOTE3-2001.DAC
ORIGINAL
02-l-02768-6
20739556
0~26-04
CME
FILED
DEPT. 10
IN OPEN COUR
MAR 2 6 2004
Pier"~'ty
Clerk
9Yf/.Ef:1un-

DEBORAH J DAHL

Petitioner(s)
vs.
Page 1of2
JAMES R DAHL
Respondent(s)
Court Reporter: CARLA HIGGINS
DAHL. DEBORAH J
P. CRAIG BEETHAM
Atta rney for Plaintiff/Petitioner
DAHL, JAMES R
SCOTT ALEXANDER CANDOO
DAHL, AMANDA
DAHL, SARAH J
DAHL, ELIZABETH R
Proceeding Set: Motion

Proceeding Outcome: Motion Held
Outcome Date: 03/26/2004 11 :29
Resolution:
Clerk's Scomis Code:MTHRG

Amended Resolution code:
Report run date/time: 03/26/04 11 :32 AM

lxca/civil.pbl.d_civil.)ouma/_report_cover

DEBORAH J DAHL

vs.
Page: 2 of 2
JAMES R DAHL
Start Date!Time: 03/26/04 11 :29 AM
Court Reporter:CARLA HIGGINS
March 26, 2004 11 : 29 AM

Matter comes on for formal proof. Attny Scott Candoo present with respondent.
Respondent, James Dahl sworn and testifies as to formal proof. 11 :31 AM Final papers
signed.
End DatefTime:
JUDGE D GARY STEINER Year 2004
Page: __
It
,_
02-3-02768-6
20738557
ORODR
03-26-04
2
3
FILED
DEPT. 10
IN OPEN COOR
4
5
MAR 2 6 2004
6
7
IN THE SUPERIOR COURT OF THE STATE OF WASHIN
8
9
10
IN RE THE MARRIAGE OF:

DEBORAH J. DAHL,
11
12
13
Petitioner,
and
JAMES R. DAHL,
14
15
16
Respondent.
)
)
)
)
)
)
)
)
)
)
)
NO. 02-3-02768-6
QUALIFIED DOMESTIC RELATIONS
ORDER RE: TIMBER OPERA TORS COUNCILWOODWORKER' SIAM DEFINED
CONTRIBUTION PLAN AND TRUST
~~~~~~~~~~~~)
1.
Effect of this Order. This Order recognizes the right of Alternate Payee to receive
17
all or a portion of Participant's benefits payable under a retirement plan qualified under the
18
Internal Revenue Code of 1986, as amended (the "Code"). This Order is intended to be a
19
qualified domestic relations order ("QDRO") under section 414(p) of the Code and section
20
206(d)(3) of the Employee Retirement Income Security Act of 1974, as amended.
21
22
23
24
25
2.
Definitions.
a.
Participant is JAMES R. DAHL. The last known address, telephone
number, birth date and social security number of Participant are:

Name:
Address:
Birth Date:
SSAN#:
26
27
28
QUALIFIED DOMESTIC RELATIONS ORDER RE: TIMBER

OPERATORS COUNCIL-WOODWORKER'S
~DEFINED
CONTRIBUTION PLAN AND TRUST - 1
u K I G I NA L
law Office of
SCOTT CANDOO
Tacoma, WA 98403
(253) 272-7274
...
1
b.
Alternate Payee is DEBORAH J. DAHL. The last known address, birth
date and social security number of Alternate Payee are:
Name:
Address:
Birth Date:
SSAN#:
5
c.
6
7
d.
hr'C.C-C..'S\ ~
'1tl-\lAlD
Plan is the Timber Operators Council-Woodworkers, IAM Defined
Plan Administrator is Associated Administrators, Inc. The Plan
Administrator's address and telephone number are:

Timber Operators Council-Woodworkers, IAM
Defined Contribution Plan and Trust
Associated Administrators, Inc.
Attn: Janice Driver
2929 N.W. 3 lst Avenue
Portland, OR 97210-1773
(503) 222-9603
10
11
12
13
14
qqD Y!)P.o..l()r"'l?'='"(....
'1-i.q. 5"7
Contribution Plan and Trust.
8
9
Deborah J. Dahl
3.
Marital Property Division. This Order relates to the division of marital property
15
of the Participant and the Alternate Payee pursuant to a Decree of Dissolution. The Alternate
l6
Payee is the former spouse of the Participant. This Order is made pursuant to and in accordance
17
with RCW 26.09 and other applicable related domestic relations laws of the state of Washington.
18
4.
Award of Benefits to Alternate Payee. The Alternate Payee is awarded Fifty One
19
Thousand Five Hundred Dollars ($51,500) of the Participant's benefits under the Plan. As soon
20
as administratively practical after determining that this Order is a QDRO and pursuant to Plan
21
procedures, the Plan Administrator shall segregate and separately account for assets representing
22
the Alternate Payee's award from the Participant's Plan account as of the closest valuation date
23
to November 18, 2003. All benefits not awarded to the Alternate Payee by this Order shall
24
remain payable to or on behalf of the Participant.
25
5. - - Alternate Payee's Form of Benefit. The Alternate Payee may elect to receive her
26
27
28

OPERATORS COUNCIL-WOODWORKER'S IAM DEFINED
Law Office of
SCOTI CANDOO
Tacoma, WA 98403
(253) 272-7274
., .
award of benefits in any form the Plan permits, except in the form of a joint and survivor annuity
with a subsequent spouse as the beneficiary or as a disability benefit. The Alternate Payee may
elect a distribution as of the first day of any month on or after the earlier of the date:
(a) Participant attains or would have attained the earliest retirement age under the Plan; or
(b) Participant or Alternate Payee is eligible for a distribution under the Plan. All distributions to
Alternate Payee shall be subject to Plan administrative rules and procedures. Alternate Payee's
award of benefits shall not be affected by any election Participant may make or fail to make
under the Plan with respect to the form of payment of his benefit. Any reduction or increase in
the benefit as a result of Participant's election or failure to elect a payment option shall be
10
charged to Participant's portion of the benefits and shall not increase or decrease the amount of
11
Alternate Payee's award of benefits.
12
6.
Death of Alternate Payee.
13
14
OPTION 1:
a.
Before Order Accepted. If Alternate Payee dies before this Order is accepted
15
by the Plan Administrator as a QDRO, the benefits awarded to Alternate Payee under this
16
17
Order shall be paid to the following Substitute Alternate Payee (sometimes called "Contingent
18
Alternate Payee") (if more than one, equally to those surviving Alternate Payee): f\mAvdo.,
19
6a_ro..~ c>~d
20
E\i-z~~
~~hildCren)/dependent(s)
of the Participant. [Fill in the name of
the Substitute Alternate Payee, which must be a child(ren) or other dependent(s) of the
21
Participant. See IRC Section 414(p)(8).]

22
23
24
25
26
27
28

IAM DEFINED
Law Office of
SCOTI CANDOO
Tacoma, WA 98403
(253) 272- 7274
1
2
3
OPTION 2:
a.
Before Order Accepted. If Alternate Payee dies before this Order is accepted
by the Plan Administrator as a QDRO, the benefits awarded to Aiternate Payee under this
4
Order shall lapse and shall revert to the Participant.
5
6
7
b.
After Order Accepted. If Alternate Payee dies after this Order is accepted
by the Plan Administrator as a QDRO and before all of the benefits awarded to Alternate Payee
under this Order are paid, the benefits awarded to Alternate Payee under this Order shall be paid
10
to the Alternate Payee's beneficiary, or pursuant to the Plan terms if there is no named
11
beneficiary.
12
7.
13
14
15
16
17
a.
20
Before Order Accepted. If Participant dies before this Order is accepted
by the Plan Administrator as a QDRO, Alternate Payee shall be deemed the Participant's
surviving spouse and beneficiary under the Plan, but only to the extent necessary to provide
Alternate Payee with the benefits awarded to Alternate Payee under this Order, provided the Plan
Administrator subsequently accepts this Order as a QDRO.
18
19
Death of Participant.
b.
If Participant dies after this Order is accepted by the Plan Administrator as
a QDRO, Alternate Payee's benefits shall not be affected.

8.
Tax Treatment. Alternate Payee shall be treated as the recipient of any benefits
21
distributed to or paid to Alternate Payee pursuant to this Order. The following party shall be
22
responsible for any taxes or excise taxes on the distribution or payment: Alternate Payee, if
23
Alternate Payee is the Participant's spouse or former spouse; and Participant, if Alternate Payee
24
is Participant's child or dependent.
25
9.
Information Requirements.
Alternate Payee and Participant shall provide all
26
27
28

IAM DEFINED
Law Office of
SCOTI CANDOO
Tacoma, WA 98403
(253) 272- 7274
information requested by the Plan Administrator.
notices to Alternate Payee's address as set forth in this Order, unless Alternate Payee provides a
new address to the Plan Administrator in writing. Until all benefits awarded to Alternate Payee
are paid, Alternate Payee shall notify the Plan Administrator of any change in Alternate Payee's
address.
10.
The Plan Administrator may provide all
Miscellaneous Provisions.
a.
This Order does not require the Plan to: provide any type or form of
benefit, or any option, not otherwise provided under the Plan; provide increased benefits
(determined on the basis of actuarial value); or pay benefits to Alternate Payee that are required
10
to be paid to another alternate payee under another order previously determined to be a QDRO.
11
12
13
b.
appropriate to enforce or clarify the provisions of this Order or to amend this Order for the
purpose of establishing or maintaining the Order as a QDRO.
14
15
16
This Court retains jurisdictiori to make such further orders as are
c.
The Plan Administrator must accept this QDRO before the Order can be
processed. JAMES R. DAHL shall serve a certified copy of the Order upon the Plan
Administrator.
17
DONE IN OPEN COURT this _
_,,~,._~' '-=----
18
19
20
21
Presented by:
22
/7
23~
24
Approved as to Form; Copy Received:
cSfuTTCANDOO
WSBA#: 7815
25
26
27
28

OPERATORS COUNCIL-WOODWORKER'S IAM DEFINED
Law Office of
SCOTI CANDOO
Tacoma, WA 98403
(253) 272-7274
' 1
""'-.,I
.,
JAME
Parti .
. DAHL, Petitioner
ant
Date signed:
rz.
/}
g/,f-~Ob'V
DEBORAH J. AHL~spondent
Alternate Payee
Date signed:
d1 'trlWr.1
o1
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5
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7
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IAMDEFINED
LllW Office of
SCOTI CANDOO
Tacoma, WA 98403
(253) 272- 727 4
i
02-3-02768-6
20738559
ORQDR
03-26-04
2
3
4
5
6
7
8
9
10
IN RE THE MARRIAGE OF:

DEBORAH J. DAHL,
11
12
13
Petitioner,
and
JAMES R. DAHL,
14
Respondent.
)
)
)
)
)
)
)
)
)
)
)
NO. 02-3-02768-6
ORDER RE: TOC - IW A PENSION PLAN
AND TRUST
15
16
1.
Effect of this Order. This Order recognizes the right of Alternate Payee to receive
17
all or a portion of Participant's benefits payable under a retirement plan qualified under the
18
Internal Revenue Code of 1986, as amended (the "Code"). This Order is intended to be a
19
qualified domestic relations order ("QDRO") under section 414(p) of the Code and section
20
206(d)(3) of the Employee Retirement Income Security Act of 1974, as amended.
21
22
23
24
25
2.
Definitions.
a.
Participant is JAMES R. DAHL. The last known address, telephone
number, birth date and social security number of Participant are:

Name:
Address:
Birth Date:
SSAN#:
26
27
28

ORDER RE: TOC - IW A PENSION PLAN
AND TRUST - 1
0_ R I G 'NA L
lawOfficeof
SCOTT
CANDOO
Tacoma, WA 98403
(253) 272-7274
b.
date and social security number o~ Alternate Payee are:
Name:
Address:
Birth Date:
SSAN#:
5
6
7
8
15
16
17
18
19
20
21
22
23
'<Y]c.uo\"J?.-"c....,~ru~S\
~A
gf4&!.c
1-2.<J57
d.
Plan Administrator is Associated Administrators, Inc. The Plan
Administrator's address and telephone number are:

TOC-IWA Pension Plan and Trust
Associated Administrators, Inc.
Attn: Pattie Rankin
2929N.W. 31st Avenue
Portland, OR 97210-1773
(503) 222-9603
11
14
qq_,
Plan is the TOC-IWA Pension Plan and Trust
10
13
Deborah J. Dahl
c.
12
Alternate Payee is DEBORAH J. DAHL. The last known address, birth
3.
Marital Property Division. This Order relates to the division of marital property
of the Participant and the Alternate Payee pursuant to a Decree of Dissolution. The Alternate
Payee is the former spouse of the Participant. This Order is made pursuant to and in accordance
with RCW 26.09 and other applicable related domestic relations laws of the state of Washington .
4.
Award of Benefits to Alternate Payee.

a.
Alternate Payee's Fractional Interest is the benefits awarded to Alternate
Payee under this section, which shall be determined using the following Fractional Interest
Formula: Fifty (50%) percent of the amount determined by multiplying Participant's accrued
benefits under the Plan as of August 28, 2002 by a service fraction. The numerator of the service
fraction shall be the Participant's whole and fractional years of employment between September
9, 1983, and August 28, 2002 . The denominator of the service fraction shall be the Participant's
whole and fractional years of employment between 1976 and August 28, 2002.
24
b.
Alternate Payee shall be treated as a separate annuitant and a surviving
25
spouse under the Plan for purposes of her Fractional Interest. All benefits payable to the
26
(
27
28

ORDER RE: TOC - IWA PENSION PLAN
AND TRUST - 2
Law Office of
SCOTT CANDOO
Tacoma, WA 98403
(253) 272-7274
(.
l. .
Alternate Payee pursuant to this Order shall be determined by using the Plan interest rate and
actuarial assumptions and adjustments and, if applicable, calculated as if the Participant retired
on the date Alternate Payee's benefits commence. All benefits-not awarded to Alternate Payee
by this Order shall remain payable to or on behalf of Participant, who shall have the right to
designate a beneficiary and/or change a beneficiary designation, if applicable to the form of
benefits elected by the Participant.
c.
Alternate Payee's Fractional Interest shall be subject to adjustment for
benefit improvements under the Plan, only as provided in this paragraph. A benefit improvement
shall not apply to the Alternate Payee unless the improvement is of the type otherwise applicable
10
to Alternate Payee benefits under the Plan. If Alternate Payee's Fractional Interest is subject to
11
12
13
adjustment for a subsidy (either subsidized early retirement benefits and/or subsidized disability
benefits), and the subsidized benefit is/are not payable at the time Alternate Payee enters pay
status, Alternate Payee's Fractional Interest shall be calculated without regard to the subsidy. If
2
3
4
5
6
7
the subsidy becomes payable later, Alternate Payee is entitled to a pro rata share.
Benefit Improvement based upon the Fractional Interest
Formula
Applies to Alternate Payee?
Retroactive benefit improvements attributable to credited

service used to calculate the Alternate Payee's Fractional
Interest, provided the improvements are made before the
Alternate Payee enters pay status.
~Yes
Cost-of-living or other benefit adjustments made after the

Participant retires.
z9Yes
ONo
Bonus checks made after the Participant retires.
9
10
Subsidized early retirement benefits.
~Yes
ONo
Subsidized disability benefits.
~Yes
ONo
13
14
ro Yes
ONo
11
12
ONo
5.
Alternate Payee's Form of Benefit. The Alternate Payee may elect to receive her
15
award of benefits in any form the Plan permits, except in the form of a joint and survivor annuity
16
with a subsequent spouse as the beneficiary or as a disability benefit. The Alternate Payee may
17
elect a distribution as of the first day of any month on or after the earlier of the date:
18
(a) Participant attains or would have attained the earliest retirement age under the Plan; or
19
(b) Participant or Alternate Payee is eligible for a distribution under the Plan. All distributions to
20
Alternate Payee shall be subject to Plan administrative rules and procedures. Alternate Payee's
21
award of benefits shall not be affected by any election Participant may make or fail to make
22
under the Plan with respect to the form of payment of his benefit. Any reduction or increase in
23
the benefit as a result of Participant's election or failure to elect a payment option shall be
24
charged to Participant's portion of the benefits and shall not increase or decrease the amount of
25
Alternate Payee's award of benefits.
26
27
28

AND TRUST - 4
Law Office of
SCOTf CANDOO
Tacoma, WA 98403
(253) 272-7274
6.
2
3
Death of Alternate Payee.

a.
of the Alternate Payee.' s death:
Result---+ Benefits awarded to

Alternate Payee under this
Order shall be paid to
Substitute Alternate-Payee
6
7
8
9
10
11
12
13
The benefits awarded under this Order shall be paid as follows in the event
Eventl
Benefits awarded to Alternate

Payee under this Order lapse
and revert to the Participant
Alternate Payee dies before

this Order is accepted by the
Plan Administrator as a
QDRO and before Alternate
Payee enters pay status
This result applies?
~Yes
OYes
ONo
No
Alternate Payee dies after

this Order is accepted by the
Plan Administrator as a
QDRO and before Alternate
Payee enters pay status
~Yes
DYes
DNo
~No
Alternate Payee dies after

entering pay status
14
b.
15
Alternate Payee's benefits are paid to Alternate Payee's

beneficiary, if applicable (depending upon the distribution
form elected by the Alternate Payee)
If applicable, the Substitute Alternate Payee (sometimes called the
l6
"Contingent Alternate Payee"), shall mean the following (if more than one, equally to those
17
surviving Alternate Payee):
18
child(ren)/dspmdeHt(s) of the Participant.
19
7.
Bn'\'F\~dA , Sa.ro..'n aud
J;.l t:z..c..berh ='{obi
,a
Tax Treatment. Alternate Payee shall be treated as the recipient of any benefits
20
distributed to or paid to Alternate Payee pursuant to this Order. The following party shall be
21
responsible for any taxes or excise taxes on the distribution or payment: Alternate Payee, if
22
Alternate Payee is the Participant's spouse or former spouse; and Participant, if Alternate Payee
23
is Participant's child or dependent, and shall be responsible for any taxes or excise taxes on the
24
distribution or payment.
25
9.
Information Requirements.
Alternate Payee and Participant shall provide all
26
27
28

AND TRUST - 5
law Office of
SCOTI CANDOO
Tacoma, WA 98403
(253) 272-7274
-.
..
. "'- ..
1
information requested by the Plan Administrator.
notices to Alternate Payee's address as set forth in this Order, unless Alternate Payee provides a
new address to the Plan Administrator in writing. Until all benefits awarded to Alternate Payee
are paid, Alternate Payee shall notify the Plan Administrator of any change in Alternate Payee's
address.
6
7
10.
The Plan Administrator may provide all
Miscellaneous Provisions.
a.
This Order does not require the Plan to: provide any type or form of
benefit, or any option, not otherwise provided under the Plan; provide increased benefits
(determined on the basis of actuarial value); or pay benefits to Alternate Payee that are required
10
11
12
13
14
to be paid to another alternate payee under another order previously determined to be a QDRO.
b.
This Court retains jurisdiction to make such further orders as are
appropriate to enforce or clarify the provisions of this Order or to amend this Order for the
purpose of establishing or maintaining the Order as a QDRO.
c.
The Plan Administrator must accept this QDRO before the Order can be
15
16
17
18
FILED
=---:-=:J~~=:t-=-.~~===~~-w.fi:FT. 10
19
OPEN COU
20
; Copy Re eived:
MAR 2 6 2004
21
22
23
24
25
26
27
28
JAMESR. DAH
Participant
Date signed: _.4~(!Z..~~tLJ.Lk.~
QUALIFIE DOMESTIC RELATIONS
AND TRUST - 6
DEBORAH . DAHL, Respondent

Alternate Payee
Date signed:
J1
mc,Jv 0
Law Office of
SCOTI CANDOO
Tacoma, WA 98403
(253) 272-7274
02-3-02768-6
20738560
PP
2
3
4
5
6
7

COUNTY OF PIERCE
8
9
In re the Marriage
10
DEBORAH J. DAHL
NO. 02-3-02768-6
of:
Petitioner,
11
and
12
JAMES R. DAHL
PARENTING PLAN
FINAL (PP)
Respondent.
13
14
This parenting plan is the final parenting plan entered by

the Court on
3 .- 6',,. oct
15
16
I.
GENERAL INFORMATION
17
18
Age
Name
19
AMANDA
20
SARAH
ELIZABETH
DAHL
DAHL
DAHL
14
11
6
21
II.
BASIS FOR RESTRICTIONS
22
23
Under certain circumstances, as outlined below, the court may

limit or prohibit a parent1s contact with the children and
the right to make decisions for the children.
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 1of12
FormaPJu~
10. 7
0 R I GI N AiL.sENHOWER
& C~RLSON'PLLC
WELLS FARGO PLAZA, SUITE 1200

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
PARENTAL CONDUCT (RCW 26. 09 .191 (1),
2.1
Does not apply.
OTHER FACTORS (RCW 26.09.191(3)).
2.2
Does not apply.
III.
6
7
8
9
10
(2)).
RESIDENTIAL SCHEDULE
The residential schedule must set forth where the children

shall reside each day of the year, including provisions for
holidays, birthdays of family members, vacations, and other
special occasions, and what contact the children shall have
with each parent. Parents are encouraged to create a
residential schedule that meets the developmental needs of
the children and individual needs of their family.
Paragraphs 3.1 through 3.9 are one way to write your
residential schedule. If you do not use these paragraphs,
write in your own schedule in Paragraph 3.13.
11
3.1
12
13
SCHOOL SCHEDULE.
3.2
14
Upon enrollment in school, the children shall reside
with the mother, except for the following days and
times when the children will reside with or be with the
other parent:
15
16
17
Friday after school to Sunday 7:00 p.m. every other

weekend. (Husband works swing shift). Depending upon
Husband's shift, Mother to be notified of exact time
on Friday at 12:00 a.m.
18
19
Midweek from 6:00 p.m. to 8:00 p.m., if Husband's

work schedule allows and as agreed to by the parties.
20
21
3. 3
22
The children shall reside with the mother during winter

vacation, except for the following days and times when
the children will reside with or be with the other
parent:
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 2of12
Forms+PIU$
10,7

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX

winter vacation from the time school ends until
Christmas Day, 11:00 a.m. and Mother shall have second
half of winter vacation from 11:00 a.m. Christmas Day
until school resumes. In odd-numbered years Mother
shall have the first half of winter vacation from the
time school ends until 11:00 a.m. Christmas Day and
Father shall have Christmas Day 11:00 a.m. until
school resumes.
1
2
3
4
s
6
3.4
SCHEDULE FOR SPRING/MID-WINTER VACATION.

The children shall reside with the mother during spring
vacation, except for the following days and times when
the children will reside with or be with the other
parent:
7
8
9
For Spring Break: Shared equally with the exchange to

take place at 6:00 p.m. on Wednesday, the midweek point
of the Spring Vacation week.
-
10
11
For Mid-Winter Break (if it applies): Shared equally

with the exchange to take place at 6:00 p.m. on
Wednesday, the midweek point of Mid-Winter Vacation
week.
12
13
14
3.5
SUMMER SCHEDULE.
Upon completion of the school year, the children shall
reside with the mother, except for the following days
and times when the children will reside with or be with
the other parent:
15
16
17

with the children. In year one {2003), Father shall
divide the four weeks-so that there is only one
two-week block, thereby leaving two one-week blocks for
vacation.
In year two (2004) and thereafter, Father
shall receive two two-week non-consecutive blocks of
summer/vacation time with the children.
18
19
20
21
3.6
22
Does not apply.
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 3of12

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
3.7
The residential schedule for the children for the

holidays listed below is as follows:
2
3
With Mother
(Specify
Year
Odd/Even/Every)
5
6
7
8
9
10
New Year's Day

Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
*
**
**
**
Odd
**
**
Even
Odd
Even
With Father
(Specify
Year
Odd/Even/Every)
*
**
**
**
Even
**
**
Odd
Even
Odd
11
For purposes of this parenting plan, a holiday shall
begin and end as follows (set forth times):
12
**Monday holidays. Holiday goes with whomever has

13
14

15
16
July 4th shall be 9:00 a.m.

the next morning.
on July 4th until 11:00 a.m.
17
18
19

20
Other:
21
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 4of12
Forms+P/u$
10. 7

WELLS FARGO PLAZA, SUIIB 1200
1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
3. 8

The residential schedule for the children for the
following special occasions (for example, birthdays) is
as follows:
With Mother
(Specify
Year
Odd/Even/Every)
4
5
With Father
(Specify
Year
Odd/Even/Every)
6
7
8
Mother's Day
Father's Day
Mother's Birthday
Father's Birthday
Every
Every
Every
Every
Share
Share
9
3.9
10
If the residential schedule, paragraphs 3.1 - 3.8,

results in a conflict where the children are scheduled
to be with both parents at the same time, the conflict
shall be resolved by priority being given as follows:
Rank the order of priority, with 1 being given the
highest priority:
11
12
13
6
3
4
5
1
14
15
16
School schedule (3. 1, 3.2)

Winter vacation (3. 3}
Spring vacation (3. 4)
Summer schedule ( 3. 5)
Holidays ( 3 . 7)
Special -occasions ( 3. 8)
17
3.10
RESTRICTIONS.
18
Does not apply

19
3.11
20
21
Transportation costs are included in the Child Support

Worksheets and/or the Order of Child Support and should
not be included here.
22
23
24
25
Transportation arrangements for the children between

parents shall be as follows:
Father shall provide transportation from Vashon Ferry
Terminal to Father's home. Mother to Vashon Terminal
(Tacoma side) to her home.
PARENTING PIAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 5of12

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
3.12
The children named in this parenting plan are scheduled
to reside the majority of the time with the mother.
This parent is designated the custodian of the children
solely for purposes of all other state and federal
statutes which require a designation or determination
of custody. This designation shall not affect either
parent's rights and responsibilities under this
parenting plan.
2
3
4
5
6
3.13
OTHER.
3.14
SUMMARY OF RCW 26.09.430 - .480, REGARDING RELOCATION

OF A CHILD.
This is a summary only. For the full text, please see

RCW 26.09.430 through 26.09.480.
9
10
If the person with whom the child resides a majority of

the time plans to move, that person shall give notice
to every person entitled to court ordered time with the
child.
11
12
If the move is outside the child's school district, the

relocating person must give notice by personal service
or by mail requiring a return receipt.
This notice
must be at least 60days before the intended move. If
the relocating person could not have known about the
move in time to give 60 days notice, that person must
give notice within 5 days after learning of the move.
The notice must contain the information required in RCW
26.09.440. See also form DRPSCU 07.0500, (Notice of
Intended Relocation of A Child.)
13
14
15
16
17
18
If the move is within the same school district, the

relocating person must provide actual notice by any
reasonable means. A person entitled to time with the
child may not object to the move but may ask for
modification under RCW 26.09.260.
19
20
21
Notice may be delayed for 21 days if the relocating

person is entering a domestic violence shelter or is
moving to avoid a clear, immediate and unreasonable
risk to heatth and safety.
22
23
If information is protected under a court order or the

address confidentiality program, it may be withheld
from the notice.
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 6of12
forms+Plu
10.1

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
A relocating person may ask the court to waive any

notice requirements that may put the health and safety
of a person or a child at risk.
1
2
Failure to give the required notice may be grounds for

sanctions, including contempt.
3
4
If no objection is filed within 30 days after service

of the notice of intended relocation, the relocation
will be permitted and the proposed revised residential
schedule may be confirmed.
A person entitled to time with a child under a court

order can file an objection to the child's relocation
whether or not he or she received proper notice.
7
8
An objection may be filed by using .the mandatory

pattern form WPF DRPSCU 07.0700, (Objection to
Relocation/Petition for Modification of Custody
10

objection must be served on all persons entitled to
time with the child.
11
12
The relocating person shall not move the child during

the.time for objection unless: (a) the delayed notice
provisions apply; or (b) a court order allows the move.
13
14
If the objecting person schedules a hearing for a date

within 15 days of timely service of the objection, the
relocating person shall not move the child before the
hearing unless there is a clear, immediate and
unreasonable risk to the health or safety of a person
or a child.
15
16
17
18
IV.
DECISION MAKING
19
4.1
.DAY-TO-DAY DECISIONS.
20
Each parent shall make decisions regarding the

day-to-day care and control of each child while the
children are residing with that parent. Regardless of
the allocation of decision making in this parenting
plan, either parent may make emergency decisions
affecting the health or safety of the children.
21
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 7of12
forms.nu 10. 7

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
MAJOR DECISIONS.
4.2
Major decisions regarding each child shall be made as

follows:
3
joint
care:
joint
joint

parent agrees to actively foster, encourage and
cooperate with the children in this regard.
8
9
10
4.3
11
Does not apply.
12
V.
DISPUTE RESOLUTION
13
14
15
16
The purpose of this dispute resolution process is to resolve

disagreements about carrying out this parenting plan. This
dispute resolution process may, and under some local court
rules or the provisions of this plan must, be used before
filing a petition to modify the plan or a motion for contempt
for failing to follow the plan.
Disputes between the parties, other than child support
disputes, shall be submitted to (list person or
agency) :
17
18

Center, or a mediator mutually agre~able to both
parties.
19
20
21
The cost of this process shall be allocated between the

parties as follows:
22
based on each party's proportional share of income
from line 6 of the child support worksheets.
23
24
25
PARENTING PIAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 8of12
forTM+l'Jus
10. 7

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
The counseling, mediation or arbitration process shall

be commenced by notifying the other party by written
request.
In the dispute resolutio~ process:
(a)
Preference shall be given to carrying out this

Parenting Plan.
(b)
Unless an emergency exists, the parents shall use

the designated process to resolve disputes
relating to implementation of the plan, except
those related to financial support.
(c)
A written record shall be prepared of any

agreement reached in counseling or mediation and
of each arbitration award and shall be provided to
each party.
(d)
If the court finds that a parent has used or

frustrated the dispute resolution process without
good reason, the court shall award attorneys' fees
and financial sanctions to the other parent.
{e)
The parties have the right of review from the

dispute resolution process to the superior court.
5
6
7
8
9
10
11
12
13
14
VI.
OTHER PROVISIONS
15
16
17
18
A.
The child shall have reasonable-telephone
privileges with the parent with whom the child is not then
residing, without interference from the residential parent.
The nonresidential parent may have reasonable telephone
contact befor~ 8:00 p.m.
19
20
21
22
23
24
25
B.
Each parent agrees to exert every reasonable effort
to maintain free access and unhampered contact and
communication between the child and the other parent, and to
promote the emotions of affection, love and respect between
the child and the other parent. Each parent agrees to
refrain from words or conduct, and to discourage other
persons from uttering words or engaging in conduct which
would have a tendency to estrange the child from the other
parent, to damage the opinion of the child as to the other
parent, or which would impair the natural development of the
child's love and respect for the other parent. Each parent
agrees and understands that words or conduct which have a
PARENTING PI.AN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 9of12
hrrns+P/u:J 10. 7

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
2
3
4
5
6
7
8
9
10
11
12
13
14
15
tendency to estrange or diminish the opinion of the child

from the other parent, also tends to diminish the child's
self-esteem and self-worth.
C.
Each parent agrees to honor the other's parenting
style, privacy and authority, so long as it is not adverse to
the child's best interest. Neither parent shall interfere in
the parenting style of the other, nor shall either parent
make plans or arrangements that would impinge upon the other
parent1s authority or time with the child without the express
agreement of the other. Each parent shall encourage the
children to discuss his or her grievance against a parent
directly with the parent in question. It is the intent of
both parents to encourage direct parent-child communication
and bonding .
D.
Each parent
with school, daycare,
regarding the child1s
full and equal access
of the child.
shall have equal authority to confer

health and other program personnel
progress, and each parent shall have
to the education and healthcare records
E.
Each parent shall inform the other when that parent
plans to be away from his or her residence with the child for
more than two consecutive nights. The information to be
provided shall include duration of the period, the
destination(s) and destination telephone number(s). This
provision is included solely for purposes of knowing the
parent1s and child's location in the event of an emergency
and is not meant to be intrusive.
16
17
F.
Neither parent shall ~dvise the child of the status
of child support payments or other legal matters regarding
the parental relationship and obligation.
18
19
G.
Neither parent shall use the children, directly or
indirectly, to gather information about the other parent or
take verbal messages to the other parent.
20
21
22
H.
Each parent shall have the right and responsibility
to insure that the children attend school and other scheduled
activities while in that parent's care. Activities shall not
be scheduled to unreasonably interfere with the other
parent1s residential time with the child.
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 10of12

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
1
2
I.
Each parent shall provide the other parent with the
address and telephone number of their residence and update
such information promptly whenever it is anticipated to
change or changes. 11Reasonableness11 is defined at least 30
days in advance of a scheduled move, or within 72 hours of an
unscheduled move.
4
5
6
7
8
9
10
11
J.
Neither parent shall ask the child to make
decisions or requests involving the residential schedule with
the children except for plans which have already been agreed
to by both parents in advance.
K.
Neither parent shall encourage the child to change
his or her primary residence or encourage the child to
believe that it is his or her choice to do so. It is a
choice which will be made by the parents or, if they cannot
agree, the courts.
L.
Neither parent shall introduce a significant other
during the pendency of the temporary Parenting Plan nor have
a significant other spend the night during their visitation
periods.
12
13
M.
Father shall refrain from the consumption of
alcohol twenty-four hours prior to visitation and during
visitation.
14
VII.
DECLARATION FOR PROPOSED PARENTING PLAN
15
Does not apply.

16
VIII.
ORDER BY THE COURT
17
18
It is ordered, adjudged and decreed that the parenting plan

set forth above is adopted and approved as an order of this
court.
19
20
21
WARNING:
Violation of residential provisions of this order
with actual knowledge of its terms is punishable by contempt
of court and may be a criminal offense under RCW
9A.040.060(2)
or 9A.40.070(2).
Violation of this order may
subject a violator to arrest.
22
23
When mutual decision making is designated but cannot be

achieved, the parties shall make a good faith effort to
resolve the issue through the dispute resolution process.
24
25
PARENTING PIAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 11of12
FormsPJus
10. 7
EISENHOWER & CAR~ON, PLLC

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
If a parent fails to comply with a provision

the other parent's obligations under th p n
affected.
3
4
Dated :
] -
2 (, ,.
c..(
5
6
Presented by:
7
8
P. Craig
W.S.B.A.
cott Candoo
W.S.B.A. #7815
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
PARENTING PLAN
WPF DR 01.0400 (9/2001)
RCW 26.09.181; .187; .194
Page 12of12
Interoffice#:
Client File, p,\SCPLUS\DAHL\Dahl.SCP
12/16/2003
10:24
12/16/2003
10:24 a.m.
Forma.+l'lus
10. 7

a.m.

1201 PACIFIC AVENUE
(253) 572-4500
(2.53) 272-5732 FAX
1111 lll ll
20738563
02-3-02768-6
l l l ll I\ I
ORSW
03-26-04
1 '
2
FILED
DEPT. 1
IN OPEN C
MAR 2 6
5
6
7

COUNTY OF PIERCE
8
9
NO. 02-3-02768-6
10
DEBORAH
ORDER OF CHILD
SUPPORT
(ORS)
J. DAHL
Petitioner,
11
and
12
JAMES R. DAHL
Respondent.
Clerk's Action Required
13
I.
14
15
The judgment
16
A.
B.
17
c.
18
D.
19
E.
F.
G.
H.
20
SUMMARY
summary:
Judgment Creditor
JAMES R. DAHL
Judgment Debtor
DEBORAH J. DAHL
Principal Judgment amount (back support)
payments due 03/01/03
to 10/01/03
$6,031.48
Interest to date of Judgment
$ ~- 7$ YfO.b
(interest 03/01/03 to 12/31/03)
Attorney's
fees
Costs
Other recovery amount
Principal judgment shall bear interest at 12% per
annum.
Attorney's fees, costs and other recovery
amounts shall bear interest at 12% per annum.
Attorney for Judgment Creditor
Attorney for Judgment Debtor
Other:
21
I.
22
23
JUDGMENT
J.
K.
L.
~.C
24
End Judgment
Summary
25
WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 1of8
Form5-1-Plu'
10.1
OR l GI NAL
WELLS FARGO PLAZA. SUITE 1200
1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
II.
1
2
2.1
TYPE OF PROCEEDING.
This order is entered pursuant to a decree of
dissolution,legal separation or a declaration of
invalidity and by agreement of the parties.
3
4
5
BASIS
CHILD SUPPORT WORKSHEET.
2. 2
The child support worksheet which has been approved by

the court is attached to this order and is incorporated
by reference or has been initialed and filed separately
and is incorporated by reference.
7
8
2.3
OTHER:
III.
FINDINGS AND ORDER
10
IT IS ORDERED that:
11
3.1
CHILDREN FOR WHOM SUPPORT IS REQUIRED.
12
Name (first/last)
Age
13
AMANDA
SARAH
ELIZABETH
14
DAHL
DAHL
DAHL
14
11
6
15
3.2
PERSON PAYING SUPPORT (OBLIGOR).
16
Name (first/last): JAMES DAHL

Birth date:
01/08/54
Service Address: (You may list an address that is not
your residential address where you agree to accept
legal documents.]
25812 120th LANE SW
VASHON, WA 98070
17
18
19
20
21
THE OBLIGOR PARENT MUST IMMEDIATELY FILE WITH THE COURT AND
22
26.23.050.
23
THE OBLIGOR PARENT SHALL UPDATE THE INFORMATION REQUIRED BY

24
25

WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 2 of 8
FOrTn$+Plua 10. 7

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
1
2
Monthly Net Income: $2,643.38

3.3 PERSON RECEIVING SUPPORT (OBLIGEE):
Name (first/last)
DEBORAH DAHL
Birth date:
07/29/57
Service Address: [You may list an address that is not
legal documents.]
916 MANOR DRIVE
FIRCREST, WA 98466
5
6
7
8
9
10
11
THE OBLIGEE PARENT MUST IMMEDIATELY FILE WITH THE COURT AND
26.23.050.
THE OBLIGEE PARENT SHALL UPDATE THE INFORMATION REQUIRED BY
12
Monthly Net Income: $4,431.63
13
The obligor may be able to seek reimbursement for day

care or special child rearing expenses not actually
incurred. RCW 26.19.080.
14
15
3.4
16
SERVICEOF PROCESSON THE OBLIGOR AT THE ADDRESS

REQUIRED BY PARAGRAPH 3.2 OR ANY UPDATED ADDRESS, OR
ON THE OBLIGEE AT THE ADDRESS REQUIRED BY IN
PARAGRAPH 3.3 OR ANY UPDATED ADDRESS, MAY BE ALLOWED
OR ACCEPTED AS ADEQUATE IN ANY PROCEEDING TO
ESTABLISH, ENFORCE OR MODIFY A CHILD SUPPORT ORDER
BETWEEN THE PARTIES BY DELIVERY OF WRITTEN NOTICE TO
THE OBLIGOR OR OBLIGEE AT THE LAST ADDRESS PROVIDED.
17
18
19
20
21
SERVICE OF PROCESS.
3. 5
TRANSFER PAYMENT.
The obligor parent shall pay $928.12
commencing January 1, 2004.
22
per month
23
24
25
ORDEROF CHILD SUPPORT
WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 3 of 8
rorm1-..Jl'lus 10.l'

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
THE OBLIGOR PARENT'S PRIVILEGES TO OBTAIN OR MAINTAIN A

LICENSE, CERTIFICATE, REGISTRATION, PERMIT, APPROVAL, OR
OTHER SIMILAR DOCUMENT ISSUED BY A LICENSING ENTITY
EVIDENCING ADMISSION TO OR GRANTING AUTHORITY TO
ENGAGE IN A PROFESSION, OCCUPATION, BUSINESS, INDUSTRY,
RECREATIONAL PURSUIT, OR THE OPERATION OF A MOTOR
VEHICLE, MAY BE DENIED, OR MAYBE SUSPENDED IF THE
OBLIGOR PARENT IS NOT IN COMPLIANCE WITH THIS SUPPORT
ORDER AS PROVIDED IN CHAPTER 74 .2.0A REVISED CODE OF
WASHINGTON.
2
3
4
5
6
3.6
STANDARD CALCULATION.
7
8
$928.12 per month.

3.7
(See Worksheet #1 line 15)
REASONS FOR DEVIATION FROM STANDARD CALCULATION.
9
The child support amount ordered in paragraph 3.5 does
not deviate from the standard calculation.
10
11
A deviation was not requested.
12
13
REASONS WHY REQUEST FOR DEVIATION WAS DENIED.
3. 8
3. 9
STARTING DATE AND DAY TO BE PAID.
14
Starting Date:
January 2004
15
Day(s) of the month

support is due:
1st
16
3.10
INCREMENTAL PAYMENTS.
17
Does not apply.
18
3.11
19
HOW SUPPORT PAYMENTS SHALL BE MADE.

Select either Enforcement and Collection or Payment
Processing Only:
20
Payment processing only: The Division of Child Support

does not provide support enforcement services for this
case. Support payments shall be made to:
21
22
Washington State Support Registry

P.O. Box 45868
Olympia, WA 98504
Phone: 1-800-922-4306
or 1-800-442-5437
23
24
25

WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 4 of 8
f'orms+P/ua 10. 7

WELLS FARGO PLAZA. SUITE 1200
1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
(DCS will process payments but will not take any

collection action.) A party required to make payments
to the Washington State Support Registry will not
receive credit for a payment made to any other party or
entity. The obliger parent shall keep the registry
informed whether he or she has access to health
insurance coverage at reasonable cost and, if so, to
provide the health insurance policy information.
2
3
4
5
3.12
WAGE WITHHOLDING ACTION.
Withholding action may be taken against wages,

earnings, assets, or benefits, and liens enforced
against real and personal property under the child
support statutes of this or any other state, without
further notice to the obliger parent at any time after
entry of this order unless an alternative provision is
made below:
7
8
9
10
[If the court orders immediate wage withholding in a

case where Division of Child Support does not provide
support enforcement services, a mandatory wage
assignment under Chap. 26.18 RCW must be entered and
support payments must be made to the Support Registry.]
11
12
13
3.13
TERMINATION OF SUPPORT.
14
Support shall be paid:

15
Until the children reach the age of 18, except as

otherwise provided below in Paragraph 3.14.
16
17
3.14
The right to petition for post secondary support is

reserved, provided that the right is exercised before
support terminates as set forth .in paragraph 3.13.
18
19
20
POST SECONDARY EDUCATIONAL SUPPORT.
3.15
PAYMENT FOR EXPENSES NOT INCLUDED IN THE TRANSFER

PAYMENT.
21
Does not apply because all payments, except medical,

are included in the transfer payment.
22
23
3.16
PERIODIC ADJUSTMENT.
Does not apply.
24
25

WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 5 of 8
rorrns+PJu:J to. 7

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
3.17
INCOME TAX EXEMPTIONS.

Tax exemptions for the children shall be allocated as
follows:
3
The parties shall file a joint tax return for 2003.
4
2004:
5
2005:
6
Mother shall claim the eldest two and Father

shall claim the youngest.
Father shall claim the eldest two and Mother
shall claim the youngest.
Thereafter, exemptions should be alternated, provided

Father is current in support payments, as follows:
12
Mother shall claim the eldest two and Father shall

claim the youngest in even tax years. Father shall claim
the eldest two and Mother shall claim the youngest in odd
tax years. When there are two exemptions to claim each
parent shall claim one. When there is only one exemption
to claim the exemption shall be alternated between the
parties with Mother claiming in even tax years and Father
claiming in odd tax years.
13
3.18 MEDICAL INSURANCE FOR THE CHILDREN LISTED IN PARAGRAPH
9
10
11
3 .1.
14
15
Unless one or more of the boxes below are checked, each

parent shall maintain or provide health insurance
coverage if:
16
17
(a) Coverage that can be extended to cover the children

is or becomes available to each parent through
employment or is union-related; and
18
19
20
21
22
23
24
25
ORDEROF CHILDSUPPORT
WPF DR 01.0500 (9/2001)
RCW26.09.175; 26.26.132(5)
Page 6 of 8

1201 PACIFIC AVENUE
(253) 572-4500
(2.53) 272-5732 FAX
(b) The cost of such coverage for the mother does not
exceed $323.64 (25 percent of mother's basic child
support obligation on Worksheet Line 7}, and the cost
of such coverage for the father does not exceed $193.36
(25 percent of father's basic child support obligation
on Worksheet Line 7).
1
2
3
4
The parents shall maintain hea Lt h insurance coverage,

if available for the children listed in paragraph 3.1,
until further order of the court or until health
insurance is no longer available through the parents'
employer or union and no conversion privileges exist to
continue coverage following termination of employment.
5
6
7
A parent who is required under this order to provide

health insurance coverage is liable for any covered
health care costs for which that parent receives direct
payment from an insurer.
8
9
10
A parent who is required under this order to provide

health insurance coverage shall provide proof that such
coverage is available or not available within twenty
days of the entry of this order to the physical
custodian or the Washington State Support Registry if
the parent has been notified or ordered to make
payments to the Washington State Support Registry.
11
12
13
14
If proof of health insurance coverage is available or

not available is not provided within twenty days the
obligee or the Department of Social and Health Services
may seek direct enforcement of the coverage through the
obligors employer or union without further notice to
the obligor as provided under Chapter 26.18 RCW.
15
16
17
18
3.19
EXTRAORDINARY HEALTH CARE EXPENSES.

The OBLIGOR shall pay 37% of extraordinary health care
expenses (the obligors proportional share of income
from the Child Support Schedule Worksheet, line 6), if
monthly.medical expenses exceed $103.40 (5% of the
basic support obligation from Worksheet line 5).
19
20
21
22
23
24
25
WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 7 of 8
f'orrM,.}'/u' 10. 7

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
3.20
BACK CHILD SUPPORT.

The obligee parent is awarded a judgment against the
obligor parent in the amount of $6,031.48 for back
child support for payments due 03/01/03 to 12/01/03.
Thiswas calculated as follows:
3
4
Obligation $785.19/month 03/01/03 to 06/01/03

in the amount of $3,140.76 plus
Obligation $712.62/month 07/01/03 to 12/01/03

in the amount of $4,275.72
6
7
(Less three payments received 07/03, 09/03 and

10/03 in the amount of $665.00);
(Less two payments received in 12/03 in the

amount of $720.00).
9
10
3.21
'{ o ct , "'
BACK INTEREST.
11
J-
The obligee parent is awarded a judgm=~ainst

the
obliger parent in the amount of $~~f;~
back
interest for the period from 03/01/03 to 12/31/03.
12
13
3.22
14
15
16
OTHER: Pursuant to the parties' CR 2A agreement of

November 18, 2003, back child support shall be paid
from father's share of any final distribution from the
sale of Contra Costa rental, and if such funds are
insufficient to fully pay off the back support
obligation and interests, then a new jud
nt for the
deficiency shall be entered.
,/
18
19
Dated:
20
Presented by:
21
Approved for entry:

Notice of presentation
waived:
22
23
~
W.S.B.A. #7815
24
25
WPF DR 01.0500 (9/2001)
RCW 26.09.175; 26.26.132(5)
Page 8 of 8
Interoffice#:
Client File: P:\SCPLUS\DAHL\Dahl.SCP
12/16/2003 10:14 a.m.
Form: P:\SCPLUS\DAHL\OCS.DOC
12/16/2003 10:14 a.m.
Forms+P/..,:t 10. 7

1201 PACIFIC AVENUE
(253) 572-4500
(253) 272-5732 FAX
WORKSHEET SYNOPSIS
3. Basic Support:
Amanda $790.00
Sarah $639.00
Elizabeth $639.00
4.
TOTAL
MOTHER
$4,431.6.3
.626
COMBINED
$7,075.01
$773.43
$154.69
$1294.57
$258.91
$2068.00
$413.60
$928.12
$1553.48
I $2068.00

7.
FATHER
$2,643.38
.374
TOTAL OBLIGATION

11.
TOTAL CREDITS
12.
Father Pays Mother
$117.00
$400.00
$517.00
$928.12
File Name: Dahl.SCP

Page was printed on 12111/2003at 02:57 PM
CASE ALERT

EXTRAPOLATED AMOUNT: $2088.98
SupportCa/c 2003 T

Worksheets (CSW)
Coun : PIERCE

Su erior Court Number: 02-3-02768-6

Part I: Basic Child Support Obligation

a.
b.
c.
d.
e.
f.
Wa es and Salaries
Business Income
S ousal Maintenance Received
Other Income
add lines 1 a throu h 1 e
Father
Mother
$2,643.38
$4,431.63
$2,643.38
$4,431.63

a. Income Taxes Federal and State
c. State Industrial Insurance Deductions
d. Mandato Union/Professional Dues
Pension Plan Pa ments
Normal Business Ex enses
add lines 2a throu h 2
line 1f minus 2h
If line 4 is less than $600, ski to line 7.
Amanda
$790.00
Sarah
$639.00
Elizabeth
$639.00
$7,075.01
$2068.00
Father
Mother

.374
.626

(1f fine 4 is less than $600, enter each parent's support
Ski to fine 15a and enter this amount.
$773.43
$1294.57
$117.00
line Sa lus line Sb
add father's and mother's totals from line Be
(line 8d minus line se., if "O" or negative, enter "O")
$117.00
$117.00
$103.40
$13.60
a.
$400.00
b.
C.
d.

Expenses (line Sf plus line 10)
$400.00
$400.00
$413.60
$154.69
$258.91
$928.12
$1553.48
Part Ill: Gross Child SupportObligation

$117.00
$400.00

$517.00
Transfer Payment


e. Enter the lowest amount of lines 1 Sb, 15c or 15d:

Father
Mother
$928.12
$1036.48
$928.12
$1036.48
Part VI: Additional Factors for Consideration (See Instructions, Page 8)

(Present estimated value of all major assets.)
a. Real Estate
b. Stocks and Bonds
c. Vehicles
d. Boats
f. Cash
Q. Insurance Plans
h. Other:
17. Household Debt

a.
b.
c.
d.
e.
f..
Name
Name
Name
Name
C. Income of Children (if considered extraordinarv)
Name
Name
Name
Name
Father's
Household
Mother's
Household
$1,000.00
--

Proqram
Program
19. Non-Recurrtno Income (describe)
Father's
Household
Mother's
Household
.
Name/age:
Name/age:

Father's income based on 10/03 paystubs. Taxes: S/2. Mother's income based on $31.00 per
hour/41 hours a week at UW with additional income from Multicare. Taxes: HH/3. Daycare
averaged over year of before/after care and full time summer.
Signature and Dates

contained in these Worksheets is complete, true, and correc .
er's Signature
J b rj_
//fJ 200(
Date
City
heet certified by the State of Washington Administrator for the Courts.

FILED
DEPT. 10
tN OPEN COUR
MAR 2 6 2004
SupportCa/c2003 T
13435 312912084 8@841
02-3-02768-6
20738564
FNFCL
03-26-04
1
2
3
4
FILED
DEPT. 10
IN OPEN COOR
MAR 2 6 2004

COUNTY OF PIERCE
8
9
10

DEBORAH J. DAHL
NO. 02-3-02768-6
and
FINDINGS OF FACT AND

CONCLUSIONS OF LAW
(FNFCL)
11
12
13
Petitioner,
JAMES R. DAHL
Respondent.
14
I. BASIS FOR FINDINGS
15
16
The findings are based on agreement.

II. FINDINGS OF FACT
17
18
19
Upon the basis of the court record, the court FINDS:

2.1
The petitioner is a resident of the State of Washington.
20
21
2.2
24
NOTICE TO THE RESPONDENT.

The respondent appeared, responded or joined in the petition.
22
23
RESIDENCY OF PETITIONER.
2.3
BASIS OF PERSONAL JURISDICTION
OVER THE RESPONDENT.
The facts below establish personal jurisdiction over the respondent.
II
FINDINGS OF FACT & CONCL OF LAW (FNFCL) - Page 1 of 6
WPF DR 04.0300 (7/2003)- CR 52; RCW 26.09.030;.070(3)
0 RIG I NA
J
~
SCOTI CANDOO
Attorney at Law
N. 30th Street, Suite~
Tacoma, WA 98403
(253)272-7274 - Office
The respondent is presently residing in Washington.
2.4
The parties were married on 9-9-83 at Pierce County.
3
4
2.5
2.6
8
2.7
2.8
A. Real Properties
14
15
16
17
18
19
20
21
22
23
24
COMMUNITY PROPERTY.
The parties have the following real or personal community property:
12
13
SEPARATION CONTRACT OR PRENUPTIAL AGREEMENT.

There is no written separation contract or prenuptial agreement.
10
11
STATUS OF THE MARRIAGE.

The marriage is irretrievably broken and at least 90 days have elapsed since the date
the petition was filed and since the date the summons was served or the respondent
joined.
STATUS OF THE PARTIES.

Husband and wife separated on 8-28-02.
5
6
DATE AND PLACE OF MARRIAGE.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
M.
N.
0.
P.
1. 916 Manor Drive, Fircrest, Washington 98466, legal description on Exhibit A.

2. 25812 - 120th Lane S.W., Vashon, Washington 98070, legal description on Exhibit A.
3. 228 Contra Costa Ave., Tacoma, Washington, legal description on Exhibit A.
2001 Chevrolet Tahoe.
1992 Chevrolet Silverado.
1989 Bonneville.
1980 Celica.
2002 Seaswirl boat.
Washington Mutual account #0335.
Washington Mutual account for rental.
Westop Credit Union account.
Columbia State Bank account.
Washington Mutual account #6390.
Multicare 403(b) Plan in Wife's name.
Wife's IRA.
Woodworker's IAM Pension Plan in Husband's name, 63% of which is community.
Woodworker's Defined Benefit Plan in Husband's name.
Southern Oil 401 (k) in Husband's name.
Q. Ameris Life Insurance policy, cash value.
R. Personal property in each's possession.
II
II

WPF DR 04.0300 (7/2003) - CR 52; RCW 26.09.030;.070(3)
FamilySot\ ForrnPAK 2003
SCOTI CANDOO
Attorney at Law
Tacoma, WA 98403
(253)272-7274 - Office
2.9
SEPARATE PROPERTY.
The husband has the following real or personal separate property:
A 37% of Woodworker's IAM Pension Plan.

B. All property acquired by him since separation.
3
4
The wife has the following real or personal separate property:
A All property acquired by her since separation.
2.10
The parties have incurred the following community liabilities:
A.
B.
C.
D.
E.
F.
G.
H.
I.
9
10
11
12
J.
13
K.
L.
14
M.
N.
0.
15
16
2.11
17
The wife has incurred the following separate liabilities:
20
A All debts incurred since separation.
21
24
SEPARATE LIABILITIES.
A Rainier Pacific - $9,595.00.

B. All debts incurred since separation.
19
23
Mortgage on Manor Drive property.

Mortgage on Vashon property.
Mortgage on Contra Costa property.
Colleague Services VISA - $4,604.00.
Capital One Mastercard - $2, 197.00.
SLM Financial - $3,000.00.
Bank of America VISA - $352.00.
Bank of America VISA - $3,567.00.
Capital One VISA - $15,299.00.
Debt to Respondent's mother - $12,000.00.
Columbia Bank
Westop CU Loan
Rainier Pacific boat loan - $9,595
Washington Mutual PLC
Chevron debt - $1,022
The husband has incurred the following separate liabilities:
18
22
COMMUNITY LIABILITIES.
2.12
MAINTENANCE.
Maintenance was not requested.
II
II
FINDINGS OF FACT & CONCL OF LAW (FNFCL) Page 3 of 6
WPF DR 04.0300 (7/2003) CR 52; RCW 26.09.030;.070(3)
SCOTT CANDOO
Attorney at Law
2115 N. 30th Street, Suite 20~
Tacoma, WA 98403
(253)272-7274 - Office
2.13
Does not apply.
2
3
2.14
2.15
2.16
9
10
11
12
2.17
14
17
2.18
20
23
24
Sarah
11
Elisabeth
Mother's/Father's
Names
Deborah Dahl
James Dahl
JURISDICTION OVER THE CHILDREN.
PARENTING PLAN.
The parenting plan signed by the court on 3-26-2004 is approved and incorporated as
part of these findings.
19
22
Age
14
This state is the home state of the children because the children lived in
Washington with a parent or a person acting as a parent for at least six
consecutive months immediately preceding the commencement of this
proceeding.
16
21
Name of
Child
Amanda
This court has jurisdiction over the children for the reasons set forth below:
15
18
DEPENDENT CHILDREN.
The children listed below are dependent upon either or both spouses.
13
PREGNANCY.
The wife is not pregnant.
6
7
FEES AND COSTS.

There is no award of fees or costs.
4
5
CONTINUING RESTRAINING ORDER
This parenting plan is the result of an agreement of the parties.

2.19
CHILD SUPPORT.
There are children in need of support and child support should be set pursuant to the
Washington State Child Support Schedule. The Order of Child Support signed by the
court on 3-26-2004 and the child support worksheet which has been approved by the
court are incorporated by reference in these findings.

WPF DR 04.0300 (7/2003) - CR 52; RCW 26.09.030;.070(3)
SCOTI CANDOO
Attorney at Law
2115N. 30th Street, Suite~
Tacoma, WA 98403
(253)272-7274 - Office
Other:
There is to be a judgment entered in favor of the Petitioner and against the Respondent
for unpaid childsupport which was ordered under the temporary orders in this matter.
2
3
2.20
OTHER.
NIA
5
6
111. CONCLUSIONS
The court makes the following conclusions of law from the foregoing findings of fact
3.1
8
9
3.2
3.3
14
15
16
DE
3.4
3.5
23
RESTRAINING ORDER.
ATTORNEY'S
. 1
IN OPEN COOR
MAR 2 6 2004
FEES AND COSTS.
Does not apply.
20
22
CONTINUING
Does not apply.
18
21
DISPOSITION.
The court should determine the marital status of the parties, make provision for a
parenting plan for any minor children of the marriage, make provision for the support of
any minor children of the marriage entitled to support, consider or approve provision for
the maintenance of either spouse, make provision for the disposition of property and
liabilities of the parties, make provision for the allocation of the children as federal tax
exemptions, make provision for any necessary continuing restraining orders, and make
provision for the change of name of any party. The distribution of prope
iabilities
as set forth in the decree is fair and equitable.
FPILTED O
13
19
GRANTING OF A DECREE.
The parties should be granted a decree.
12
17
JURISDICTION.
The court has jurisdiction to enter a decree in this matter.
10
11
OF LAW
3.6
OTHER.
N/A.
Dated:3
..-o?tz.., CY
24
WPF DR 04.0300 (7/2003) - CR 52; RCW 26.09.030;.070(3)
FatnilySoft FormPAK 2003
SCOTI CANDOO
Attorney at Law
Tacoma, WA 98403
(253)272-7274 - Office
..
'
Presented by:
2
3
4
5
Approved for entry:

/~
(~NDOO
W.S.B.A. #7815
Craig Beetham
W.S.B.A. #20139
JAMES R. DAHL
Respondent
DEBORAH J. DAHL
Petitioner
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
FINDINGS OF FACT & CONCL OF LAW (FNFCL)- Page 6 of6
WPF DR 04.0300 (7/2003) - CR 52; RCW 26.09.030;.070(3)
FamilySoft ForrnPAK 2003
SCOTT CANDOO
Attorney at Law
Tacoma, WA 98403
(253)272-7274 - Office
. . .
Presented by:
Approved for entry:

Notice of presentation wai
4
5
SC TICANDOO
W.S.B.A. #7815
Attorney for Responde t
Petitioner
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
WPF DR 04.0300 (712003)- CR 52; RCW 26.09.030;.070(3}
Fami!ySoft FonnPAK 2003
SCOTI CANDOO
Attorney at Law
Tacoma, WA 98403
(253)272-7274 - Office
20119
11 ~ l I Ill l\'11111111
o2-3.a2160-6
39129s22
sTFJ~
-.- - -o~~~-1~
.....
9/5/2012
aa~a3
URT FOR Pierce COUNTY, WASHINGTON

No. 04-9-03737-0
Deborah J. Dahl
Plaintiff
vs
0 d-
:s -Q dlb8-~ED
SATISFACTION OllN COUNTY CLERK'S OFFICE

JUDGMENT
A.M.
James R. Dahl
SEP - 4 2012
Defendant
P.M.

KNOW ALL PERSONS BY THESE PRESENTS: that Deborah J. Dahl, the judgment cred~6T1rran action
- DEPUTY
in the Superior Court of the State Washington for the County of Pierce, wherein Deborah J. Dahl, Plaintiff
(s) and James R. Dahl, Defendant(s) hereby acknowledges l!J full D partial satisfaction of the judgment
recovered against James R. Dahl on the 20th day of June, 2012 in the sum of $6,522.10 including D
costs and D interest, which said judgment is entered in the execution docket of said Court.
Deborah J. Dahl
or Attorney for Plaintiff(s)
Address
Telephone
State of Washington
SS.
County of Pierce
I certify that I know or have satisfactory evidence that Deborah J. Dahl is the person who appeared
before me, and said person acknowledged that free and voluntary act for the uses and purposes
mentioned in this instrument.
Dated: June 20, 2012
Notary name printed or typed: Rob Ross

Notary Public in and for the State of WA
Residing at Univ Place
My appointment expires: April 08, 2014
E-FILED
December 14 2004 11:00 AM
KEVIN STOCK
COUNTY CLERK

DEBORAH J DAHL
Petitioner(s),
vs.
NO. 02-3-02768-6
NOTICE OF INTENT TO WITHDRAW
JAMES R DAHL
Respondent(s)
TO: Clerk of the Court

AND TO: P. CRAIG BEETHAM, attorney for Petitioner
NOTICE IS HERBY GIVEN that SCOTT ALEXANDER CANDOO intends to withdraw as
attorney for Respondent(s) JAMES R DAHL, in the above-entitled action on the December 27,
2004. This notice is given pursuant to Civil Rule 71(c) of the Rules for Superior Court.
Withdrawal shall be effective without court order and without the service and filing of any
additional papers unless an objection to the withdrawal is served upon the withdrawing attorney
prior to the date set fourth above.
There is no trial date scheduled for this case.
PAGE 1 OF 2
ntiwdsup-0001.pdf

2115 N 30th St Ste 201
TACOMA, WA 98403-3397
(253) 272-7274
02-3-02768-6
The last know name and address of the parties I have been representing are listed below:
JAMES R DAHL
25812 - 120TH LANE SW
VASHON ISLAND, WA 98070
CERTIFICATE OF SERVICE
I certify under penalty of perjury under the laws of the State of Washington that the foregoing is
true and correct: That on December 14, 2004, I mailed a copy of this document to the attorney(s)
of record and/or parties at their respective addresses of record.
DATED: December 14, 2004
PAGE 2 OF 2
ntiwdsup-0001.pdf
/s/ SCOTT ALEXANDER CANDOO

SCOTT ALEXANDER CANDOO, #7815
Attorney for Respondent(s)

2115 N 30th St Ste 201
TACOMA, WA 98403-3397
(253) 272-7274
02-3-02768-6
23808759
STFJG
09-30-05
FI LED
IN COUNTY CLERK'S
RAINIER TITLE COMPANY

6004 WESTGATEBLVD
SUITE 120
TACOMA, WA 98406
A.M.
SEP 3 0 2005
PIERCE CO
KEVIN S
BY
PIERCE COUNTY
02-3-02768-6
PLAINTIFF:
DEBORAH J. DAHL
DEFENDANT:
JAMES R. DAHL
OFFICE
RTC
SEP 3 0 2005
~\ 'l ~?\t1
P.M.
TY, WASHINGTON
CK, County Clerk
DEPUTY
21734
10/3/2005
IN THE DISTRICT COURT FOR Pierce COUNTY, WASHINGTON

Deborah J. Dahl
NO. 02-3-02768-6
Plaintiff
vs.
James R. Dahl
Defendant
KNOW ALL PERSONSBY THESE PRESENTS:That Deborah J. Dahl, the Judgment creditor in an
action in the District Court of the State of Washington, for the County of Pierce, wherein James R.
Dahl, Plaintiff(s), and Deborah J. Dahl, Defendant(s), hereby acknowledge(s) X full D partial
satisfaction of the Judgment recovered against Deborah J. Dahl, on the 26th day of September
2005, in the sum of $25,000 including x costs and D interest, which said Judgment is entered in
the execution docket of said Court.
Dated: September 26, 2005
Deborah J.
hi
State of Washington
County of
'\? \.Q..I{
SS:
\......
$-e2 .\e h> h>(
, ~
~
, before me personally appeared
\)c.,b \
to me known
to be the individual(s) described in and who executed the ~n
and foregoing instrument, and
acknowledged that
':>he
signed the same as
__be c
freeand voluntary act and
deed for the uses and purposes therein mentioned.
Given under my hand and official seal the day and year last above written.
On this ~
day of
tye-~C)'\s'h, :;J
Notary Public in and for the State of

Residing at
\sc c~
My Appointment expires:
I a-1
<a-cl=
Satisfaction of Judgment
Page 1 of 1
LPB-62
RAINIER TITLE COMPANY
Reference: 20175699303CB1
LPB-62 {7/97)
00047
02-3-02768-6
27390367
PIERCE COUNTY SUPERIOR COURT

KEVIN STOCK
CURI< OF THE SUPERIOR COURT
SM
TACOMA WA
02-3-02768-t.
3
4
5
Rcpt. Date
04/26/2!JJ?
Acct [~3te
041261200?
ReceiPt!Item H
Tran-GOlje Docket- ' de
2007-05-06857/01
Cashier: MLN
1104
Tim ,
12:03 PM
$FFR
p,jid BY: EISONHO*'ERT,, CARLSON
T nmsaction Amount:
Superior Court of Washington

County of PIERCE
8
9
In re:
10
DEBORAH J. DAHL
A.M.
No. 02-3-02768-6
Petitioner,
12
and
13
JAMES R. DAHL
APR 6 2007
PIERce
KEVIN
11
$4 .. 00
Summons for Modifica\101'!'-r---..:=

of Child Support
(SM)
Respondent.
14
15
To: James Dahl
16
1.
An action has been started against you in the above court requesting that the court
modify the child support provisions of your support order. The requests are stated in the
petition, a copy of which is served upon you with this summons. .
2.
You must respond to this summons and petition by filing a written response with the
clerk of the court and by serving a copy of your response on the person signing this
summons. You must also complete the Washington Child Support Schedule Worksheet
and a Financial Declaration (Form WPF DRPSCU 01.1550) served with this summons.
The completed worksheet and financial declaration must be filed and served with your
written response.
3.
Your written response to the summons and petition must be on form WPF DR 06.0300,
Response to Petition for Modification of Child Support (RSP). This form may be
obtained by contacting the clerk of the court at the address below, by contacting the
Administrative Office of the Courts at (360) 705-5328, or from the Internet at the
Washington State Courts homepage:
17
18
19
20
21
22
23
24
25
Summons for Mod of Child Suppt (SM) - Page 1 of 2

WPF DR 06.0200 (6/2006) - CR 4.1; RCW 26.09.175 (2),(3)
Fam11ySott FormPAK 2006
. ?IGINAL

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 Facsimile
410 4/27/2087
00077
1
4.
If you do not file and serve your written response within 20 days (60 days if you are
served outside of the State of Washington) after the date this summons was served on
you, exclusive of the date of service, the court may, without further notice to you, enter a
default judgment against you ordering the relief requested in the petition. If you serve a
notice of appearance on the undersigned person, you are entitled to notice before an
order of default may be entered.
5.
You may demand that the other party file this action with the court. If you do so, the
demand must be in writing and must be served upon the person signing this summons.
Within 14 days after you serve the demand, the other party must file this action with the
court, or the service of this summons and petition will be void.
6.
If you wish to seek the advice of an attorney in this matter, you should do so promptly so
that your written response, if any, may be served on time. Copies of these papers have
not been served upon your attorney.
7.
One method of serving your written response, completed worksheet and financial
declaration is to send them by certified mail with return receipt requested.
2
3
4
5
6
7
8
9
10
11
This summons is issued pursuant to Superior Court Civil Rule 4.1 and RCW 26.09.175(2) and
(3) of the State of Washington.
12
13
Dated:
14
15
16
17
18
19
File originalof your answerand other

documentswith the clerk of the court
at:
Clerk of the Court
Pierce County Court
County-City Building
930 Tacoma Ave. S., Rm 110
Tacoma, WA, 98402
20
Serve a copyof your answerand other

documentson:
Moving Party's Lawyer

P. Craig Beetham
1201 Pacific Avenue
Tacoma, WA 98402
21
22
23
24
25
Summons for Mod of Child Suppt (SM) - Page 2 of 2

WPF DR 06.0200 (6/2006) - CR 4.1; RCW 26.09.175 (2),(3)

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 Facsimile
02-3-02768-6
27390368
$PTMDS
04-26-07
2
3
4
5
6
7
County of PIERCE
In re:
10
DEBORAH J. DAHL
No. 02-3-02768-6
11
Petitioner,
12
and
13
JAMES R. DAHL
Petition for Modification

of Child Support
(PTMD)
Respondent.
14
15
I. Basis
16
Deborah J. Dahl represents to the court that:
17
1.1
Placeof Residence
18
The petitioner resides in Pierce County, WA.
19
The children reside in Pierce County, WA.
20
The respondent resides in Pierce County, WA_
21
1.2
Jurisdiction Over Parents
22
This court has jurisdiction over the parents for the reasons that follow.
23
There is a Washington Order of Child Support.
24
Both parties presently reside in the State of Washington.
25
Pet for Mod of Child Suppt (PTMD) - Page 1 of 3

WPF DR 06.0100 {6/2006) - RCW 26.09.170; .175
FamilySoft FormPAK 2006
OR,G\NAL

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 Facsimile
418
4/27/2897
00079
,,...
1.3
Most Recent Support Order
The most recent support order was entered in Pierce County on March 26, 2004.
The order requires James Dahl to pay $928.12 per month for the support of (fist names
of children:
4
Amanda Dahl
Sarah Dahl
Elizabeth Dahl
5
6
7
1.4
Reasons for Modifying Child Support

The order of child support should be modified for the following reasons.
9
Amanda Dahl is in need of post secondary educational support because the child is in
fact dependent and is relying upon the parents for the reasonable necessities of life.
10
11
Amanda Dahl is a dependent adult child and support should be extended beyond his or
her eighteenth birthday.
12
The previous order was entered more than a year ago and:
13
The children have moved to a new age category for support purposes.
14
The children are still in high school and there is a need to extend support beyond
the children's eighteenth birthday to allow the children to complete high school.
15
16
1.5
17
The starting date of the modified child support order should be the date on which this
petition is filed.
18
19
Starting Date of Modified Order
1.6
Other
20
21
22
23
24
25
Pet for Mod of Child Suppt (PTMD) - Page 2 of 3

WPF OR 06.0100 (6/2006) - RCW 26.09.170; .175
FamilyScfl FcrmPAK 2006

1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 Facsimile
410
4/27/2067
II. Relief Requested
The court should modify the order of child support by requiring either or both parents to
maintain or provide health insurance coverage consistent with RCW 26.09.105 for the children,
if not previously ordered, and by:
0@080
ordering child support payments which are based upon the Washington State Child
Support Schedule.
5
6
7
extending child support beyond Amanda Dahl's eighteenth birthday to allow the child to
complete high school.
extending child support beyond Amanda Dahl's eighteenth birthday until she is no longer
dependent upon either or both parents and is capable of self-support.
8
allowing for post secondary educational support for Amanda Dahl.
9
ordering the payment of attorney fees and costs.
10
11
, WSBA #20139
e tioner
13
14
15
16
I declare under penalty of perjury under the laws of the State of Washington that the foregoing
is true and correct.
17
Signed at----------'
[City]
[State] on
[Date].
18
19
Deborah Dahl
Signature of Petitioner
20
21
22
23
24
25
Pet for Mod of Child Suppl (PTMD) - Page 3 of 3

WPF DR 06.0100 (6/2006) - RCW 26.09.170; .175

1200 WELLS.FARGO PLAZA
1201 PACIFIC AVENUE
TACOMA, WA 98402
(253) 572-4500
(253) 272-5732 Facsimile
410 4/27/2007
00081
-- .
1
2
3
4
5
6
s
9
10
12

The court should modify the order of child support by requiring either or both parents to
maintain or provide health insurance coverage consistent with RCW 26.09.105 for the children,
if not previously ordered, and by:
ordering child support payments which are based upon the Washington State Child
Support Schedule.
extending child support beyond Amanda Dahl's eighteenth birthday to allow the child to
complete high school.
extending child support beyond Amanda Dahl's eighteenth birthday.until she is no longer
. dependent upon either or both parents and is capable of self-support.
allowing for post secondary
educational support for Amanda Dahl.
Dated: ~----.~"""""-----+-~~~
13
14
15
16
I dedare under penalty of

17
18
Signed at
perjury under the laws of the State of Washington that the foregoing
VA PS He. s J 4.t.w~J.
[City]
wA
[State) on
J_{ Apro 1
[Date].
19
Debcirah Dahl
20
Signature of Petitioner
21
22
23
..
~
24
25
Pet for Mod of Child Suppt {PTMD) Page 3 of 3

WPF DR 06.0100 (6/2000) - RCW 26.09. 170; .175
FamllySofl FO!mPAI<2000
i
"EISENHOWER &c CARLSON, PLlq
i200 Vv""EU..S.FARGO Pl.AZ..~
1201 PACIFIC A VENUE
TACOMA, WA 98402
(253) 572-4500
(253) ?..72-5732 Facsimile
410 4/27/2007 00082

,~--.
DECLARATION REGARDING FILING OF FACSIMILE

SIGNATURE PAGE OF DEBORAH DAHL
IN DAHL AND DAHL
3
4
Julie M. Worrell certifies under penalty of perjury under the State of Washington that the
5
following is true and correct:
6
I am employed with Eisenhower & Carlson, PLLC, attorneys for Petitioner, Deborah Dahl,
7
and make this declaration pursuant to GR l 7(a)(2).
8
The name of the document to be filed with a facsimile signature, to which this declaration is
9
10
11
12
13
14
attached, is the Petition for Modification.

The Petition consists of 4 pages together with a facsimile copy of page 4 bearing the
signature of Deborah Dahl and this declaration page, for a total of 5 pages. I have examined the
Petition and I have determined that the document is a complete and legible petition.
DATED at Tacoma, Washington, on this 251h day of April, 2007.
15
16
Paralegal
17
18
19
20
21
22
23
24
25
26
GR 17 DECLARATION
EISENHOWER
00341092.DOC
-------EISENHOWER & CARLSON,
1200WellFargoPlaza
I 20 ~ Pacific Avenue
Taco"' WA9840l
PLLC ~:~
;;;:~;:::ii~o
E-FILED
May 15 2007 10:52 AM
KEVIN STOCK
COUNTY CLERK

DEBORAH J DAHL
Petitioner(s),
vs.
NO. 02-3-02768-6
NOTICE OF APPEARANCE
JAMES R DAHL
Respondent(s)
AND TO: P. CRAIG BEETHAM, attorney for Petitioner, DEBORAH J DAHL, AMANDA
DAHL, SARAH J DAHL, ELIZABETH R DAHL
PLEASE TAKE NOTICE that SCOTT ALEXANDER CANDOO, appears herein on behalf
of the Respondent(s) JAMES R DAHL and requests that all further pleadings and paper, except
original process, be served upon said attorney at the address listed below.
DATED: May 15, 2007
ntaprsup-0001.pdf


2115 N 30th St Ste 201
TACOMA, WA 98403-3397
(253) 272-7274
02-3-02768-6
278 7272S
NTAB
07-16-07
IN couNrf ILE D
CLERK'S OFF/ E
JUL 1 6 2007
A.M.
k~RCEcouN
BY VIN
f,}fk
fN THE SUPERIOR COURT OF THE STATE OF WAS HIN~

6
7
DEBORAH DAHL,
sroc'fl WASH/ 'Gro
TY
NO. 02-3-02768-6
Petitioner,
NOTICE OF ABSENCE AND
UNA V AILABJLITY
9
vs.
10
JAMES DAHL,
11
Res ondent.
12
13
TO:
Clerk of the Above-Entitled Court
AND TO:
All Parties and Their Respective Counsel Herein
14
YOU, AND EACH OF YOU, please take notice that P. CRAIG BEETHAM of
15
EISENHOWER & CARLSON, PLLC will be unavailable from August 6, 2007, through
16
August 16, 2007.

17
PLEASE REFRAIN from filing or attempting to serve any motions or other forms
18
of expedited pleading practice that would conflict with the undersigned's

19
unavailability
for the period specified.

20
21
DATED this /~day of July, 2007.
22
23
24
25
/JJnBJnam, WSBA # 20139

r Petitioner
26
NOTICE OF ABSENCE AND UNA v AILABIJd.R
00362232.DOC
l G N~EtOWER
J
& CARLSON, PLLC
ATIOl!.NEYS-A T-U. W
1201 PACIFIC AVENUE
TACOMA, WASHrNGTON 98402
PHONE 253-512-4500
FAX 253-272-5732
II
02-3-02768-6
28661098
FI LED
11-19-07
NTAB
NOV I 8 2007
A.M.
PIEE,~CE COUNTY WASHINGTON

KBY .-IN )TOCK, CountY: Clerk
P.M.
OEPUTY
4
5
6
7
DEBORAH DAHL,
NO. 02-3-02768-6
Petitioner,
NOTICE OF ABSENCE AND

UNAVAILABILITY
vs.
10
JAMES DAHL,
11
Res ondent.
12
13
TO:
Clerk of the Above-Entitled Court
ANDTO:
All Parties and Their Respective Counsel Herein
14
YOU, AND EACH OF YOU, please take notice that P. CRAIG BEETHAM of
15
EISENHOWER
16
17
18
19
&
CARLSON, PLLC will be unavailable from December
through January t,
2008.
PLEASE REFRAIN from filing or attempting to serve any motions or other forms
of expedited pleading practice that would conflict with the undersigned's unavailability
for the period specified.
20
21
t, 2007,
/
DATED this
/)
22
23
24
25
etham, WSBA #
for Petitioner
20139
26
ORIGINAL
NOTICE OF ABSENCE AND UNAVAILABILITY

00372109.DOC
- I

A 'ITORNEYS-AT-LA W
1201 PACIFlCAVENUE
PHONE 253-572-4500
FAX 253-272-5732
E-FILED
December 05 2012 4:22 PM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

IN RE:
DEBORAH J DAHL
Petitioner(s)
No. 02-3-02768-6
RELOCATION:
ORDER ASSIGNING CASE TO FAMILY COURT
& NOTICE OF HEARING
Vs.
JAMES R DAHL
(ASTRELO)
Respondent(s)
This case is determined to be a family court matter (RCW 26.12.010) and has been assigned to FAMILY COURT - 2,
Judge JAMES ORLANDO.
Notice to Objecting Party:
Once the objection is filed, the objecting party shall serve a copy of this Notice & Order on the relocating party. (RCW
26.09.480)
Trial Date:
Hearings involving relocations or intended relocations of children are to be accorded priority by the court. (RCW
26.09.560.)
Assignment to Set Trial Date
Friday - December 14, 2012 9:00 AM
At that time, the court will provide you a trial date for hearing the objection to relocation. Failure to appear will result in the dismissal
of the objection and allowing the relocation.
The resource of this report item is not reachable.

Dated: December 5, 2012
Judge: FAMILY COURT - 2
Department ORLA
Pierce County Superior Court: County-City Building, 930 Tacoma Avenue South, Tacoma WA 98402.
Dec 5, 2012 4:22 PM
.. a.
' ~'
I'
02-3-02768-6
39416803
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FI LED
P.M.
10-26-12
PPP
PIERCE COUITTY, W
KEVIN STO K.
BY

County of Pierce
[X ] In re the Marriage of:
[ ] In re the Domestic Partnership of:
No. 02-3-02768-6
DEBORAH J. DAHL
Petitioner,
and
JAMES R. DAHL
Res
ndent.
Parenting Plan
[X ] Proposed (PPP}
[ ] Temporary (PPT)
[]Final Order (PP)
This parenting plan is:

[]
[]
[]
[X]
the final parenting plan signed by the court pursuant to a decree of dissolution, legal
separation, or declaration concerning validity signed by the court on this date or
dated ~~~~~~~~~~
the final parenting plan signed by the court pursuant to an order signed by the court on
this date or dated
which modifies a previous parenting
plan or custody decree.
a temporary parenting plan signed by the court.
proposed by (name) Deborah J. Dahl.
It Is Ordered, Adjudged and Decreed:

I. General lnfonnation
Name
Elizabeth R. Dahl
(DOB 01-01-1997)
Parenting Plan (PPP, PPT, PP) - Page 1 of 11

WPF DR 01.0400 Mandatory (6i2008) - RCW 26.09.016, .181; .187; .194
Age
IS
HING10N
unty Clerk
QEPUTY
II. Basis for Restrictions

Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contact with the child and the right to make decisions for the child.
2.1
Parental Conduct(RCW 26.09.191 (1 ), (2))

[X]
[]
Does not apply.

The []petitioner's [] respondent's residential time with the child shall be limited or
restrained completely, and mutual decision-making and designation of a dispute
resolution process other than court action shall not be required, because [ ] this parent
[]a person residing with this parent has engaged in the conduct which follows:
[]
(]
[]
Wil1ful abandonment that continues for an extended period of time or substantial

refusal to perform parenting functions (this applies only to parents, not to a
person who resides with a parent).
Physical, sexual or a pattern of emotional abuse of a child.
A history of acts of domestic violence as defined in RCW 26.50.010( 1) or an
assault or sexual assault which causes grievous bodily harm or the fear of such
harm.
2.2
Other Factors (RCW 26.09.191 (3))

[]
[X]
Does not apply.

The []petitioner's [X] respondent's involvement or conduct may have an adverse
effect on the child's best interests because of the existence of the factors which follow:
[]
[]
[X ]
[]
[]
[]
[]
Neglect or substantial nonperformance of parenting functions.

A Jong-term emotional or physical impairment which interferes with the
performance of parenting functions as defined in RCW 26.09.004.
A long-term impairment resulting from drug, alcohol, or other substance abuse
that interferes with the performance of parenting functions.
The absence or substantial impairment of emotional ties between the parent and
child.
The abusive use of conflict by the parent which creates the danger of serious
damage to the child's psychological development.
A parent has withheld from the other parent access to the child for a protracted
period without good cause.
Other:
Ill. Residential Schedule

The residential schedule must set forth where the child shall reside each day of the year,
including provisions for holidays, birthdays of family members, vacations, and other special

WPF DR 01.0400 Mandatory(612008)- RCW 26.09.016, .181; .187; .194
occasions, and what contact the child shall have with each parent Parents are encouraged to
create a residential schedule that meets the developmental needs of the child and individual
needs of their family. Paragraphs 3. 1 through 3. 9 are one way to write your resident;af
schedule. If you do not use these paragraphs, write in your own schedule in Paragraph 3. 13,
3.1
Schedule for Children Under School Age

[X]
[]

Prior to enrollment in school, the child shall reside with the []petitioner
[]respondent, except for the following days and times when the child(ren) will reside
from (day and time)
[]
[]
every week [ ] every other week [ ] the first and third week of the month
the second and fourth week of the month [ ] other:
from (day and time)

[]
[]
3.2
to (day and time)--------
--------~ to (day and time) --------
every week [ ] every other week [ ] the first and third week of the month
SchoolSchedule
Upon enrollment in school, the child shall reside with the [X] petitioner
[ ] respondent, except for the following days and times when the child will reside with or be with
the other parent:
from (day and time)--------[]
[]
every week []every other week []the first and third week of the month
From (day and time)

[]
[]
[]
to (day and time)-------
to (day and time)
every week []every other week []the first and third week of the month
The school schedule will start when each child begins []kindergarten [)first grade
[]other:

WPF DR 01,0400 Mandatory (61'2008) - RCW 26.09.016, .181;, 187;, 194
3.3
Schedule for WinterVacation

The child shall reside with the [X] petitioner [ ] respondent during winter vacation, except for
the following days and times when the child will reside with or be with the other parent:
Winter vacation shall be split between the parents as follows. In odd numbered years beginning
in 2013, the child shall spend the portion of vacation through Christmas Day with the
petitioner/mother. The child shall then travel to Washington State to spend the remainder of
winter vacation, through some portion of New Year's Day with the respondent/Father. The child
shall then return to North Carolina with the goal of arriving for the resumption of classes
In even numbered years beginning in 2014, the child shall travel to Washington following her
release for winter vacation and spend that portion of winter vacation through Christmas Day
with the respondent/father. The child sha11 then return to North Carolina and spend the
remainder of winter vacation with the petitioner/mother.
3.4
Schedule for Other School Breaks

The child shall reside with the [X ] petitioner [ ] respondent during other school breaks, except
for the following days and times when the child will reside with or be with the other parent:
3.5
Summer Schedule
Upon completion of the school year, the child shall reside with the [X] petitioner
[]respondent, except for the following days and times when the child will reside with or be with
the other parent:
[ ] Same as school year schedule.
[X] Other: During summer break, the child shall spend two consecutive weeks with the
respondent/father, to be scheduled by March 30Cb of each year. It is anticipated that the
precise scheduling of the 2 week visitation shall take into consideration when
respondent/father is able to schedule his own vacation. The parties shall also take into
consideration the child's athletics schedule in establishing each summer's visitation
period.
3.6
Vacation With Parents

[X]
[]
Does not apply.

The schedule for vacation with parents is as follows:
(Vacations with respondent father are governed by 3.5 above.)
Parenting Plan (PPP, PPT, PP} - Page 4 of 11

WPF DR 01.0400 Mandatory (61'2008) - RCW 26.09.016, .181; .187; .194
3. 7
Schedule for Holidays

The residential schedule for the child for the holidays listed below is as follows:
With Petitioner
(Specify Year
Odd/Even/Every)
New Year's Day
Martin Luther King
Presidents' Day
Memorial Day
July 4th
Labor Day
Veterans' Day
Thanksgiving Day
Christmas Eve
Christmas Day
With Respondent
(Specify Year
Odd/Even/Every)
See section 3 .3 above.

Every
Every
Every
Every
Every
Every
Every
See section 3.3 above.
See section 3.3 above.
[]
For purposes of this parenting plan, a holiday sha11 begin and end as follows (set forth
times):
[]
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
a) [X ]
Other: See section 3.3 ref winter vacation and section 3.5 ref summer
vacation. The child's birthday shall be governed by Stttion 3.3 ref Winter Break.
Subject to preserving the child's school and athletic schedule, the respondent father
may exercise periodic special occasion visitation in North Carolina, at his own
expense. Such special occasion visitation shall be scheduled at least 60 days in
advance and with a good faith effort not to disrupt activities already planned by
child and petitioner/mother.
3.8
Schedulefor Special Occasions

The residential schedule for the child for the foJJowing special occasions (for example, birthdays)
is as follows:
With Petitioner
With Respondent
(Specify Year
(Specify Year
Odd/Even/Every)
Odd/Even/Every)
Mother's Day
Every
Father's Day
Every

WPF DR 01.0400 Mandatory (6/2008)- RCW 26.09.016, .181; .187; .194
[X ]
3.9
Other: See 3.3, 3.5 and 3. 7 above.
Priorities Under the ResidentialSchedule

[]
(X]
Does not apply because one parent has no visitation or restricted visitation.
Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1and3.2, in the following order:
(X]
winter vacation (3 .3)
_ 5_school breaks (3 .4)
2 summer schedule (3.5)
_I_
[)
_3_holidays (3.7)
_4_special occasions (3.8)
_6 _vacation with parents (3 .6)
Other:
3.10 Restrictions
[]
[X]
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
The []petitioner's (X] respondent's residential time with the children shall be limited
because there are limiting factors in paragraphs 2.1 and 2.2. The following restrictions
shall apply when the children spend time with this parent:
No alcohol consumption 24 hours before visitation is to begin, during visitation or

when transporting child during visitation.
The child shall not serve as a messenger between the parents and any disputes
between the parents shall be resolved by the parents without placing the child in the
middle.
(]
There are limiting factors in paragraph 2.2, but there are no restrictions on the
[ J petitioner's []respondent's residential time with the children for the following
reasons:
3.11 Transportation Arrangements

Transportation arrangements for the child, between parents shall be as follows:
Section 3.7 visitation shal1 be the responsibility of the father, including his own expenses for
travel to North Carolina and expenses while he is there.
Section 3.3/Winter Break and 3.5/Summer break shall be:
WPF DR 01.0400 Mandatory (61'2008)-RCW 26.09.016, .181; .187; .194
The Petitioner/mother shall pay the child's round trip travel expenses from North Carolina
to Washington State and back for the child's for summer break visitation.
The respondent/father shall pay child's round trip expenses from Nonh Carolina to
Washington and back for the child's winter break visitation.
3.12
Designation of Custodian
The children named in this parenting plan are scheduled to reside the majority of the time with
the ( X] petitioner [] respondent. This parent is designated the custodian of the child solely for
purposes of all other state and federal statutes which require a designation or determination of
custody. This designation shall not affect either parent's rights and responsibilities under this
parenting plan.
3.13 Other: (None)

3.14
Summary of RCW 26.09.430 - .480, Regarding Relocation of a Child

This is a summary only. For the full text, please see RCW 26.09.430 through 26.09.480.
If the person with whom the child resides a majority of the time plans to move, that person shaJJ
give notice to every person entitled to court ordered time with the child.
If the move is outside the child's school district, the relocating person must give notice by
personal service or by mail requiring a return receipt.
the intended move. If the relocating person could not
60 days' notice, that person must give notice within 5
notice must contain the information required in RCW
07 .0500, (Notice of Intended Relocation of A Child).
This notice must be at least 60 days before

have known about the move in time to give
days after learning of the move. The
26.09.440. See also form DRPSCU
If the move is within the same school district, the relocating person must provide actual notice by
any reasonable means. A person entitled to time with the child may not object to the move but
may ask for modification under RCW 26.09.260.
Notice may be delayed for 21 days if the relocating person is entering a domestic violence shelter
or is moving to avoid a clear, immediate and unreasonable risk to health and safety.
If information is protected under a court order or the address confidentiality program, it may be
withheld from the notice.
A relocating person may ask the court to waive any notice requirements that may put the health
and safety of a person or a child at risk.
Failure to give the required notice may be grounds for sanctions, including contempt.
If no objection is filed within 30 days after service of the notice of intended relocation, the
relocation will be permitted and the proposed revised residential schedule may be
confirmed.
A person entitled to time with a child under a court order can file an objection to the child's
relocation whether or not he or she received proper notice.
WPP: DR 01.0400 Mandatory (612008) - RCW 26.09.016, .181; .187; .194
An objection may be filed by using the mandatory pattern form WPF DRPSCU 07 .0700,
(Objection to Relocation/Petition for Modification of Custody Decree/Parenting Plan/Residential
Schedule). The objection must be served on all persons entitled to time with the child.
The relocating person shall not move the child during the time for objection unless: (a) the
delayed notice provisions apply; or (b) a court order allows the move.
If the objecting person schedules a hearing for a date within 15 days of timely service of the
objection, the relocating person shall not move the child before the hearing unless there is a
clear, immediate and unreasonable risk to the health or safety of a person or a child.
IV. Decision Making

4.1
Day-to-Day Decisions
Each parent shall make decisions regarding the day-to-day care and control of each child while
the child is residing with that parent. Regardless of the allocation of decision making in this
parenting plan, either parent may make emergency decisions affecting the health or safety of the
children.
4.2
Major Decisions
Education decisions
Non-emergency health care
Religious upbringing
[X]
[X]
[X]
[]
[]
[]
[]
[]
[]
4.3
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
[]
[]
[]
[]
[]
[]
[]
[]
[]
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
[]
[]
[]
[]
[]
[]
[]
[]
[]
joint
joint
joint
joint
joint
joint
joint
joint
joint
Restrictionsin Decision Making

[)
[X ]
Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2 above.
Sole decision making shall be ordered to the [X] petitioner [ ] respondent for the
following reasons:
[J
[]
[X ]
A limitation on the other parent's decision making authority is mandated by

RCW 26.09.191 (See paragraph 2.1).
Both parents are opposed to mutual decision making.
One parent is opposed to mutual decision making, and such opposition is
reasonably based on the following criteria:
(a)
The existence ofa limitation under RCW 26.09.191~

WPF DR 01.0400 Mandatory (612008) - RCW 26.09.016, .181; .187; .194
(b)
(c)
(d)
[]
The history of participation of each parent in decision making in each of

the areas in RCW 26.09.184(4)(a);
Whether the parents have demonstrated ability and desire to cooperate
with one another in decision making in each of the areas in
RCW 26.09.184(4)(a); and
The parents' geographic proximity to one another, to the extent that it
affects their ability to make timely mutual decisions.
There are limiting factors in paragraph 2.2, but there are no restrictions on mutual
decision making for the following reasons:
[X] OTHER: The last parenting plan provided for some mutual decision making.
Circumstances have changed, however. There is now only one child covered by the
parenting plan, this cbiJd is older, 16 on January 01, 2013, and the respondent has
not voluntarily engaged in the decision making process in recent years. Now,
relocation to North Carolina will affect the parties' ability to make timely decisions.
V. Dispute Resolution
The purpose of this dispute resolution process is to resolve disagreements about carrying out
this parenting plan. This dispute resolution process may, and under some local court rules or
the provisions of this plan must be used before filing a petition to modify the plan or a motion for
contempt for failing to follow the plan.
[X]
Disputes between the parties, other than child support disputes, shall be submitted to (list person
or agency):
[]
counseling by
[X ]
mediation by a dispute resolution center as agreed by the parties, with consideration

of video or remote meeting technology. If this box is checked and issues of domestic
violence or child abuse are present, then the court finds that the victim requested
mediation, that mediation is appropriate and that the victim is permitted to have a
supporting person present during the mediation proceedings, or
[]
arbitration by
The cost of this process shall be allocated between the parties as follows: As determined in the
mediation process
[]
[]
[X ]
% petitioner
% respondent.
based on each party's proportional share of income from line 6 of the child support
worksheets.
as determined in the dispute resolution process.
Parenting Plan (PPP. PPT, PP) - Page 9 of 11

WPF DR 01.0400 Mandatory (6i2008) - RCW 26.09.016, .181; .187; .194
The dispute resolution process shall be commenced by notifying the other party by
request [X ] certified mail [ ] other:
I ) written

(a)
(b)
(c)
(d)
(e)
[]

Unless an emergency exists, the parents shall use the designated process to resolve
disputes relating to implementation of the plan, except those related to financial support.
A written record shall be prepared of any agreement reached in counseling or mediation
and of each arbitration award and shall be provided to each party.
If the court finds that a parent has used or frustrated the dispute resolution process
without good reason, the court shall award attorneys' fees and financial sanctions to the
other parent.
The parties have the right ofreview from the dispute resolution process to the superior
court.
No dispute resolution process, except court action is ordered.
VI. Other Provisions

[]
[X ]
There are no other provisions.

There are the following other provisions
A.
The respondent father shall not consume alcohol within 24 hours of exercising visitation
and shall not consume alcohol during visitation or prior to transporting the child.
B.
The child shall not be used to gather information on the other parent or to
transport/transmit messages between the parents.
C.
Disputes between the parents shall be resolved between the parent's and the child shall not
be involved in those disputes, if any. Specifically,the child shall not be the sounding board
or point of contact for one parent's dissatisfaction or anger with the other parent.
D.
The child's physical and emotional weH-beingand development are of paramount

importance and shall be the gauge when assessing parental interaction with the child.
VII. Declaration for Proposed Parenting Plan

[]
[X]
Does not apply.

(Only sign if this is a proposed parenting plan.) 1 declare under penalty of perjury under the laws
Parenting Plan (PPP, PPT, PP) - Page 10of11

WPF DR 01.0400 Mandatory (612008)- RCW 26.09.016, .181; .187; .194
of the state of Washington that this plan has been proposed in good faith and that the statements in Part II
of this Plan are true and correct.
October ~ 3, 2012 at Fircrest, WA
Petitioner
Date and Place of Signature
Respondent
VIII. Order by the Court

It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and approved as an
order of this court.
WARNING: Violation of residential provisions of this order with actual knowledge of its terms is
punishable by contempt of court and may be a criminal offense under RCW 9A.40.060(2) or
9A.40.070(2). Violation of this order may subject a violator to arrest.
When mutual decision making is designated but cannot be achieved, the partiestshall make a good faith
effort to resolve the issue through the dispute resolution process.
If a parent fails to comply with a provision of this plan, the other parent's obligations under the plan are
not affected.
Dated:--------------
Judge/Commissioner
Presented by:
Approved for entry:
Signature of Party
DEBORAH DAHL, Petitioner
Signature of Party or Lawyer/WSBA No.

Print Name

WPF DR 01.0400 Mandatory (61'2008) -RCW 26.09.016, .181; .187; .194
\_
-.
l lUlm~~iHiHl\\l\
02-3-02768-6
RTS
39521400
11-14-12

County of Pierce
In re Maniage of
No. 02-3-02768~
Return of Service
(Notice of Intended Relocation
of Children)
(RTS)
DEBORAH J. DAHL
Petitioner( s ),
and
JAMES R. DAHL
Res ndent( s .
I Declare:
1.
. I am over the age of 18 years, and I am not a party to this action.
2.
I served (name) James R. Dahl with the following documents:

[X ]
[X ]
[J
[]
3.
Notice of Intended Relocation of Children.

Parenting Plan (Proposed)
Residential Schedule.
Other:
The date, time and place of service were:

Date:
Address:
11
'5tf-Q I a
/~
'1Yl'111~/
lut~
Time of service or time of mailing
""'
l.Jr
wA
j't~
a.m~
.
a.~%Jr.,
Return of Service (Not Intended Reloc) (RTS) - Page 1 of 2

WPF DRPSCU 07.0600 (612008)-RCW 26.09.440(1)(a)
4.
Service was made pursuant to RCW 26.09.440{l)(a):

[X]
{]
[]
5.
by delivery to the person named in paragraph 2.

by delivery to (name)
, a person of suitable
age and discretion residing at the usual abode of the person named in paragraph 2.
by mailing a copy to the person named in paragraph 2, by any form of mail requiring a
return receipt. (Tape return receipt below.)
Other:
J declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at Tacoma, Washington on (date)
\\ /
5 { ~D \ 'l_
~~
1(~\e0V\
~e.tSCAt
Print or Type Name

Fees:
Service
Mileage
Total
(Tape Return Receipt here, if service was by mail)
File the original Return of Service with the clerk. Provide a copy to the law enforcement agency where
protected person resides if the documents served include a restraining order signed by the court.
Return of Service (Not Intended Reloc) (RTS) - -Page 2 of 2

WPF DRPSCU 07.0600 (61'2008) - RCW 26.09.440(1)(a)
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
Petitioner(s),
vs.
NO. 02-3-02768-6
JAMES R DAHL
Respondent(s)
AND TO: P. CRAIG BEETHAM, attorney for Petitioner, SCOTT ALEXANDER CANDOO,
attorney for Respondent, DEBORAH J DAHL, AMANDA DAHL, SARAH J DAHL,
ELIZABETH R DAHL
PLEASE TAKE NOTICE that SANDRA E. JOHNSTON, appears herein on behalf of the
Respondent(s) JAMES R DAHL and requests that all further pleadings and paper, except original
process, be served upon said attorney at the address listed below.
ntaprsup-0001.pdf
/s/ SANDRA E. JOHNSTON

SANDRA E. JOHNSTON, #27313
SANDRA E. JOHNSTON
818 S YAKIMA STE 201
TACOMA, WA 98405
(253) 272-0566
E-FILED
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
4
5

6
7
DEBORAH J. DAHL,
9
10
Petitioner,
and
NOTICE OF ABSENCE &

UNAVAILABILITY
JAMES R. DAHL,
Respondent.
11
12
NO. 02-3-02768-6
To:
And To:
13
Clerk of the Court

Deborah J. Dahl
You and each of you will please take notice that Attorney Sandra E. Johnston will be
14
unavailable during the following dates and requests that during this time no pleadings or notices be
15
served either upon her or appearances be scheduled, which requires her or the client's attention
16
either in person, by pleading. Because Ms. Johnston is a sole practitioner, she also requests that no
action requiring her attention be initially noted or calendared for 2 days immediately following
17
her absence to allow adequate preparation and time to contact her client/s.
18
1.
19
20
2.
December 10, 2012 to December 14, 2012

December 21, 2012 to January 3, 2013
Out of County Trial

Christmas I New Year's Holiday
Ms. Johnston cannot supervise or introduce another attorney to the facts involved in this case,
during her absence. Terms and sanctions will be requested should any matter requiring her attention
21
or attendance be scheduled as noted above in order for the client/s to obtain the services of substitute
22
counsel to review the file, appear, file pleadings, and resist such matters as necessary, including the
23
request for a motion to continue.
24
Dated this 5th day of December, 2012.
25
NOTICE OF ABSENCE &

UNAVAILABILITY
Page 1 of 1
818 S. Yakima, Suite 201

Phone
253-272-0566;
FAX
253-272-4172
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7
SuperiorCourt of Washington
County of PIERCE
9
10

No. 02-3-02768-6
DEBORAH J. DAHL
11
12
13
Petitioner,
and
JAMES R. DAHL
Respondent.
14
Objection to Relocation/
Petitionfor Modificationof
CustodyDecree/Parenting
Plan/ResidentialSchedule
(OBPT)
Para. 3.10: checkbox if petitionis
attached for:
15
16
I. Identificationof Parties
17
1.1
ObjectingParty
18
Name (first/last) of objecting party: James R. Dahl.
19
1.2
Relocating Party
20
Name (first/last) of relocating party: Deborah J. Dahl.
21
1.3
Other Persons With Court-Ordered Time With the Children
22
List other persons with court-ordered time with the child.

23
1.4
Dependent Children
24
25
Name (first/last) Elizabeth Rose Dahl
Age 15
Obj/Relocation/Pt for Modification (OBPT) - Page 1 of 7

WPF DRPSCU 07.0700 Mandatory (6/2008) - RCW 26.09.260(6), .480
The Law Office of Sandra E. Johnston

818 S. Yakima Avenue, Suite 201
Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
II.
(Check all that apply)
3
4
Objection to Relocation or Proposed Revised Residential Schedule
2.1
I, James R. Dahl, object to the intended relocation described in Deborah J. Dahl's Notice
of Intended Relocation of Children dated 10/25/12.
2.2
I, James R. Dahl, object to the proposed revised parenting plan/residential schedule

attached to Deborah J. Dahl's Notice of Intended Relocation of Children dated 10/25/12.
5
6
A true and correct copy of the Notice of Intended Relocation of Children, with Petitioner's
proposed new parenting plan/residential schedule is not attached because it has already
been filed by the petitioner herein. My proposed parenting plan is filed herewith.
7
8
9
10
Ill.
3.1
Basis
Petition for an Order Modifying Custody Decree/Parenting Plan/Residential

Schedule Pursuant to Relocation
11
This is a petition for modification of custody decree/parenting plan/residential schedule

pursuant to relocation. The objecting party asks the court to enter an order:
12
13
Approving the parenting plan/residential schedule filed with this petition. (Use the
Washington State mandatory pattern form.)
14
Other:
15
I don't object to a temporary relocation of the child to North Carolina. I ask that the
child be allowed to temporarily relocate for the upcoming semester/quarter, with a review
to occur upon her completion of the upcoming semester/quarter.
16
17
I do object to the proposed parenting plan which gives me very little time with my
daughter. Additionally, my daughter has two older sisters who are close in age to her
(but both adults) and who are not relocating to North Carolina. The parenting plan should
allow our daughter significant time in Washington State to maintain her bond with her
sisters, her life long friends, and me.
18
19
20
21
3.2
The relocation of the child is being pursued. There is no need for adequate cause for
hearing this petition for modification.
22
23
24
Adequate Cause
3.3
Child Support
Does not apply.
25

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
3.4
Jurisdictiohand Venue
2
The court has proper jurisdiction and venue.
3
The objecting party resides in King.
4
The child reside(s) in Pierce.
5
The relocating party resides in Pierce.
6
The current custody decree/parenting plan/residential schedule was entered in Pierce
County, WA. A certified copy of the current custody decree/parenting plan/residential
schedule is filed with or attached to this petition, if the decree or plan to be modified was
entered in another county or state.
7
8
9
3.5
Jurisdicti
on Over Proceeding
10
This court has jurisdiction over this proceeding for the reasons below.
11
This court has exclusive continuing jurisdiction. The court has previously made a child
custody, parenting plan, residential schedule or visitation determination in this matter
and retains jurisdiction under RCW 26.27.211.
12
13
This state is the home state of the child because the child lived in Washington with a
parent or a person acting as a parent for at least six consecutive months immediately
preceding the commencement of this proceeding.
14
15
Washington was the home state of the child within six months before the
commencement of this proceeding and the child is are absent from the state but
a parent or person acting as a parent continued to live in this state.
16
17
The child and the parents or the child and at least one parent or person acting as a
parent, have significant connection with the state other than mere physical presence,
and substantial evidence is available in this state concerning the child's care, protection,
training and personal relationships, and the child has no home state elsewhere.
18
19
No other state has jurisdiction.
20
3.6
Uniform Child Custody Jurisdictionand Enforcement Act Information
21
22
During the last five years, the child has lived in no place other than the State of
Washington and with no person other than the objecting party or another party.
to custody or visitation:
Claims
23
24
The objecting party does not know of any person other than the relocating party who has
physical custody of, or claims to have custody or visitation rights to, the child.
25
Involvement in any other proceeding concerning the child:


Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
1
2
The objecting party has not been involved in any other proceeding regarding the child.
Other legal proceedings concerning the child.
The objecting party does not know of any other legal proceedings concerning the child.
3.7
Reasons for Objecting to the Relocation
Based upon the following factors, the detrimental effects of allowing the children to move
with the relocating person outweigh the benefits of the move to the child and the
relocating person:
3.7.1
The relative strength, nature, quality, extent of involvement, and stability of the
child's relationship with each parent sibling and other significant persons in the
child's life.
Does apply. Explain:
10
Although I will not object to the relocation, the proposed parenting plan does not
afford the child enough time in the State of Washington to maintain her bond with
her young adult siblings, her long term friends (as she is 15), and me, her father.
11
12
13
3. 7.2
Prior agreements of the parties.

Does not apply.
14
15
16
3.7.3
Disrupting contact between the child and the objecting party or parent is more
detrimental to the child than disrupting contact between the child and the person
with whom the child resides a majority of the time.
Does apply.
17
18
19
For the same reasons listed above under 3. 7.1.

3.7.4a The objecting party or parent is not subject to limitations under RCW 26.09.191.
Does apply.
20
21
Explain:
Explain:
I disput any claims made by Petitioner regardings allegations under RCW

26.09.191
22
23
3. 7.4b The following parents or persons entitled to residential time with the child are
subject to limitations under RCW 26.09.191.
Does apply.
24
Explain:
25

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
I disput any claims made by Petitioner regardings allegations under RCW

26.09.191.
3.7.5
The reasons and good faith of each person seeking the relocation.
Does apply.
Although I believe that the Petitioner is making the move in good faith, I do not
agree that the proposed parenting plan and/or her allegations were made in good
faith.
5
6
Explain:
3.7.6
The age, developmental stage, and needs of the child, and the likely impact the
relocation or its prevention will have on the child's physical, educational, and
emotional development, taking into consideration any special needs of the child.
Does apply.
10
See above paragraph 3. 7 .1.
11
3. 7. 7
Explain:
The quality of life, resources, and opportunities available to the child and to the
relocating party in the current and proposed geographic locations.
12
Does apply. Explain:

13
See above paragraph 3.7.1.

14
3.7.8
15
The availability of alternative arrangements to foster and continue the child's

relationship with and access to the other parent.
16
Does apply.
17
See above paragraph 3. 7 .1
18
3.7.9
Explain:
Alternatives to relocation and whether it is feasible and desirable for the other
party to relocate.
19
Does apply.
Explain:
20
21
I am nearing retirement age. It is not possible for me to relocate to North

Carolina and there is little or no likelihood at my age of being able to find a
commensure job and salary should I leave my job USF Reddaway.
22
3. 7 .10 The financial impact and logistics of relocation or its prevention.
23
Does apply.
Explain:
24
See above paragraph 3.7.9.
25

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
3.8
2
Reasons for Objecting to the Relocating Party's Proposed Parenting

Plan/Residential Schedule
I object to the relocating party's proposed parenting plan/residential schedule because:
Our daughter is equally bonded to her parents; however, she has expressed an interest
in going with her mother to North Carolina. Because my daughter is a mature 15 year
old, I will not object to her wishes to relocate with her mother. I ask that sufficient time
be given to me in order to preserve her bond with her siblings, her lifelong friends in
Washington State, and me. My child has never been to North Carolina. Because of
that I ask the Court to consider a denial of her relocation in the event that my daughter
wishes to come home.
6
7
8
3.9
Modification or Adjustment to the Residential Provisions of the Parenting

Plan or Residential Schedule
9
The objecting party requests an adjustment of the residential provisions of the relocating
party's proposed parenting plan. The adjustment does not include a change in the
residence in which the child resides the majority of the time.
10
11
The objecting party may request a modification of the relocating party's proposed
parenting plan/residential schedule, including a change in the residence in which the
child resides the majority of the time, should the child decide that she does not like living
in North Carolina after having spent the next
12
13
14
3.10
Protection Order
15
Does not apply.
16
If you need immediate protection, contact the clerk/court for RCW 26.50 Domestic
Violence forms or RCW 10.14 Antiharassment forms.
17
18
19
3.11
Other
N/A
IV.
20
21
22
23
24
25
Relief Requested
The objecting party requests that the court:

Restrain the permanent relocation, but allow the temporary relocation of the child to North
Carolina until further Court review, so that the 15 year old child can have an opportunity to see
what it will be like to live in North Carolina, away from her father, her two older siblings and her
friends.
Approve the proposed parenting plan/residential schedule which is filed with this
Objection/Petition.

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
1
Other:
2
Keep jurisdiction of this matter with Pierce County Superior Court for all future
modifications and/or hearings with this child.
3
4
5
Dated:
---=-{_J
.
d--~J;~~
=-
$"------'--'.
\
27313
~andra E. Johnst9n
Lawyer/WSBA
\)ltorney for Fathe,, Respondent & Objecting Party
No.
I declare under penalty of perjury under the laws of the State of Washington that the foregoing is
true and correct.
9
Signed at
j&!J~
-s-.a.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
1
2
3
4
5
6
7
County PIERCE
8
9
10
No.
DEBORAH J. DAHL
Parenting Plan
Proposed (PPP)
11
12
13
02-3-02768-6
Petitioner,
and
JAMES R. DAHL
Respondent.
14
15
This parenting plan is proposed by James R. Dahl.
16
17
18
19
I.
General Information
This parenting plan applies to the following child:
20
Name
Age
21
Elizabeth Rose Dahl
15
22
II.
Basis for Restrictions
23
24
Under certain circumstances, as outlined below, the court may limit or prohibit a parent's contact
with the child and the right to make decisions for the child.
Parenting Plan (PPP, PPT, PP) Page 1 of 8
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.181;
.187; .194

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
2.1
Parental Conduct(RCW 26.09.191 ( 1 ), (2))
2
Does not apply.
3
2.2
Other Factors (RCW 26.09.191(3))
4
Does not apply.
5

6
occasions, and what contact the child shall have with each parent. Parents are encouraged to
needs of their family. Paragraphs 3.1through3.9 are one way to write your residential
schedule. If you do not use these paragraphs, write in your own schedule in Paragraph 3. 13.
10
3.1
7
8
11
12
3.2
13
3.3
17
A. Winter Break shall be divided evenly. The first half of Winter Break shall begin on
the day school lets out until the first Saturday following Christmas Day. The second half
shall begin from the first Saturday following Christmas Day until the day before school is
to resume.
18
19
B. The parents shall alternate with Father having the first half of Christmas break in
Odd years and the second half in Even years. Mother shall have the first half in Even
years and the second in Odd years.
20
21
23
24
Schedule for WinterVacation

The child shall reside with the petitioner during winter vacation, except for the following
days and times when the child will reside with or be with the other parent:
16
22
School Schedule
Upon enrollment in school, the child shall reside with the petitioner, except for the
following days and times when the child will reside with or be with the other parent:
14
15
3.4

The child shall reside with the petitioner during other school breaks, except for the
A. Father shall have the entirety of Spring break every year.
the day school lets out until the day before school resumes.

.187; .194
Spring break shall begin

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
B. All other school breaks, not otherwise addressed herein, shall be taken by the
person scheduled to have the child.
2
3
3.5
Summer Schedule
Upon completion of the school year, the child shall reside with the petitioner, except for
4
5
A.
Father shall have the entirety of June and July every Summer.
6
B. Summer shall begin on the Sunday immediately after school lets out in June and last
until the last Sunday in July every year.
3.6
The schedule for vacation with Father is as follows:
10
A.
If Father is able to get additional vacation time (other than the visitation listed
elsewhere herein), he may have additional visitation time with his daughter in North
Carolina for that which he is able to take.
B.
Father may have visitation with his child in North Carolina an additional four
times per year, not otherwise outlined herein.
C.
Father's North Carolina visitation time shall not interfere with the child's
schooling, although she may remain in his care while attending school for the
duration of his visit. If she is in his care during school, Father shall ensure that her
homework and other school obligations are completed timely.
11
12
13
14
15
16
17
3.7

18
19
20
21
22
23
24
New Year's Day

Presidents' Day
Memorial Day
July 4th
Labor Day
Veterans' Day
Thanksgiving Day
Christmas Eve
Christmas Day
With Petitioner
(Specify Year
Odd/Even/Every)
With Respondent
(Specify Year
Odd/Even/Every)
See 3.3 above

See B below
See B below
See B below
See 3.3 above

See B below
See B below
See B below
Every
See B below
See B below
Every
See 3.3 above
See 3.3 above
See B below
See B below
See 3.3 above
See 3.3 above

WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.181; .187; .194

Tacoma, WA 98405
Phone 253-272c0566 Fax 253-572-4137
1
A.
2
B.
3
4
3.8
MLK, President's Day, Memorial Day, Labor Day and Veteran's Day shall be
taken by the parent scheduled to have the child.
Schedule for Special Occasions

The residential schedule for the child for the following special occasions (for example,
birthdays) is as follows:
With Petitioner
With Respondent
(Specify Year
(Specify Year
Odd/Even/Every)
Odd/Even/Every)
5
6
7
Mother's Day
Father's Day
Birthdays
10
A.
Every
See B & C below
Every
See B & C below
Father shall have every Father's Day weekend for so long as it falls during his
summer break visitation or, if it falls during school, he may elect to take it in North
Carolina, if possible.
11
12
B. The child's birthday shall be celebrated by the parent regularly scheduled to have
the second half of Winter Break (see paragraph 3.3 above).
13
C.
All other birthdays shall be celebrated during regularly scheduled visitation.
14
3.9
Priorities Under the Residential Schedule
15
Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1 and 3.2, in the following order:
16
17
1 winter vacation (3.3)
2 school breaks (3.4)
4 vacation with parents (3.6)
5 holidays (3. 7)
6 special occasions (3.8)
18
19
20
21
3.10
22
23
24
Restrictions
3.11
TransportationArrangements
Transportation costs are included in the Child Support Worksheets and/or the Order of
Child Support and should not be included here.

.187; .194

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
Transportation arrangements for the child between parents shall be as follows:

2
Father shall pay for and obtain all flights for the child. Mother shall be 100% liable to
pay for the cost thereof, which shall be calculated in the order of child support as $3,000
of annual travel allotment. Additional travel expense (to North Carolina by father) shall
be born solely by him.
3
4
3.12
The child named in this parenting plan is scheduled to reside the majority of the time
with the petitioner. This parent is designated the custodian of the child solely for
purposes of all other state and federal statutes which require a designation or
determination of custody. This designation shall not affect either parent's rights and
6
7
8
3.13
Other
N/A
10
11
3.14
12
13
If the person with whom the child resides a majority of the time plans to move, that
person shall give notice to every person entitled to court ordered time with the child.
14
15
16
17
personal service or by mail requiring a return receipt. This notice must be at least 60
days before the intended move. If the relocating person could not have known about
the move in time to give 60 days' notice, that person must give notice within 5 days after
learning of the move. The notice must contain the information required in RCW
26.09.440. See also form DRPSCU 07.0500, (Notice of Intended Relocation of A
Child).
18
19
If the move is within the same school district, the relocating person must provide actual
notice by any reasonable means. A person entitled to time with the child may not object
to the move but may ask for modification under RCW 26.09.260.
20
21
Notice may be delayed for 21 days if the relocating person is entering a domestic
violence shelter or is moving to avoid a clear, immediate and unreasonable risk to health
and safety.
22
23
24
If information is protected under a court order or the address confidentiality program, it

may be withheld from the notice.
A relocating person may ask the court to waive any notice requirements that may put the
health and safety of a person or a child at risk.

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
1
2
If no objection is filed within 30 days after service of the notice of intended
relocation, the relocation will be permitted and the proposed revised residential
4
A person entitled to time with a child under a court order can file an objection to the
child's relocation whether or not he or she received proper notice.
An objection may be filed by using the mandatory pattern form WPF DRPSCU 07.0700,
(Objection to Relocation/Petition for Modification of Custody Decree/Parenting
Plan/Residential Schedule). The objection must be served on all persons entitled to time
with the child.
6
7
8
The relocating person shall not move the child during the time for objection unless: (a)
the delayed notice provisions apply; or (b) a court order allows the move.
If the objecting person schedules a hearing for a date within 15 days of timely service of
the objection, the relocating person shall not move the child before the hearing unless
there is a clear, immediate and unreasonable risk to the health or safety of a person or a
child.
10
11
12
IV.
Decision Making
13
4.1
14
Each parent shall make decisions regarding the day-to-day care and control of each
child while the child is residing with that parent. Regardless of the allocation of decision
making in this parenting plan, either parent may make emergency decisions affecting the
health or safety of the child.
15
16
17
4.2
Major Decisions
18
19
petitioner
Non-emergency health care: petitioner
petitioner
20
21
22
23
4.3
Restrictions in Decision Making

Sole decision making shall be ordered to the petitioner for the following reasons:
24
(a)
The existence of a limitation under RCW 26.09.191;

WPF DR 01.0400 Mandatory (6/2008)- RCW 26.09.181; .187; .194

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
1
2
(b)
The history of participation of each parent in decision making in

each of the areas in RCW 26.09.184(4)(a);
(c)
Whether the parents have demonstrated ability and desire to

cooperate with one another in decision making in each of the
areas in RCW 26.09.184(4)(a); and
(d)
The parents' geographic proximity to one another, to the extent

that it affects their ability to make timely mutual decisions.
3
4
5
6
V.
7
8
9
Dispute Resolution
the provisions of this plan must, be used before filing a petition to modify the plan or a motion for
10
11
12
13
Disputes between the parties, other than child support disputes, shall be submitted to
(list person or agency):
mediation by Pierce County Center for Dispute Resolution, if this box is checked
and issues of domestic violence or child abuse are present, then the court finds that the
victim requested mediation, that mediation is appropriate and that the victim is permitted
to have a supporting person present during the mediation proceedings, or
14
The cost of this process shall be allocated between the parties as follows:
15
50% petitioner 50% respondent.

16
17
18
written request. other:
Notice may be given by email. Both parties shall keep the other apprised of his/her
email address.
19
20
(a)
(b)
Unless an emergency exists, the parents shall use the designated process to
resolve disputes relating to implementation of the plan, except those related to
financial support.
(c)
A written record shall be prepared of any agreement reached in counseling or

mediation and of each arbitration award and shall be provided to each party.
( d)
If the court finds that a parent has used or frustrated the dispute resolution
21
22
23
24


Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
1
process without good reason, the court shall award attorneys' fees and financial
sanctions to the other parent.
2
3
(e)
The parties have the right of review from the dispute resolution process to the
superior court.
VI. Other Provisions

5
There are no other provisions.
VII.
Declaration for Proposed Parenting Plan
7
8
(Only sign if this is a proposed parenting plan.) I declare under penalty of perjury under
the laws of the State of Washington that this plan has been proposed in good faith and
that the st
in Part II of this Plan are true and correct.
12--tJf-lb
10
-{acoma /Jv't!,
11
12
13

It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and
approved as an order of this court.
14
15
WARNING:
Violation of residential provisions of this order with actual knowledge of its terms is
9A.40.070(2).
Violation of this order may subject a violator to arrest.
16
17
18
When mutual decision making is designated but cannot be achieved, the parties shall make a
good faith effort to resolve the issue through the dispute resolution process.
If a parent fails to comply with a provision of this plan, the other parent's obligations under the
plan are not affected.
19
20
21
Judge/Commissioner
22
Approved for entry:
23
24
E-FILED
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5

DEBORAH J. DAHL,
NO. 02-3-02768-6
Petitioner,
DECLARATION OF JAMES R. DAHL
and
10
JAMES R. DAHL,
11
Respondent
12
I, James R. Dahl, do declare as follows:

13
I am competent to testify regarding the contents herein and make this declaration on
14
personal knowledge.
15
16
Relocation
I do not object to Petitioner's request to move to North Carolina on a temporary basis.
17
At the time of the move my daughter will be 16 years old. She has two older sisters who are not
18
19
20
moving and who live close to me. She will want to spend as much time as possible in
Washington as possible, not only to maintain her bond with me, but also to visit with them and
21
her life-long friends who still live here.
22
Travel
23
My daughter will be 16 at the time of her temporary relocation. She already is a highly
24
capable, independent young woman. She will be able to travel and/or fly without an escort.
25
She currently has her driver's learner's permit and I am teaching her how to drive.
Page 1 of3
The Law Office of SANDRA E. JOHNSTON

Phone
253-272-0566;
FAX
253-272-4172
Bonding
I am very close to my children. I am not a confrontational man. That has resulted in my
2
3
giving into their mother's demands on all things involving our girls and has sometimes resulted
in me getting less visitation than that to which I am entitled. I avoided confrontation not
because I wanted less time with my girls, but because I wanted fewer arguments and less stress
for them.
ParentingPlan
8
9
10
The parenting plan I propose is a standard plan for a parent left behind. The only other
concern I have is that Elizabeth has not been to North Carolina before. Both of her siblings are
staying here. Because of her age and maturity, I seek flexibility on placement so that if she is
11
unhappy in North Carolina she can return home to Washington.

12
The visitation schedule proposed by Petitioner would give our daughter very little time
13
in Washington and I definitely object to it. I ask the Court to give me as much time as
14
reasonable possible. I would like to have visitation in Washington at least four times a year,
15
16
which would include the following:
17
1.
18
2. every summer, all of June and July, beginning the first Sunday after school lets out until
19
20
21
22
23
every Spring Break;
the last Sunday in July;

3. every Thanksgiving, flying out the day school lets out and returning the day before
school resumes; and
4. one half of Christmas Break every year, with the first half beginning the day school lets
out until the Saturday following Christmas and the second half from the first Sunday
24
following Christmas until the day before school resumes.

25
DECLARATION
Page 2 of3
OF JAMES R. DAHL

Phone 253-272-0566; FAX 253-272-4172
2
3
I also ask that I be allowed up to monthly visitation in North Carolina, with having given
14 days of notice to the Petitioner prior to the visit. I have no objection to ensuring that my
North Carolina visits do not interfere with my daughter's schooling.
My ex-wife is and has been a good mother to our girls. Unfortunately our relationship
5
following our divorce has not been as cordial as I had hoped. I have often caved into her
6
demands regarding the timing of visitation just to keep the peace. It now appears that she is
7
attempting to use my accommodations as a weapon against me. I ask the Court not to allow that
8
9
10
to happen.
I work nights as a commercial truck driver; however, our oldest daughters have both
11
volunteered to stay overnight and help whenever needed.
12
Drinking
13
It is not fair to label me with a drinking problem. There have never been any findings of
14
her allegations in this action. It is true that I drank a lot during our marriage. It is also true that
15
three years ago, in 2009, I was charged with a DUI. I have not had any problems in the last
16
three years and my drinking has slowed way down. I successfully completed an alcohol
17
program and all Court conditions. My DUI will be reduced to a Neg. I in March of 2014.
18
19
I declare under penalty of perjury under the laws of the State of Washington that the
foregoing is true and correct to the best of my knowledge.
20
Signed and sworn in Tacoma, Washington on this
21
22
23
24
25

Page 3 of3

Phone
253-272-0566;
FAX
253-272-4172
E-FILED
February 04 2013 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
SUPERIOR COURT OF THE STATE OF WASHINGTON
FOR PIERCE COUNTY
7
8
9
10
DEBORAH J. DAHL,
Petitioner,
11
and
12
JAMES R. DAHL, Respondent.
13
Defendants.
)
)
)
)
)
)
)
)
)
)
NO. 02-3-02768-6
14
15
TO:
Sandra E. Johnston, Counsel for Respondent
16
17
18
YOU AND EACH OF YOU will please take notice and are hereby notified that Deborah J.
Dahl hereby enters her appearance in the above cause by and through her legal counsel, Eric V. Berg,
19
Attorney at Law, without waiving any applicable defenses or objections to any issue in the above-
20
referenced cause, and further requests that all further notices, pleadings and papers herein be served
21
upon said attorney ~t the ~ddress below stiled, except original process. ~
22
DATED this ~
day of February 2013.
----~=-~-"
-----'----=--
Eric V. Berg, WSBA #28011

Attorney for Deborah Dahl
P.O. Box 949, Olalla, WA 98359
(253) 851-9619
23
24
25
26
Eric V. Berg
Attorney at Law, WSBA #28011
P. 0. Box 949, Ola/fa, WA 98359
(253) 851-9619
Email: [email protected]
CERTIFICATION OF SERVICE
2
3
The undersigned certifies that he is over the age of 18 years and not a party to this
action. A true and correct cor,y of the foregoing document was SjiVed on all parties' attorneys
of record by United States 1 s Class Mail on or before February_.,..._.2013.
,
4
5
6
forego::~~:;,c::~t.
~~
Eric V. Berg
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Eric V. Berg
Attomey at Law, WSBA #28011
P. 0. Box 949, Ola/la, WA 98359
(253) 851-9619
Email: [email protected]
E-FILED
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7
County of PIERCE
In re:
10
DEBORAH J. DAHL
No. 02-3-02768-6
Return of Service
(Optional Use)
(RTS)
11
Petitioner,
12
and
13
JAMES
R. DAHL
Respondent.
14
15
I Declare:
16
1.
I am over the age of 18 years, and I am not a party to this action.
17
2.
I served the following documents to Deborah Dahl.
18
other:
1.
2.
3.
4.
5.
19
20
Notice of Appearance;
Notice of Absence & Unavailability;
Relocation: Order Assigning Case to Family Court & Notice of Hearing;
Objection to Relocation w/Proposed Parenting Plan; and
Declaration of James R. Dahl.
21
22
3.
The date, time and place of service were (if by mail refer to Paragraph 4 below):
23
Date.
24
Address:
. .~s 1
12/05/12 Time.
a . ~
916 Manor Drive

Fircrest, WA 98466
25
Return of servtce (RTS) - Page 1 of 2
WPF DRPSCU 01.0250 (6/2010) - CR 4(g), RCW 4.28.080(15)

Tacoma, WA 8405
Phone 253-272-0566 Fax 253-572-4137
4.
Service was made:
2
by delivery to the person named in paragraph 2 above.
3
4
5.
Service of Notice on Dependent of a Person in Military Service.
6.
Other:
5
6
N/A
7
8
I declare under penalty of perjury under the laws of the state of Washington that the foregoing
)-J--S- =! L
Signed at
10
q JC ,/1q,o1.-
1)"";'/t.c.
on
Grc;.cs-1'
12
cG
13
Fees:
14
15
Service
Mileage
Total
16
(Tape Return Receipt here, if service was by mail.)
17
File the original Return of Service with the clerk. Provide a copy to the law enforcement agency
where protected person resides if the documents served include a restraining order signed by
the court.
11
18
Signature
19
20
21
22
23
24
25
Return of Service (RTS) - Page 2 of 2
WPF DRPSCU 01.0250 (6/2010) - CR 4(g), RCW 4.28.080(15)

Tacoma, WA 8405
Phone 253-272-0566 Fax 253-572-4137
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
Petitioner(s),
vs.
NO. 02-3-02768-6
JAMES R DAHL
Respondent(s)
AND TO: SCOTT ALEXANDER CANDOO, attorney for Respondent, SANDRA E.
JOHNSTON, attorney for Respondent
NOTICE IS HERBY GIVEN that P. CRAIG BEETHAM intends to withdraw as attorney
for Petitioner/Plaintiff(s) DEBORAH J DAHL, in the above-entitled action on December 11,
2012. This notice is given pursuant to Civil Rule 71(c) of the Rules for Superior Court.
prior to the date set forth above.
PAGE 1 OF 2
ntiwdsup-0002.pdf

Wells Fargo Plaza
TACOMA, WA 98402-4395
(253) 572-4500
02-3-02768-6
The last known name and address of the parties I have been representing are listed below:
DEBORAH J DAHL
916 MANOR DRIVE
FIRCREST, WA 98466
true and correct: That on December 11, 2012, I mailed a copy of this document to the attorney(s)
of record and/or parties at their respective addresses of record.
PAGE 2 OF 2
ntiwdsup-0002.pdf
/s/ P. CRAIG BEETHAM

P. CRAIG BEETHAM, #20139
Attorney for Petitioner/Plaintiff(s)

Wells Fargo Plaza
TACOMA, WA 98402-4395
(253) 572-4500
OF THE STATE OF WASHINGTON

t PIERCE COUNTY
02-3-02768-6
39692935
ORACS
Ft~
IN OPDEP;.
12-17-1 ~
No_ 02-3-02768DEBORAH J DAHL
0RDER AMEND
CASE SCHEDUL
Petitioner(s)
vs.
Type of Case:
Estimated Trial (days}:
Track Assignment:
Assigned Department:
JAMES R DAHL
Respondent(s}
EN couRr
DEC
4 2.1111
...
'
DIC
1
Relocation
ORLA - Judge FAMILY co
Docket Code: ORACS
--------------~------------Relocation Trial
04/02/13 9:00
otherwiseinstructed,ALL Attorneys/Parties
shall reportto the trial courtat 9:00 AM
1Unless
on the date of trial.
If the case has been filed, the plaintiff shall serve a copy of the Case Schedule on the defendant(s} with the summons and
within five (5) court days of service of the defendant's first response/appearance.
If the case has not been filed, but an

All attorneys and parties shall make themselves familiar with the Pierce County Local Rules, particularly those relating to
DATED: 12/17/12
Judge Family Court - 2

Department ORLA (253) 798-3654
21573
12/!8/2~!2
1&~~&2

No. 02-3-02768-6
DEBORAH J DAHL
ORDER AMENDING
CASE SCHEDULE
Petitioner(s)
vs.
JAMES R DAHL
Type of Case: DIC

Estimated Trial (days): 1
Track Assignment: Relocation
Assigned Department: ORLA. Judge FAMILy COURT.
Respondent(s)
CC:
Docket Code: ORACS
DEBORAH J DAHL, PRO SE (Self-Represented)

SANDRA E. JOHNSTON, Atty
SCOTT ALEXANDER CANDOO, Atty
Page 2 of 2
r:
' '2,1953'
1 m-norn1 ~ 1~-1
02-3-02768-6
39905789
ASTFAM1
',1,...'Z!VZ-8'13
0000$
01-28-13

DEBORAH J DAHL
No. 02-3-02768-6
Petmonert s)
JAMES RDAHL
Request for Reassignment

[
] For Trial
[
] Issuance of Case Schedule
Respondent(s}
vs.
] For Motion Only
Pf\'m..\
Defendant/Respondent's Attorney
SANDRA E JOHNSTON
SCOTI ALEXANDER CANDOO
PARTA
For due cause ( Judicial Assignment Rotation I Other ~

Juvenile Family
Court I Referred Family Court ), the above entitled action is referred to Administration
from Dept.~_
'Ofor reassignment.
~
lq.
&~~~
~~
_,]:~-- G::.j
Date.January24,2013
PARTS
r-:p..'(V\ \ ,
( ) The above entitled action is r~assignedfor hearing to Dept. No.

Judge
'Z' ~ ~
this 2..'1..
day of
at
l w
~.m.
All parties are to report
directly and immediately to the above numbered department if reassignment is for
immediate trial.
CJ.~
, 20~,
( ) Case to remain in Dept. No

, Judge
for monitoring and
case managementpurposes but declared a Visiting Judge (VISI)case on
day
of
, 20__
by Presiding Judg~ --------A visiting Judge from another Washington State C unty will be assigned to preside over
this case.
lxreport pbl/d_C1V1l_reass1gnment_report
Pnnted January 24, 2013
(rev 10/02/09)
--
.... ": :-
02-3-02768-6
39905795
LTR 16
21958 1/29/2013 00~06}
_ ~~~~~--JPERIOR COURT
OF THE
STATE OF WASHINGTON
FOR PIERCE COUNTY
FAMILY COURT - 1
JUDGE ELIZABETH P MARTIN
Dea Fm1gan, Jud1c1al Assistant
Suzanne Tnmble, Court Reporter
(253) 798--6630
334 COUNTY-CITY BUILDING

930 TACOMA AVENUE SOUTH
TACOMA, WA 98402-2108
January 24, 2013

2115 N 30TH ST STE 201
TACOMA, WA 98403-3397
DEBORAH J DAHL
916 MANOR DRIVE
FIRCREST, WA 98466
SANDRA E. JOHNSTON
818 S YAKIMA STE 201
TACOMA, WA98045
RE:
DEBORAH J DAHL vs. JAMES R DAHL

Pierce County Cause No. 02-3-02768-6
Dear Counsel/Litigant
The above referenced case has been reassigned to The Honorable Elizabeth P Martin,
FAMILY COURT - 1. If you have any questions please call me at (253) 798-6630
Sincerely,
DEA FINIGAN
Dea Finigan
Judicial Assistant
cc:
Pierce County Clerk for filing
E-FILED
January 28 2013 3:18 PM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
Petitioner(s),
vs.
NO. 02-3-02768-6
JAMES R DAHL
Respondent(s)
AND TO: DEBORAH J DAHL, Pro Se, SANDRA E. JOHNSTON, attorney for Respondent
NOTICE IS HERBY GIVEN that SCOTT ALEXANDER CANDOO intends to withdraw as
attorney for Respondent(s) JAMES R DAHL, in the above-entitled action on February 09, 2013.
This notice is given pursuant to Civil Rule 71(c) of the Rules for Superior Court.
prior to the date set forth above.
PAGE 1 OF 2
ntiwdsup-0002.pdf

2115 N 30th St Ste 201
TACOMA, WA 98403-3397
(253) 272-7274
02-3-02768-6
The last known name and address of the parties I have been representing are listed below:
JAMES R DAHL
25812 120TH LANE SW
VASHON ISLAND, WA 98070
true and correct: That on January 28, 2013, I mailed a copy of this document to the attorney(s) of
record and/or parties at their respective addresses of record.
DATED: January 28, 2013
PAGE 2 OF 2
ntiwdsup-0002.pdf


2115 N 30th St Ste 201
TACOMA, WA 98403-3397
(253) 272-7274
E-FILED
March 11 2013 12:39 PM
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
4
5

6
7
DEBORAH J. DAHL,
9
10
13
NOTICE OF ABSENCE &

UNAVAILABILITY
Petitioner,
and
JAMES R. DAHL,
Respondent.
11
12
NO. 02-3-02768-6
To:
And To:
Clerk of the Court

Eric Berg, Attorney for Petitioner
14
15
16
action requiring her attention be initially noted or calendared for 2 days immediately following
17
18
her absence to allow adequate preparation and time to contact her client/s,
1.
2.
March 21, 2013 to March 25, 2013; and

May 20, 2013 to May 28, 2013.
19
20
21
22
23
Dated this 6th day of March, 2013.

24
25
NOTICE OF ABSENCE &
UNAVAILABILITY
Page 1 of 1

Phone
253-272-0566;
FAX
253-272-4172
E-FILED
March 29 2013 12:43 PM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

County of Pierce
DEBORAH J. DAHL,
No. 02-3-02768-6
Petitioner,
and
JAMES R. DAHL,
Respondent.
FIRST AMENDED
Parenting Plan
[X] Proposed (PPP)
[ ] Temporary (PPT)
[ ] Final Order (PP)
This parenting plan is:

[]
[X]
the final parenting plan signed by the court pursuant to an order signed by the court on
this date or dated
, which modifies a previous parenting
plan or custody decree.
proposed by Deborah J. Dahl, petitioner.

I. General Information
Elizabeth R. Dahl

WPF DR 01.0400 Mandatory (612008)RCW 26.09.016, .181; .187; .194
16
Eric V. Berg
P. 0. Box 949, Olalla, WA 98359
(253) 851-9619
II. Basis for Restrictions

Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contact with the child(ren) and the right to make decisions for the child(ren).
2.1
Parental Conduct (RCW 26.09.191(1 ), (2))

Does not apply.
2.2
Other Factors (RCW 26.09.191 (3))

[]
Does not apply.
[X]
The []petitioner's (X] respondent's involvement or conduct may have an adverse effect
on the child's best interests because of the existence of the factors which follow:
[X]
[]
[X]
A long-term impairment resulting from drug, alcohol, or other substance abuse

that interferes with the performance of parenting functions.
The absence or substantial impairment of emotional ties between the parent and
child.
Other: respondent's home may be non-compliant with building and fire codes.

The residential schedule must set forth where the child(ren) shall reside each day of the year,
occasions, and what contact the child(ren) shall have with each parent. Parents are encouraged
to create a residential schedule that meets the developmental needs of the child(ren) and
individual needs of their family. Paragraphs 3. 1 through 3. 9 are one way to write your
residential schedule. If you do not use these paragraphs, write in your own schedule in
Paragraph 3. 13.
3.1
Schedule for Child Under School Age

3.2
School Schedule
Upon enrollment in school, the child shall reside with the petitioner, except for the following
days and times when the child will reside with or be with the other parent: see following
provisions.

WPF DR 01. 0400 Mandatory (612008) -
RCW 26.09.016, .181; .187; .194
Eric V Berg
P. 0. Box 949, Olalla, WA 98359
(253) 851-9619
3.3
Schedule for Winter Vacation

The child shall reside with the petitioner during winter vacation, except for the following days
and times when the child will reside with or be with the other parent:
Winter vacation shall be split as follows: the first half begins the day after school is dismissed for
winter break and ends at 9:00 a.m. on December 26th; the second half begins at 9:00 a.m. on
December 26th and continues until 6:00 p.m. two days before school is scheduled to resume.
The father shall have visitation on the first half in even numbered years, the mother on odd
numbered years.
3.4

The child shall reside with the petitioner during other school breaks, except for the following
All of Spring Break, beginning 9:00 a.m. after the day school lets out and ending at 6:00
p.m. two days before school resumes.
3.5
Summer Schedule
Upon completion of the school year, the child shall reside with the petitioner, except for the
From July 31st to August 24th.
3.6

[]
[X]
Does not apply.

The schedule for vacation with parents is as follows:
In addition to visitation otherwise provided herein, respondent can have visitation in

North Carolina four times per year, upon 30 days' notice by email to petitioner, each
visitation not to exceed four days and not to disrupt the child's school schedule.
3.7

The residential schedule for the child(ren) for the holidays listed below is as follows:
With Petitioner
(Specify Year
Odd/Even/Every)
New Year's Day
With Respondent
(Specify Year
Odd/Even/Every)
See paragraph 3 .3

WPF DR 01. 0400 Mandatory (612008) RCW 26.09.016, .181; .187; .194
Eric V. Berg
Attorney at Law, WSBA #28on
P. 0. Box 949, Olalla, WA 98359
(253) 851-9619

Presidents' Day
Memorial Day
July 4th
Labor Day
Veterans' Day
Thanksgiving Day
Christmas Eve
Christmas Day
Every
Every
Every
Every
Every
Every
Odd
See paragraph 3 .3
See paragraph 3 .3
Even
[X]
For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times): 9:00 am to 8:00 pm on the day of the holiday.
[X]
[X]
Other:
Respondent may exercise visitation at his choosing in North Carolina on three of the
above holidays that are indicated "every" with petitioner, with at least 30 days notice to
petitioner, so long as the child's school attendance, athletic and extracurricular activities
are not disrupted and with making a good faith effort not to disrupt activities already
planned by petitioner.
The Thanksgiving visitation by respondent begins the day after school lets out and ends
so that she is to be at petitioner's residence by 5:00 pm the day before school resumes.
3.8

The residential schedule for the child for the following special occasions is as follows:
Mother's Day
Father's Day
Child's Birthday
[X]
3.9
With Petitioner
(Specify Year
Odd/Even/Every)
Every
With Respondent
(Specify Year
Odd/Even/Every)
Every
See paragraph 3 .3
Other: ifrespondent elects to have visitation on Father's Day it is to occur in North

Carolina.
PrioritiesUnder the ResidentialSchedule

(]
(X]
Does not apply because one parent has no visitation or restricted visitation.
Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1and3.2, in the following order:
[]

Eric V. Berg
P. 0. Box 949, Olalla, WA 98359
(253) 851-9619
3 holidays (3. 7)
4 special occasions (3.8)

[]
3.10
Other:
Restrictions
[]
[X]
The respondent's residential time with the child shall be limited because there are
limiting factors in paragraphs 2.1 and/or 2.2. The following restrictions shall apply when
the child spends time with this parent:
No consumption of alcohol at any time from 24 hours before visitation is to
begin until the visitation ends and the child has left the custody of respondent.
No overnight visitation without adult presence and supervision.
No overnight visitation at respondent's residence on Vashon Island until
certification that it is compliant with building and fire codes.
3.11
Transportation Arrangements
Transportation arrangements and costs for the child, between parents shall be as follows:
Respondent is to make arrangements for any travel necessary by the child and pay for
same. Petitioner shall reimburse respondent for certain of said expenses, within 30 days of
receiving proof of payment (but not before travel has actually commenced) as:
Spring Break
Summer
Winter Break
Thanksgiving Break
petitioner
petitioner
petitioner
petitioner
pays
pays
pays
pays
50%
50%
50%
50%
of child's
of child's
of child's
of child's
air
air
air
air
fare
fare
fare
fare
Petitioner's duty of reimbursement does not take effect until and unless respondent is
current in past and present child support obligations.
In the event child is unable to travel on the above holidays to Washington, then
respondent will have the option of visitation in North Carolina, with petitioner reimbursing to
respondent her same percentage of his air-fare as indicated above,
WPF OR 01.0400 Mandatory (612008)RCW 26.09.016, .181; .187; .194
Eric V Berg
Attorney at Law, WSBA #28on
P. 0. Box 949, Olalla, WA 98359
(253) 851-9619
Other than as provided above, respondent pays the costs of travel for visitation.
Regarding travel for which petitioner is obligated to reimburse any part, respondent is to
book travel at the lowest fares available, to be booked at least 30 days before the time of travel.
3.12
The child named in this parenting plan is scheduled to reside the majority of the time with the
petitioner. This parent is designated the custodian of the child solely for purposes of all other
state and federal statutes which require a designation or determination of custody. This
designation shall not affect either parent's rights and responsibilities under this parenting plan.
3.13
Other
The parties may, by mutual agreement in writing (which can include email by both parties)
reasonably vary from the time frames in this parenting plan.
3.14

If the person with whom the child resides a majority of the time plans to move, that person shall
give notice to every person entitled to court ordered time with the child.
personal service or by mail requiring a return receipt. This notice must be at least 60 days before
the intended move. If the relocating person could not have known about the move in time to give
60 days' notice, that person must give notice within 5 days after learning of the move. The
notice must contain the information required in RCW 26.09.440. See also form DRPSCU
07.0500, (Notice oflntended Relocation of A Child).
If the move is within the same school district, the relocating person must provide actual notice by
any reasonable means. A person entitled to time with the child may not object to the move but
may ask for modification under RCW 26.09.260.
Notice may be delayed for 21 days if the relocating person is entering a domestic violence shelter
or is moving to avoid a clear, immediate and unreasonable risk to health and safety.
If information is protected under a court order or the address confidentiality program, it may be
withheld from the notice.

A relocating person may ask the court to waive any notice requirements that may put the health
and safety of a person or a child at risk.
Eric V Berg
P. 0. Box 949, Olalla, WA 98359
(253) 851-9619
If no objection is filed within 30 days after service of the notice of intended relocation, the
relocation will be permitted and the proposed revised residential schedule may be
confirmed.
A person entitled to time with a child under a court order can file an objection to the child's
relocation whether or not he or she received proper notice.
An objection may be filed by using the mandatory pattern form WPF DRPSCU 07 .0700,
(Objection to Relocation/Petition for Modification of Custody Decree/Parenting Plan/Residential
Schedule). The objection must be served on al1 persons entitled to time with the child.
The relocating person shall not move the child during the time for objection unless: (a) the
delayed notice provisions apply; or (b) a court order allows the move.
If the objecting person schedules a hearing for a date within 15 days of timely service of the
objection, the relocating person shall not move the child before the hearing unless there is a
clear, immediate and unreasonable risk to the health or safety of a person or a child.
IV. Decision Making

4.1
Each parent shall make decisions regarding the day-to-day care and control of each child while
the child is residing with that parent. Regardless of the allocation of decision making in this
parenting plan, either parent may make emergency decisions affecting the health or safety of the
child.
4.2
Major Decisions
Education decisions
Non-emergency health care
Religious upbringing
4.3
[X]
[X]
[X]
[]
[]
petitioner
petitioner
petitioner
petitioner
petitioner
[]
[]
[]
[]
[]
respondent
respondent
respondent
respondent
respondent
[]
[]
[]
[]
[]
joint
joint
joint
joint
joint
Restrictions in Decision Making

[X ]
Sole decision making shall be ordered to the petitioner for the following reasons:
[ ]
A limitation on the other parent's decision making authority is mandated by
[X]
[ ]
RCW 26.09.191 (See paragraph 2.1).

Both parents are opposed to mutual decision making.
(a)

Eric V. Berg
Attorney at Law, WSBA#28011
P. 0. Box 949, Olalla, WA 98359
(253) 851-9619
[ ]

(a)
(b)
( c)
(d)
[]

The history of participation of each parent in decision making in each of
the areas in RCW 26.09.184(4)(a);
Whether the parents have demonstrated ability and desire to cooperate
with one another in decision making in each of the areas in
RCW 26.09.184(4)(a); and
The parents' geographic proximity to one another, to the extent that it
affects their ability to make timely mutual decisions.
There are limiting factors in paragraph 2.2, but there are no restrictions on mutual decision
making for the following reasons:
the provisions of this plan must be used before filing a petition to modify the plan or a motion
for contempt for failing to follow the plan.
[X]
Disputes between the parties, other than child support disputes, shall be submitted to (list person or
agency):
[X]
mediation by PCCDR, with video or remote meeting technology employed if available. If

this box is checked and issues of domestic violence or child abuse are present, then the
court finds that the victim requested mediation, that mediation is appropriate and that the
victim is permitted to have a supporting person present during the mediation proceedings;
[X]
Costs of said mediation are to be paid as follows: 50% petitioner; 50% respondent.
The dispute resolution process shall be commenced by notifying the other party by [ ] written
request [X] certified mail [ ] other:
(a)
(b)
(c)

Unless an emergency exists, the parents shall use the designated process to resolve disputes
relating to implementation of the plan, except those related to financial support.
A written record shall be prepared of any agreement reached in counseling or mediation
and of each arbitration award and shall be provided to each party.
Parenting Plan (PPP, PPT, PP) - Page 8 of 1 O

WPF DR 01. 0400 Mandatory (612008) RCW 26.09.016, .181;. 187; .194
Eric V. Berg
P. 0. Box 949, Olalla, WA 98359
(253) 851-9619
WFBH
3/27/2013 9:14:40 AM
(d)
(e)
PAGE
3/003
!fthe court finds that it parent has used or frustrated the dispute resolution process
without good reason, the court shall award attorneys' fees a.11<l financial sanctions tu the
other parent
The panics have the right of review from the dispute resolution process to the superior
court.
Vi. Other Provisions

[}
[X]
There are no other previsions.

Neither par~y shnH use the child to gather information regarding the other party or to convey
messsges/intormation to the other party.
The child shall not be involved in disputes. between the parties, if any. For example, neither
party shall share with the child any anger or dissatisfaction regard!n.g the other party,
VU. Declaration for Proposed Parenting Plan
[X]
(Only :sign if this is a proposed parenting plan.) I dt.<eb~re under penalty of'perjury under the laws.
of the state of Washington that this plan has been pmposc<l in good faith and that the statements
in Part
n ofthis
Plan are true and correct.
______ /tdt.tt1tt)1.., . . . (!Gar_~-:----..----------- ..--

Petitioner
Viii. Otder
by the Court
H fa; ordered, adjudged and decreed that the parenting plan set forth above is a.dopt",J and approved as an
order of this court.

Parenting Plan (PPP, PPT, PP} - Page s of
WPF OR 01.0400 Mandatory {612008}"'
r..u:V1/2609.o1s, tst: .18?; .194
'1(}
Eric v: Berg
Atwmey at Imv, WSBA #z/;1(Jll
P. 0. !k~x949, Ofoffo, W'A 98359
(i5Jl 8151-9619
Violation of residential provisions of this order with actual knowledge of its terms is
WARNING:
When mutual decision making is designated but cannot be achieved, the parties shall make a good faith
effort to resolve the issue through the dispute resolution process.
If a parent fails to comply with a provision of this plan, the other parent's obligations under the plan are
not affected.
Dated:
Judge/Commissioner
Presented by:
Eric V. Berg, SBA #28011


Approved for entry:

Sandra E. Johnston, WSBA #27313

Eric V Berg
P. 0. Box 949, Olalla, WA 98359
(253) 851-9619
2
3
4
5
6
8
9
10
)
)
) NO. 02-3-02768-6
)
) AFFIDAVIT OF FACSIMILE FILING
)
)
)
)
)
)
)
In Re Marriage of
DEBORAH J. DAHL,
Petitioner,
11
12
and
13
JAMES R. DAHL,
14
Respondent.
15
~~~~~~~~~~~~~~~)
16
The below signed declares on personal knowledge:
17
I am the person responsible for the
filing of the initials and signature page(s) which were faxed or electronically transmitted, on
18
the foregoing FIRST AMENDED PROPOSED PARENTING PLAN. I have determined that
19
the document consists of eleven pages (including affidavit page) and that it is complete and
20
legible.
21
22
foregoing is true and correct.
Signed at Olalla, Washington March!'
23
(?, fi/?
c;/t/
24
->>
Eric V. Berg, WSBA #28011

25
26
2013.
AFFIDAVIT OF FACSIMILE FJLING - Page
1 of 1
Eric V. Berg
P. 0. Box 949, Olallo, WA98359
(253) 851-9619 Fax: (253) 509-9999
22969
--
---
02-3-02768-6
40295921
\._
--
CME
4/4~2011
48B23
---
04-03-13
------
---

DEBORAH J DAHL,
Cause No. 02-3-02768-6
FILED
Petitioner(s)
DEPT. 2
IN OPEN COURT
SETTLEMENT CONFERENCE STATUS
vs.
] SETTLEMENT CONF HELD (STLCON)
ETTLEMENT CONF HELD-SETILED
STLCON)
] FAILED TO APPEAR PARTY(IES) (SCR)
] CANCELLED/STRICKEN (SCR)
JAMES R DAHL,
Respondent(s)
Settlement Conference Requested by ~
.;f 7~ - /JS-~"
Assigned to Judge/Commissioner KATHERINE STO!f

Ttns case rs set ror
rasu
Scheduled for hearing
m on
~/15
<t-// U.3
"l.,_
/uv~~
(date) at
-~e.
f/.'1-p ,~
CONTINUED to
//l~
(time).
(time)
OLZ
HOLD FORM UNTIL HEARING

HELD OR CANCELLED
Rev (3/04)
Judicial Assistant/Clerk
l.J.!.~ .m11 [
U,, -,,
1111
_______,,,
2
3
4
5
6
7
County PIERCE
8
9
No. 02-3-02768-6
DEBORAH J DAHL
Parenting Plan
Final (PPF)
10
11
\N 0 P C.\-
,...,
~?R - 11.0\'~
Petitioner,
12
f\LEO
?.
0~-:-r..,
~r:r.roUR
1
and
13
JAMES R. DAHL
Respondent.
14
,:, .-r~
15
16
This parenting plan is the final parenting plan signed by the Court pursuant to an order signed
by the Court on this date and filed herewith, which modifies a previous parenting plan or custody
decree.
17
18
I.
General Information
19
20
Name
Age
Elizabeth Rose Dahl
16
21
22
II.
23
24
Basis for Restrictions
Under certain circumstances, as outlined below, the court may limit or proh1b1t a parent's contact
with the child and the right to make decisions for the chlld.
Parenting Plan (PPP, PPT, PP) Page 1of10
Fam1lySoft FormPAK 2012
187; 194
OR\G\NAL

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
..
1
2
2.1
3
4
Parental Conduct (RCW 26.09.191(1), (2))

Does not apply.
2.2
Other Factors (RCW 26.09.191(3))

Does not apply.
6
7
8
9
Ill.
Residential Schedule
mcludmg provisions for holidays, birthdays of family members, vacations, and other special
occasions, and what contact the child shall have with each parent Parents are encouraged to
needs of the family. Paragraphs 3. 1 through 3. 9 are one way to write your residential
schedule. If you do not use these paragraphs, write in your own schedule m Paragraph 3. 13.
10
3.1
11
12
13
3.2
15
Does Not Apply.

schedule.
16
18
19
20
21
22
23
School Schedule
Upon enrollment in school, the child shall reside with the petitioner/mother, except for
the following days and times when the child will reside with or be with the father:
14
17
3.3
See the following provisions below for Father's out-of-state visitation
Schedule for Winter Vacation

The child shall reside with the petitioner during winter vacation, except for the following
Winter Break shall be divided evenly. The first half of Winter Break shall begin on
the day after school lets out until December 26th. The second half shall begin from
December 26th until the day before school is to resume; &
B. Every year, Father shall have the first half of Christmas break and mother the
second half each year, which also gives mother the child's birthday and New Year's Eve
holidays.
24

WPF DR 01.0400 Mandatory (6/2008)- RCW 26.09 181; 187; 194
FamilySofl FormPAK 2012

818 S Yakima Avenue, Suite 201
Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
, 3.4
Schedulefor Other School Breaks

The child shall reside with the petitioner during other school breaks, except for the
A.
Father shall have the entirety of Spring break every year. Spring break shall
begin the day after school lets out until the day before school resumes: and
All other school breaks, not otherwise addressed herein, shall be taken by the
person scheduled to have the child.
5
6
7
3.5
SummerSchedule
Upon completion of the school year, the child shall reside with the pentioner, except for
10
Each year, Father shall have vacation beginning on July 31st (so that the child can
spend her mother's birthday on July 29th with mother) until August 24th.
11
12
Although accommodations may be necessary with regards to flight times, in no case

shall Father receive less than three weeks in the summer with the child beginning July
3151 each year.
13
14
'3.6
15
The schedule for vacation with Father is as follows
16
A
This paragraph applies to Father only, as it only addresses his vrsitation to North
Carolina to visit his child) ct-l( ha..ud 5~l(
~ o.J'N~~ A .30AAuS ~G'<'
"'UO-ii u {-1n. ~ .(,Ml\~
. -- (\~
.,,
B.
If Father rs able to get add1tioha1 vacation time (other than the visitation listed
elsewhere herein), he may have the following additional visitation time with his
daughter in North Carolina: d'NAt four times per year, not otherwise outlined ~
heremj and Ar;f io iA/.
</ uX.lJ(S ~
~
~
~ AIC i
17
18
19
ceca
20
21
22
23
c.
n ~1r~ I
rw
Father's North Carolina visitation time shall not interfere with the child's
schooling, although she may remain m his care while attendmg school for the
duration of his visit If she 1s in school during hrs visit, Father shall ensure that
her homework, extracurricular, sports and/or other school obligations/activities
are attended and/or completed timely If the child has a job, the father shall
enable her to get to work timely.
24
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09 181, .187; 194

818 S. Yakima Avenue, Suite 20 I
Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
'4
y
3. 7
2
3
With Petrtroner
(Specify Year
Odd/Even/Every)
With Respondent
(Specify Year
Odd/Even/Every)
5
New Year's Day
Presidents' Day
Easter
Memorial Day
July 4th
Labor Day
Veterans' Day
Thanksgiving Day
Christmas Eve
Christmas Day
6
7
8
9
10
Every
See 3. 7 B below
See 3. 7 B below
See 3. 7 B below
See 3. 7 B below
Obt:> i ~
blfouJ
See 3. 7 B below
See 3. 7 B below
Even; See 3.70 below
See 3.3 above
See 3.3 above
~.rt
See 3.7 B below

See 3.7 B below
See 3.7 B below
91 flt~
See 3 7 B below
Eve~ See 3.7 C
See 3.7 B below
See 3.7 B below
Odd, See 3.7 D below
See 3.3 above
See 3.3 above
'Lil
l),dJ}
Ul
V''~~
\-''
11
A
Holidays, which fall on a Friday or a Monday, shall include Saturday and Sunday;
8.
MLK, President's Day, Easter, Memorial Day, Labor Day and Veteran's Day shall
be taken by Mother unless Father is able to travel to North Carolina. If he is
able to travel to North Carolina, Father may have first choice of any THREE of
those holidays;
fliAJ'
C.. lfNJl
12
13
14
Et1tJ \"'
15
C.
"'b
1 jrVW
Father may have EVEEt't' July 4th Holiday, to be taken m Washington and
at his
own expense;
16
D.
Thanksqrvrnq Holiday shall begin the day school lets out until the day before
school resumes; &
Father shall give mother at least 30 days' notice prior to any travel to Nort
Carolina; &
f'.
f\'lo~r
17
18
19
20
21
22
23
24
3.8
is~~~
{t>Otfo
b~ ~'SM~.<.
l}
zors .
'
The residential schedule for the child for the following special occasions (for exJ~P~
birthdays) rs as follows
With Petitroner
With Respondent
(Specify Year
(Specify Year
Odd/Even/Every)
Odd/Even/Every)
Mother's Day
Father's Day
Every
Parentmg Plan (PPP, PPT, PP) Page 4 of 10

WPF DR 01.0400 Mandatory (6/2008) - RCW 26 09 181, 187; .194
FamdySoft FormPAK 2012
Every, but only if taken in NC

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
Birthdays
Every
A. Father shall have every Father's Day weekend for so long as he travels to North
Carolina in order to take this occasion with the child;

4
5
B. The child's birthday shall be celebrated with Mom, as it falls annually during her
Winter Break (see paragraph 3.3 above); &
C. All other birthdays shall be celebrated during regularly scheduled visitation.
3.9
Priorities Under the Residential Schedule
8
Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1 and 3.2, m the following order:
9
Rank the order of priority, with 1 being given the highest priority
10
5 holidays (3. 7)
6 special occasions (3 8)
11
12
13
14
3.10
15
Restrictions
Does not apply because there are no flm1tmg factors m paragraphs 2.1 or 2.2.
16
3.11
Transportation Arrangements
17
Transportation arrangementsfor the child between parents shall bf1ji{ollows.~
18
1.
19
20
For the following travel, on or before at leas~..r

prio~o tr~
Father shall pay
for and obtain all flights for the child (except for Spring Break which shall be paid for
and obtained by Mothm-} Mother shall reimburse father as soon as possible, but
not later than within Mldays from the df.j)] his initial purchase (with proof thereof /.fl'/
provided to mother): z..~
., ~
""C
21
a.
b.
c.
d
22
23
24
f ~,
2.
Spring Break:
Summer Break
Thanksgiving:
Christmas:
75o/;:
~other pays
Mother pays 75%
Mother pays 75%
Mother pays 75%
If for some unforeseen reason, the child cannot leave North Carolina for her time
with Father, Mother shall pay the same percentage for Father's flight to visit the

WPF DR 01 0400 Mandatory (6/2008) - RCW 26 09 181, .187; .194

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
child in North Carolina, with Father maintaining (without reimbursement) his

lodging and food.
2
3
3.
Father shall pay 100% of his travel costs when visiting the child in North Carolina,
except for as provided in paragraph #2 above ..
4.
In all cases of vlsttatron herein, the parents shall reasonably work with one another to
accommodate the child's schedule for reasonable flight times between Washington
and North Carolina, while maximizing Father's time with his child.
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
3.12 Designation of Custodian

The child named m this parenting plan is scheduled to reside the majority of the time
with the petitioner. This parent is designated the custodian of the child solely for
purposes of all other state and federal statutes which require a designation or
determination of custody. This designation shall not affect either parent's rights and
responsibilities under this parenting plan
3.13 Other
1. Deviation from the Schedule:
The parents acknowledge and agree that as they

and the child grow older, and as the parents' work schedules change, it is probable
that revisions will be required in this plan. The parents acknowledge that such
changes are unpredictable and agree to remain flexible with respect to the provisions
in this plan The parents also acknowledge their willingness to accommodate
changes to, and to remain flexible regarding changes to, the other parent's work
schedule. However, acceptance or waiver of any deviations from the provisions of
this parenting plan shall not constitute acceptance or waiver of subsequent
deviations from this plan;
2. Accommodations to this plan in regards to the other parent and/or the child must be
mutually agreed upon and done by way of writing (email with confirmed receipt or@)
certified mail). Changes and accommodation to visitation that facilitate the child's
schedule shall not constitute a violation of this plan or the basis to increase or
\
decrease the conditions set herein;
~\
A\<
3. "Travel Costs: The parents agree to work reasonably with one another to obtain the
least expensive flights, while not reducing Father's visitanon time and
accommodating the child's needs and mother's workmche
I
4. Consumption of Alcohol:
h;tt.u s"4tU tter
~11
s1:t11 nail consum
~
alcohol, wfule that parent rs
/,
l..
exercising residential time wrth the child.
23
3.14 Summary of RCW 26.09.430. 480, Regarding Relocation of a Child

24
This rs a summary only. For the full text, please see RCW 26.09.430 through 26.09 480.
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.181; 187, 194
Fat111lySoft FormPAK 2012
The Law Officeof Sandra E. Johnston

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
1
2
If the person with whom the child resides a majority of the time plans to move, that
person shall give notice to every person entitled to court ordered time with the child.
3
4
5
lf the move is outside the child's school district, the relocating person must give notice by
personal service or by mail requiring a return receipt. This notice must be at least 60
days before the intended move. If the relocating person could not have known about
the move in time to give 60 days' notice, that person must give notice within 5 days after
learning of the move. The notice must contain the information required in RCW
26.09.440. See also form DRPSCU 07 0500, (Notice of Intended Relocation of A
Child).
7
8
If the move rs within the same school district, the relocating person must provide actual
notice by any reasonable means. A person entitled to time with the child may not object
to the move but may ask for modification under RCW 26.09.260.
9
10
Notice may be delayed for 21 days 1f the relocating person is entering a domestic
violence shelter or is moving to avoid a clear, immediate and unreasonable risk to health
and safety.
11
12
13
14
15
16
17
If information is protected under a court order or the address confidentiality program, it

may be withheld from the notice.
A relocating person may ask the court to waive any notice requirements that may put the
health and safety of a person or a child at risk.
If no objection is filed within 30 days after service of the notice of intended
relocation, the relocation will be permitted and the proposed revised residential
A person entitled to time with a child under a court order can file an objection to the
child's relocation whether or not he or she received proper notice
18
19
20
21
An objection may be filed by using the mandatory pattern form WPF DRPSCU 07.0700,
(Objection to Relocation/Petition for Modification of Custody Decree/Parenting
Plan/Residential Schedule). The objection must be served on all persons entitled to time
with the child.
The relocating person shall not move the child during the time for Objection unless: (a)
the delayed notice provisions apply; or (b) a court order allows the move.
22
23
24
If the objecting person schedules a hearing for a date within 15 days of timely service of
the objection, the relocating person shall not move the child before the hearing unless
there rs a clear, immediate and unreasonable risk to the health or safety of a person or a
child.

WPF DR 01 0400 Mandatory (6/2008) - RCW 26.09 181; 187, .194
FamJlySoft FormPAK 2012

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
IV. DecisionMaking
2
4.1
3
Each parent shall make decisions regarding the day-to-day care and control of each
child while the child is residing with that parent. Regardless of the allocation of decision
making m this parenting plan, either parent may make emergency decisions affecting the
health or safety of the child.
4
5
6
4.2
Major Decisions
7
8
petitioner
Non-emergency health care petitioner
petitioner
9
10
11
14T>wroer' V\.ti tt.v ftVul- s NLll
4.3
Restrictionsin Decision Making
fo'fi,I
pw~
..,_,, ~u.cd
1 )
{l...i..r
cft.v
UM.i /.AJ<.rJ I~ o~~ 0
o {.,
.14ptMj{.S
12
Sole decision makmg shall be ordered to the petitioner for the following reasons:
13

f'
14
(a)
(b)
The history of participation of each parent m decision making in

each of the areas in RCW 26.09.184(4)(a);
(c)
Whether the parents have demonstrated ability and desire to

cooperate with one another in decision making in each of the
areas in RCW 26.09.184(4)(a); and
(d)
The parents' geographic proximity to one another, to the extent

that rt affects their ability to make timely mutual decisions.
15
16
17
18
19
20
21
22
23
24
the provisions of this plan must, be used before ftling a petition to modify the plan or a motion for
Disputes between the parties, other than child support disputes, shall be submitted to
WPF DR 01 0400 Mandatory (6/2008)- RCW 26 09.181, 187, 194
FamllySoft FormPAK 2012

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
..,
1
(list person or agency):
2
Mediation by Pierce County Center for Dispute Resolution, with Mother being allowed to
appear by phone, if this box 1s checked and issues of domestic violence or child abuse
are present, then the court finds that the victim requested mediation, that mediation is
appropriate and that the victim is permitted to have a supporting person present during
the mediation proceedings. or
3
4
5
The cost of this process shall be allocated between the parties as follows:
6
50% petitioner 50% respondent.
7
written request via certified mall.
Notice may be given by email.

email address.
Both parties shall keep the other apprised of his/her
10
11
(a)
(b)
Unless an emergency exists, the parents shall use the designated process to
resolve disputes relating to implementation of the plan, except those related to
financial support.
(c)
A written record shall be prepared of any agreement reached in counseling or

mediation and of each arbitration award and shall be provided to each party.
(d)
If the court finds that a parent has used or frustrated the dispute resolution
process without good reason, the court shall award attorneys' fees and financial
sanctions to the other parent.
(e)
The parties have the right of review from the dispute resolution process to the
superior court.
12
13
14
15
16
17
18
19
VI.
Other Provisions
--tit /;I lou).,y
20
There are BO ether pr6visions.

(} ~
I.
v' h
We{ n...t-r- p Q...r~
~- ~ tlM.Jrl. ~~tn
-M
f23
!YJ~
Does Not Apply.
2,
3. ltt[k
\I"
\..~
~+,
VJ'i ~
11 __
+e 0.'U ~
, ,/.
VM
f~ f;;o~fp:::e~i~Grttin
~11-.r
0)
Skll
=~
~f- 11--t ofl.....ttl'
1)() r
Q,
ix~
I.
'fl-lp1--1~'
.sJ..Arl tA'l-~ ~
)M-~
ol\.s SaAis ~~
il"-'
~Id
0 fl4-
pet-r-+t.
.s.N.tU ~U)v-i"~ ."4 et4-r\ 1f'k.c*r \ '-tt~:v ,.u._~\lLMuJ

l<:s bb N
~.:h- l-1 ~ \... i1M.s S<'d.e r.f .(J.L( W4f f..ll."'\
arenting Plan (PPP, PPT, PP) Page 9of10

WPF DR 01.0400 Mandatory (6/2008)- RCW 26 09.181;
FiamllySoft FormPAK 2012
el
3 tvitll UM c(k ~{
187; 194
\) The Law Office o~ndra E. Johiisiijd'

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
..
22909 4/4~2013
40~33

2
3
4
5
6
It rs ordered, adjudged and decreed that the parenting plan set forth above is adopted and
approved as an order of this court.
WARNING: Violation of residential provisions of this order with actual knowledge of its terms is
When mutual decision making is designated but cannot be achieved, the parties shall make a
good faith effort to resolve the issue through the dispute resolution proce .
7
8
9
If a parent fails to comply with a provision of this plan) the other p

plan are not affected.
Dated,__
L(.....__~_( _J """"""-?;
10
11
12
13
Eric
Berg I WSBA #28011
Attorn y for Peutroner
14
15
16
17
18
19
20
21
22
23
APR -12013
24
WPF DR 01 0400 Mandatory (6/2008) - RCW 26 09 181; .187, 194
Fam1lySoft FonnPAK 2012
ice of Sandra E. Johnston

818 S Yaktma Avenue, Suite 201
Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
I~
r 1 u 11r1n111mi1-~
~
02-3-02768-6
-- ------
40285928
ORMDO
04-03-13
3
4
FILED
DEPT. 2
JN OPcN
c6uRr
APR -12013
7
County of PIERCE
8
9
10
In re:
No. 02-3-02768-6
DEBORAH J DAHL
11
12
13
Order Re Modification/Adjustment
Of Custody Decree/Parenting
(ORMDD/ORDYMT}
Petitioner,
and
JAMES R. DAHL
Respondent.
14
15
I.
Basis
16
17
This order is based on a petition for an order modifying the pnor custody decree/parenting
plan/residential schedule/judgment establishing parentage and an agreement of the parties.
18
II. Findings
19
The Court Finds::
20
2.1
Jurisdiction
21
This court has jurisdiction over this proceeding for the reasons below
22
23
This court has exclusive continuing junsdrction. The court has previously made a child
custody, parenting plan, residential schedule, or visitation determination in this matter
and retains jurisdiction under RCW 26 27.211.
24
25
Ord re Mod/AdJof Parenting Pin (ORMDD, ORDYMT) - Page 1 of 4
WPF DRPSCU 07 0400 Mandatory (7/2011) - RCW 26 09.260, .270;
26.10.200
ORIGINAL

818 S Yakima Avenue, Suite 20 I
Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
22909 4/4/2513
9Bti35
This state is the home state of the child because: the child lived in Washington with a
3
commencement of this proceeding and the child is are absent from the state but a parent
or person acting as a parent continued to hve in this state.
4
5
parent have significant connection with the state other than mere physical, presence;
and substantial evidence rs available in this state concerning the child's care, protection,
training and personal relationships and the child has no home state elsewhere.
2.2
10
ModificationUnder RCW 26.09.260(1 ),(2)

The custody decree/parenting plan/residential schedule should be modified because a
substantial change of circumstances has occurred in the circumstances of the child or
the nonmoving party and the modification is in the best interest of the child and is
necessary to serve the best interest of the child. This finding is based on the factors
below:
11
12
13
The parties agree to the modification.
14
The following facts, supporting the requested modification, have arisen since the decree
or plan/schedule or were unknown to the court at the time of the decree or
plan/schedule:
15
16
Mother has taken a new job in North Carolina and father agrees that their
youngest daughter may move with her Mother based on the residennal schedule
negotiated by the parties, albeit the child's two older siblings (sisters) still reside
in Washington State.
17
18
19
2.3
20
21
Does not apply.
2.4
22
23
24
Modificationor AdjustmentUnder RCW 26.09.260(4) or (8)
Adjustmentsto Residential ProvisionsUnder RCW 26.09.260(5)(a) and (b)

Does not apply.
2.5
Adjustmentsto Residential ProvisionsUnder RCW 26.09.260(5)(c), (7), (9)

Does not apply.
25
Ord re Mod/Adj of Parentrng Pin {ORMDD, ORDYMT)- Page 2 of 4
WPF DRPSCU 07.0400 Mandatory (7/2011) - RCW 26 09 260; .270,
2610 200
FarrulySoft FormPAK 2012

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
1
This section only applies to a person with whom the child does not reside a
majority of the time who is seeking to increase residential time.
2
3
2.6
Adjustments to Nonresidential Provisions Under RCW 26.09.260(10)
4
The following non-residential aspects of the parentrng plan/residential schedule should
be adjusted because there rs a substantial change of circumstances of either party or of
the child and the adjustment rs in the best interest of the child:
5
6
Decision making.
7
Transportation arrangements.
8
9
2.7
Substantial Change in Circumstances

(Complete this part if a modification or adjustment is based on paragraphs 2.2, 2.4,
2.5.1, 2.5.3 or 2.6).
10
11
The following substantial change has occurred in the circumstances of either party or of
the child:
12
13
Mother has taken a new job m North Carolina and father agrees that the child may move
with her mother based on the residential schedule negotiated by the parties, without a
deviation for his cost of travel or other costs and/or changes to the pnor Order of Child
Support filed on March 26, 2004.
14
15
2.8
Protection Order
16
Does not apply
17
18
19
20
21
22
111. ORDER
It is Ordered:
The pennon to modify/adjust the custody decree or parenting plan/residential schedule is
granted. The custody decree or parenting plan/residential schedule signed by the court
on this date and filed herewith is approved and incorporated as part of this order. This
decree or parenting plan/residential schedule supersedes all previous decrees or
parenting plans/residential schedules.
23
24
25
Ord re Mod/AdJ of Parenting Pin (ORMDD, ORDYMT) - Page 3 of 4
WPF DRPSCU 07.0400 Mandatory (7/2011) - RCW 26 09.260; 270,
26.10.200
FamllySoft FormPAK 2012

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
.
1
2
Other:
Pierce County Superior Court shall retain jurisdiction over this matter until the child
reaches the age of rnajonty and/or is no longer m need of support (including
post-secondary support).
4
5
6
7
Dated:~_l-f_._f.___,I
8
9
Pr:esented by:
11
En V. Berg
Date
Sig ature of Party or LawyerNVSBA No.
Atto ney for Petitioner
12
13
14
15
Date
16
17
f\t.EO
o~fi1.
18
,buRi
\N oPr:.N C
19
~?R -11\ln
20
21
22
23
24
25
Ord re Mod/AdJ of Parenting Pin (ORMDD, ORDYMT)- Page 4 of 4
WPF DRPSCU 07 0400 Mandatory (7/2011) - RCW 26 09.260; .270,
2610 200
Fam1lySoft FotmPAK 2012

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
E-FILED
June 04 2014 11:13 AM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7
County of Pierce
Inre:
No. 02-3-02768-6
DEBORAH J. DAHL,
10
11
and
Summons for Modification

of Child Support
12
JAMES R. DAHL,
(SM)
Petitioner,
Respondent.
13
14
15
To:
JAMES R. DAHL, Respondent
1.
An action has been started against you in the above court requesting that the court modify the
child support provisions of your support order. The requests are stated in the petition, a copy
of which is served upon you with this summons.
2.
You must respond to this summons and petition by filing a written response with the clerk of
the court and by serving a copy of your response on the person signing this summons. You
must also complete the Washington Child Support Schedule Worksheet and a Financial
Declaration (Form WPF DRPSCU 01.1550) served with this summons. The completed
worksheet and financial declaration must be filed and served with your written response.
3.
Your written response to the summons and petition must be on form WPF DRPSCU 06.0300,
Response to Petition for Modification of Child Support (RSP). This form may be obtained
by contacting the clerk of the court at the address below, by contacting the Administrative
Office of the Courts at (360) 705-5328, or from the Internet at the Washington State Courts
homepage:
16
17
18
19
20
21
22
23
24
25
THOMAS A. CENA, JR.

Attorney at La
3929 Bridgeport Way West, #30
Summons for Mod of Child Suppt (SM) - Page 1
WPF DRPSCU 06.0200 Mandatory (6/2008) - CR 4.1; RCW 26.09.175 (2),(ib3) 572_5120 Fax: (253) 593-4503
E-MAIL: [email protected]
4.
If you do not file and serve your written response within 20 days (60 days if you are served
outside of the state of Washington) after the date this summons was served on you, exclusive
of the date of service, the court may, without further notice to you, enter a default judgment
against you ordering the relief requested in the petition. If you serve a notice of appearance
on the undersigned person, you are entitled to notice before an order of default may be
entered.
5.
You may demand that the other party file this action with the court. If you do so, the demand
must be in writing and must be served upon the person signing this summons. Within 14
days after you serve the demand, the other party must file this action with the court, or the
service of this summons and petition will be void.
6.
If you wish to seek the advice of an attorney in this matter, you should do so promptly so that
your written response, if any, may be served on time. Copies of these papers have not been
served upon your attorney.
7.
One method of serving your written response, completed worksheet and financial declaration
is to send them by certified mail with return receipt requested.
2
3
4
5
6
7
8
9
10

the state of Washington.
11
12
Dated:
d<AM! 'f,
~O/"f
13
THOMAS A. CENA, JR., WSBA NO. 6539

14
15
16
17
18
File original of your response with

the clerk of the courtat:
Serve a copy of your response on:
PIERCE COUNTY CLERK

Tacoma, WA 98402
253-798-7455
THOMAS A. CENA, JR.

Attorney at Law
3929 Bridgeport Way W., #304
Phone: 253-572-5120
19
20
21
22
23
24
25

WPF DRPSCU 06.0200 Mandatory (6/2008) - CR 4.1; RCW 26.09.175
THOMAS A. CENA, JR.

Attorney at La
(2),(i~53) 572_5120 Fax: (253) 593-4503
E-FILED
June 10 2014 3:57 PM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7
County of Pierce
Inre:
No. 02-3-02768-6
DEBORAH J. DAHL,
10
11
and
Summons for Modification

of Child Support
12
JAMES R. DAHL,
(SM)
Petitioner,
Respondent.
13
14
15
To:
1.
An action has been started against you in the above court requesting that the court modify the
child support provisions of your support order. The requests are stated in the petition, a copy
of which is served upon you with this summons.
2.
You must respond to this summons and petition by filing a written response with the clerk of
the court and by serving a copy of your response on the person signing this summons. You
must also complete the Washington Child Support Schedule Worksheet and a Financial
Declaration (Form WPF DRPSCU 01.1550) served with this summons. The completed
worksheet and financial declaration must be filed and served with your written response.
3.
Your written response to the summons and petition must be on form WPF DRPSCU 06.0300,
Response to Petition for Modification of Child Support (RSP). This form may be obtained
by contacting the clerk of the court at the address below, by contacting the Administrative
Office of the Courts at (360) 705-5328, or from the Internet at the Washington State Courts
homepage:
16
17
18
19
20
21
22
23
24
25
THOMAS A. CENA, JR.

Attorney at La
WPF DRPSCU 06.0200 Mandatory (6/2008) - CR 4.1; RCW 26.09.175 (2),(ib3) 572_5120 Fax: (253) 593-4503
4.
If you do not file and serve your written response within 20 days (60 days if you are served
outside of the state of Washington) after the date this summons was served on you, exclusive
of the date of service, the court may, without further notice to you, enter a default judgment
against you ordering the relief requested in the petition. If you serve a notice of appearance
on the undersigned person, you are entitled to notice before an order of default may be
entered.
5.
You may demand that the other party file this action with the court. If you do so, the demand
must be in writing and must be served upon the person signing this summons. Within 14
days after you serve the demand, the other party must file this action with the court, or the
service of this summons and petition will be void.
6.
If you wish to seek the advice of an attorney in this matter, you should do so promptly so that
your written response, if any, may be served on time. Copies of these papers have not been
served upon your attorney.
7.
One method of serving your written response, completed worksheet and financial declaration
is to send them by certified mail with return receipt requested.
2
3
4
5
6
7
8
9
10

the state of Washington.
11
12
Dated:
d<AM! 'f,
~O/"f
13

14
15
16
17
18
File original of your response with

the clerk of the courtat:
Serve a copy of your response on:
PIERCE COUNTY CLERK

Tacoma, WA 98402
253-798-7455
THOMAS A. CENA, JR.

Attorney at Law
Phone: 253-572-5120
19
20
21
22
23
24
25

WPF DRPSCU 06.0200 Mandatory (6/2008) - CR 4.1; RCW 26.09.175
THOMAS A. CENA, JR.

Attorney at La
(2),(i~53) 572_5120 Fax: (253) 593-4503
E-FILED
June 10 2014 3:57 PM
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6

County of Pierce
In re:
No. 02-3-02768-6
DEBORAH J. DAHL,
10
Petitioner,
and
11
Petition for Modification

of Child Support
(PTMD)
JAMES R. DAHL,
12
Res ondent.
13
I. Basis
14
DEBORAH J. DAHL represents to the court that:

15
1.1
Place of Residence
16
The petitioner resides in Forsyth County, North Carolina.

The child resides in Forsyth County, North Carolina.
The respondent resides in Pierce County, Washington.
17
18
1.2
19
This court has jurisdiction over the parents for the reasons that follow.
20
21
22
Jurisdiction Over Parents
[X]
1.3
There is a Washington Order of Child Support.
Most Recent Support Order

The most recent support order was entered in Pierce County, Washington, dated March 26,
2004.
23
24
25
Pet for Mod of Child Suppt (PTMD) - Page 1

WPF DRPSCU 06.0100 Mandatory (6/2010) - RCW 26.09.170; .175
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
1
2
The order requires JAMES R. DAHL to pay $928.12 per month for the support of the
following children:
Amanda Dahl, Sarah Dahl and Elizabeth Dahl
1.4
6
7
Reasons for Modifying Child Support

[X]
A party commenced this action.
[]
The DSHS commenced this action under RCW 26.09.170(8), or RCW 26.09.170(9)
and/or RCW 26.09.175(3) and:
[]
Public assistance money is being paid to or for the benefit of a child; or
[]
A party to the order in a nonassistance case requested a review; or
[]
Another state or jurisdiction requested a modification of the order.
OR
8
9
10
AND, the order of child support should be modified for the following reasons:
11
[X]
12
13
There has been the following substantial change of circumstances since the order was
entered (explain):
15
The child for whom the support continues to be required, Elizabeth Dahl, is now in an older age
category. Support is required, at this time, for only one of the three children for which it was
originally required. The income of the parties has changed from the date of the last support
order. No change, review or modification of the support in this matter has been accomplished
since March of 2004.
16
[]
No post-secondary support was ordered and the right to request post-secondary child
support was not reserved. (Name of child)
is in need of
post secondary educational support because the child is in fact dependent and is relying
upon the parents for the reasonable necessities of life and there has been the following
substantial change of circumstances since the order was entered (explain):
[X]
ELIZABETH DAHL is a dependent adult child and support should be extended

beyond his or her 18th birthday because: The child will be s senior in high school on
her 18th birthday, January 1, 2015. She will not graduate high school until June of
2015. Elizabeth Dahl has participated in advanced placement classes in English,
Environmental Science, French and Pre-Calculus. She maintains a overall grade point
average of3.6 to 3.7. Elizabeth Dahl attended, in the Summer of 2013, a 10-dayyouth
leadership forum in medicine at the University of North Carolina at Chapel Hill. In the
Summer of 2014, she will attend a national youth leadership forum in medicine at
14
17
18
19
20
21
22
23
24
25

THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Johns Hopkins University in Baltimore. The child's eligibility to attend the Johns
Hopkins forum required her previous attendance at the University of North Carolina
event. The child wishes and is qualified to pursue academic education after high
school graduation.
2
3
[]
4
Whether or not there is a substantial change of circumstances, the previous order was
entered more than a year ago and:
[]
[]
[]
[]
The order works a severe economic hardship.

The child has moved to a new age category for support purposes.
The child is still in high school and there is a need to extend support beyond
the child's is" birthday to allow the child to complete high school.
An automatic adjustment of support should be added consistent with RCW
26.09.100.
8
[]
Other:
10
1.5
Starting Date of Modified Order

[X]
11
The starting date of the modified child support order should be the date on which this
petition is filed.
12
1.6
13
1.6.1 Petitioner asks the Court to establish a judgment for unpaid and delinquent child
support from the previously entered child support order of March 26, 2004 through June 1, 2014.
Other
14
1.6.2 Unpaid and delinquent child support totals $89,081.32.
15
16
1.6.3 Interest on unpaid child support totals $52,307.86, which includes the sum of
$7,298.09 as interest upon the judgment for unpaid child support of $6,031.48, which judgment is
included in the order of child support filed March 26, 2004.
17
18
19
The court should modify the order of child support by:
20
[x]
21
22
[x]
requiring either or both parents to maintain or provide medical support consistent with
RCW 26.09.105, including but not limited to health insurance coverage for the child(ren), and
by requiring each parent to contribute his or her proportionate share of uninsured medical
expenses.
ordering child support payments which are based upon the Washington State child support
statutes. A copy of the child support worksheet is filed with this action.
23
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
[]
[x]
2
3
[]
[x]
[]
5
6
7
8
9
[X]
[]
[]
[]
[]
[]
[x]
[X]
ordering repayment or credit for overpaid child support since the date of filing this petition.
ordering payment of underpaid child support since the date of filing this petition or entering
judgment in that amount.
requiring a periodic adjustment of support.
extending child support beyond Elizabeth Dahl's 18th birthday to allow the child to complete
high school.
extending child support beyond (name of child)
's
18th birthday until (he) (she) is no longer dependent upon either or both parents and is capable
of self-support.
allowing for post secondary educational support for Elizabeth Dahl.
ordering the payment of day care.
ordering the payment of educational expenses.
ordering the payment of long distance transportation expenses.
ordering the payment of uninsured medical expenses.
awarding the tax exemption for the child(ren) as follows:
other: Establishing a judgment for unpaid child support in the amount of $89,081.32, plus
interest on unpaid support in the amount of L').:,.t-itt'-f--il.;.t:i
10
11
12
13
14
15
Dated:
d.u.MJ. l-f I 201 '(

I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true
and correct.
Signed at Salem, North Carolina, this __ day of May, 2014.
16
17
18
DEBORAH J. DAHL, Petitioner
19
20
21
22
23
24
25

WPF DRPSCU 06.0100 Mandatory (6/2010) - RCW 26.09.170;
.175
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Fax Server
1
2.
AM
PAGE
3/003
[]
ordering repnymenr or credit for overpaid child support since the date of filing this petition.
(x]
ordering payment of underpaid child support since the date of filing this petition or entering
. . ~ ....
[]
3
[x]
[]
5
[X]
[1
[]
[]
[]
[]
[x]
9
5/30/2014 11:31:02
[X]
10
judgmerit
in.that.arn().l 11~~ .
requiring a periodic adjustment of support.

extending child support beyond Elizabeth Dahl's l8u1 birthday to allow the child to complete
high school.
extending child support beyond (ruune of child)
's
1811' birthday until (he) (she) is no longer dependent upon either or both parents and is capable
of self-support,
allowing for post secondary educational support for Elizabeth Dahl.
ordering the payment of day care.
ordering the payment of educational expenses.
ordering the payment of long distance transportation expenses.
ordering the payment of uninsured medical expenses.
awarding the tax exemption for the child(ren) as follows:
other: Establishing a judgment for unpaid child support in the amount of $89,081.32, plus
interest on unpaid support in the amount of $52,307.86.
11
Dated:
12
13
_
14
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true
and correct.
15
Signed at Salem, North Carolina, this li_ day of May, 2014.
16
17
18
~~ltoM
J.
Petitioner
DEBORAH
D,
19
20
21
22
23
24
THOMAS A. CENA,
Attorney at La
25
Pet for Mad of Chlld Suppt (PTMD} - Page 4
WPF DRPSCU 06.0100 Mandatory (6/201 O} - RCW 26.09.170; .175

Universlty Plnce, WA 9846
(253) 572-5120 Fax: (253) 593-450
2
3
4
5
6
7
Countyof Pierce
Inre:
No. 02-3-02768-6
DEBORAH J. DAHL,
AFFIDAVIT OF ATTORNEY
RE FAX TRANSMITTAL
10
Petitioner,
11
and
12
JAMES R. DAHL,
13
Respondent.
14
STATE OF WASHINGTON)
15
SS.
County of Pierce
16
THOMAS A. CENA, JR., being first duly sworn on oath, deposes and says:
17
That he is the attorney for DEBORAH J. DAHL, Petitioner in the above-entitled
18
19
matter.
20
21
22
That I have examined the attached Petition for Modification of Child Support,
23
24
25
Affidavit - 1
TIIOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
which is being filed with the above-entitled Court.

2
The Petition consists of seven (7)
pages (including this affidavit) and it is complete and legible.
3
4
5
6
SUBSCRIBED AND SWORN TO BEFORE ME this
4_ day of June, 2014.
v&~~~
8
9
10
NOTARY PUBLIC in and for the

State of Washington, residing at
11
Tacoma.
My Commission Expires:
C-- (-/ .r:

D
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Affidavit
-2
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
E-FILED
October 02 2014 8:46 AM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
No. 02-3-02768-6
Petitioner(s),
vs.
JAMES R DAHL
Respondent(s)
Name: SANDRA E. JOHNSTON
Address: 705 S 9TH STE 104 TACOMA, WA 98405
Phone: (253) 272-0566

Please take notice that an issue of law in this case will be heard on the date and time shown below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
Show Cause
Nature of Hearing: Child Support
Calendar: Show Cause/Family Law
CALENDAR DATE: Thursday, November 06, 2014 9:00 AM

WORKING COPIES SHALL BE SUBMITTED TO COMMISSIONERS SERVICES ROOM 140,
BEFORE 12:00 NOON TWO COURT DAYS PRIOR TO HEARING
DATED:
October 2, 2014.
Signed:
/s/ THOMAS ANTHONY CENA JR
NAME:
THOMAS ANTHONY CENA JR
Phone:
(253) 572-5120
WSBA#:
For:
6539
ADDRESS: 3929 Bridgeport Way W #304

UNIVERSITY PLACE, WA 98466-br>U
Note for Commissioners Calendar (ntc.rptdesign)
1 of 1
E-FILED
June 12 2014 3:33 PM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
IN THE ~l.JPERIOR COURT FOR THE STATE Of WASHINGTON

IN ANO FOR THE COUNTY OF PIERCE
Cause No. 02-3-02768-6

IN RE: DEBORAH .J. DAHL
Return of Service:
Plaintiff/Petitioner
.J \:\ff~ I~.
SL '\1\.10'\S OF MOOJFICA'l 101'1 OF CHILD

SUPPORT (~'1)
PCTI nor, FOR i\1001 FICA TIO'\ OF Cl II LD
~liPPORT (PTMO)
uvru,
Oefendant/Respondent
The undersigned. hereby declares under penalty of perjury under the laws of the State of Washington. that the
following is true and correct: I am now, and at all times herein mentioned. a citizen of the United States and a
resident of the State of Washington, over the age of eighteen years. not a party to or have an interest in the above
entitled action and competent to be a witness.
Personal Service
On the date .JUNE 7n. 201~ at I l:-'8Pl\1. at the address of215 CO~TRA COSTA. City of FIRCREST.
WA Ii INGTON 98466 I duly served the above described documents upon .JA '\1 F.~ OAH Lb) then and there
personally delivering ONI<. true and correct copy thereof and leaving same with .IA' l\r .JUELl'\IG - MOTHF.R
Service.
1 ravel.
Date: JU~E 11111 20 I~
sy4f.~ ~H~ ~,,_--
elvin Cahoon PC#9 I 88

Tacoma, Washington
Bad Address:
Proof.
Other
. TOTAL$
.___ _.I
Rock Solid Legal Support

(253) 682-1230
l nps b}
.___ _.I
Miles
E-FILED
July 07 2014 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7
County of PIERCE
8
9
10

No. 02-3-02768-6
DEBORAH J. DAHL
11
12
13
Petitioner,
and
JAMES R. DAHL
Respondent.
14
15
1.
16
17
Acceptance of Service
(ACSR)
Acceptance of Service
James Dahl accepts service of the summons and petition in this action.
2.
Consent to Personal Jurisdiction
18
James Dahl consents to personal jurisdiction.
19
3.
Other
20
The Summons (without the Petition) was originally served on Respondent's 88 year old
mother; however, Respondent has now actually received both the Summons and
Petition filed in this matter and r by accepts s
ce thereof.
21
22
23
24
Dated:
25
Acceptance of Service (ACSR) - Page 1 of i
WPF DRPSCU 01.0310 (6/2006)

705 S. 9th Street, Suite #104
Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
E-FILED
July 07 2014 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7
County of PIERCE
8
9
10
In re:
No. 02-3-02768-6
DEBORAH J. DAHL
11
12
13
Petitioner,
and
JAMES R. DAHL
Respondent.
14
15
Response to Petition for

Modification of Child Support
(RSP)
To:
Deborah Dahl
1.
Admissionsand Denials
16
17
18
The allegations of the Petition in this matter are admitted or denied as follows (check
only one for each paragraph):
19
Paragraph of the Petition
20
1.1
Denied
1.2
Admitted
1.3
Denied
1.4
Denied
1.5
Denied
1.6
Denied
Each allegation of the petition that is denied, is denied for the following reasons [List
separately]:
21
22
23
24
1.1
Respondent resides in King County
25
Resp to Pet for Mod of Child Suppt (RSP) - Page 1 of 3
WPF DRPSCU 06.0300 Mandatory (6/2008) - CR 8; RCW 26.09.175

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
1
1.3
2
3
4
Additionally there was a $400 obligation included therein for daycare costs that
were not incurred for the last 7 years. Father's obligation was listed as 37.4 %
for each child. Over the years, Father paid over the amount outlined in the
order. Instead of paying his percentage for each child, he divided the total
(which included an extra $400 for daycare that was not being used) by three.
He has paid over the amount that he was ordered to pay monthly for each child.
5
6
7
8
The most recent order entered on 03/26/04 orders that the following amounts are
the basic support for each child:
Amanda
$790
Sarah
$639
Elizabeth
$639
1.4
10
11
Elizabeth Dahl is not a dependent adult. The young woman has outstanding
scholastic achievement, as evidenced in the Petitioner's own statement in her
Petition that her daughter is already attending leadership forums in medicine at
UNC in Chapel Hill and Johns Hopkins in Baltimore. There is no expectation
that such a gifted child will need to remain living in her mother's home in North
Carolina, while attending a University in Baltimore or elsewhere. The older two
children were not given an order of support for postsecondary education.
Respondent does not object to paying child support up until his daughter finishes
high school in May 2015 (this year the school year was prolonged for snow
days); however, there is no basis to continue child support past Elizabeth's high
school graduation.
12
13
14
Father recommends the division of college tuition to be 1/3 to Respondent, 1/3 to

Petitioner, and 1/3 to the student, after any monies are received by way of
tuition reduction (due to mother's employment), grant, or scholarship for
the cost of tuition (up to the cost of University of Washington tuition) and for so
long as the child maintains minimum statutory grades and is enrolled full time.
15
16
17
1.5
There should be no modification of the monthly child support payment based on

the recently agreed relocation modification. This petition should solely address
post-secondary support.
1.6
There are no prior outstanding amounts owed to Petitioner. Petitioner and

Respondent made a rational decision to follow the guidelines in the prior Order of
Child Support for each child and Petitioner accepted those amounts on a regular
basis month after month without notice to Respondent that it was not an agreed
payment amount.
18
19
20
21
22
23
24
25
Petitioner filed a Petition to Modify Child Support in 2007, but it only addressed
post-secondary support for Amanda and was not pursued. The next filing was
the October 2012 Notice of Relocation, to which Respondent objected. On April
1, 2013, approximately one year ago, that matter was resolved with an agreed
Order re Modification/Adjustment of Custody Decree at a settlement conference
with Judge Stolz. That mediation process resulted in no change to child
FamllySoftFonnPAK 2014

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
support. Respondent took the amount of his child support into consideration
when the cost of his travel to see his daughter was applied.
The Court should not allow Petitioner to come back now for a third bite at the
litigation apple and seek arrearages for support that were effectively considered
and waived over a year ago. This requested relief should be denied based on
the prior order and/or the equitable theory of laches.
3
4
5
2.
Request for Relief
The court should modify the order of child support by:
Affirming the current payment amount of child support of $309.38, which is the same
amount that the Respondent was paying at the time of the entry of the last Court order.
8
Allowing the last monthly payment of child support to end in May 2015.
9
Entering a post-secondary support obligation to Respondent for 1/3 of the cost of tuition,
after all scholarship and grant money is applied.
10
Award Respondent Father attorney's fees for Petitioner's intransigence, or alternatively,

based on her ability to pay and his need.
11
12
And finally, bar the Petitioner's new attorney, Thomas A. Cena, Jr., from representing
her. Attorney Cena is business partners with Respondent's former attorney for this
matter herein, Scott Candoo. Mr. Cena affirmed that Scott Candoo told him that he
had represented Mr. Dahl in this very same matter. Respondent strongly objects to
Attorney Cena representing a party adverse to his interests.
13
14
15
16
17
18
3.
Notice of Further Proceedings

Notice of all further proceedings in this
Dated:_}.......__
_3_,
_\,,~----
19
20
Notice to party: you may list an address that is not
legal documents. Any time this address changes
while this action is pending, you must notify the
opposing parties in writing and file an updated
Confidential Information Form (WPF DRPSCU
09.0200) with the court clerk.
21
22
23
24
Tacoma, WA 98405
25


Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
E-FILED
July 14 2014 2:34 PM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
IN THE SUPERIOR COURT OF THE STATE OF W ASIIlNGTON

IN
AND FOR THE COUNTY OF PIERCE
DEBORAH J. DAHL,
Petitioner,
)
)
) NO. 02-3-02768-6
)
) NOTICE OF WITHDRAW AL AND

) SUBSTITUTION OF ATTORNEYS
VS.
)
)
JAMES R. DAHL,
Respondent.
)
)
~~~~~~~~~~~~~~~.)
To: Sandra Johnston, attorney for respondent
To: Clerk of the Superior Court
You and each of you are hereby notified that the undersigned, Eric V. Berg, hereby
withdraws as attorney for the petitioner, Deborah J. Dahl in the above-captioned action and
consents to the substitution of Thomas A. Cena, Jr. as attorney for petitioner. By his signature
below Mr. Cena accepts said substitution. This withdrawal is effective immediately.
July 11, 2014
{7y3
Eric V. Berg, WSBA~..__--~~~.uasA. ena, r., WSBA No. 6539
P.O. Box 949, Olalla, WA 98359
3929 Bridgeport Way W, #304
253-851-9619
253-572-5120
NOTICE OF WITHDRAW AL
Page 1of1
Eric V. Berg, WSBA #28ou

Attorney at Law
P. 0. Box 949, Olalla, WA 98359
(253) 851-9619
Fax: (253) 509-9999
E-FILED
August 13 2014 2:04 PM
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHJNGTON

7
8
NO. 02-3-02768-6

9
DEBORAH J. DAHL,
NOTICE OF ABSENCE &
10
Petitioner,
11
12
13
UNAVAILABILITY
and
JAMES R. DAHL,
Respondent
To:
And To:
Clerk of the Court

Thomas Anthony Cena Jr, Attorney for Petitioner
14
15
16
17
action requiring her attention be initially noted or calendaredfor 2 days immediately following
18
19
20
21
her absence to allow adequate preparation and time to contact her client/s.
1.
August 15, 2014 to August 31, 2014;

22
23
24
Dated this 13th day of August, 2014.
25
, WSBA #27313
NOTICE OF ABSENCE &
UNAVAILABILITY
Page 1of1
E-FILED
November 03 2014 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
No. 02-3-02768-6
Petitioner(s),
vs.
JAMES R DAHL
Respondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO OPPOSING PARTY:
Name: THOMAS ANTHONY CENA JR
Address: 3929 Bridgeport Way W #304 UNIVERSITY PLACE, WA 98466
U
Phone: (253) 572-5120

Motion
Nature of Hearing: Dismiss, Other REMOVE COUNSEL, PROTECT FINANCIAL DATA FROM
COUNSEL, & AWARD FEES
Calendar: KATHERINE M. STOLZ
CALENDAR DATE: Friday, November 14, 2014 9:00 AM

WORKING COPIES SHALL BE DELIVERED TO THE COURT PURSUANT TO PCLR 7 (a) (7)
PARTY SETTING HEARING SHALL CONFIRM BY NOON TWO COURT DAYS PRIOR TO HEARING
Submitted by:
DATED:
November 1, 2014.
Signed:
NAME:
SANDRA E. JOHNSTON
Phone:
(253) 272-0566
WSBA#:
For:
27313
ADDRESS: 705 S 9TH

STE 104
TACOMA, WA 98405
Note for Motion Docket (ntmtsup.rptdesign)
1 of 1
E-FILED
October 02 2014 8:46 AM
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7

County of Pierce
8
In re:
9
No. 02-3-02768-6
DEBORAH J. DAHL,
10
11
12
Petitioner,
and
DECLARATION
J. DAHL
OF
DEBORAH
JAMES R. DAHL,
Respondent.
13
14
I, DEBORAH J. DAHL, do hereby certify and declare, under penalty of perjury, under
15
the laws of the State of Washington, that the following statements are true and correct, to the
16
best of my knowledge and belief.
17
1. I am asking for modification of the child support responsibility with respect to my
18
youngest daughter, Elizabeth (Rizzy).
19
will be 18 years old on January 1, 2015. Her date of birth is January 1, 1997. At that time
20
21
Elizabeth lives with me in Winston-Salem, NC and
she will still be in high school, a senior. I am also asking for the court to order Elizabeth's
father, James Dahl, to be responsible for post-secondary support for Elizabeth while she is
22
attending college.
23
24
25
Declaration of Deborah Dahl -1
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
2. I am specifically asking for an order of support for Elizabeth, not only for her tuition
2
and college expenses but for her living expenses at school plus an amount to be paid to me
directly because Elizabeth will continue to live with me when not at school. She is a
4
5
dependent child and will be a dependent adult when she turns 18. She has and will have no
income and will be completely dependent on me for her expenses. Her expenses will include
(but not be limited to) room, board, clothing, health care, transportation, tuition, books,
7
college fees, and personal items It would be difficult for her to work and at the same time
8
attend to her post high school education. Elizabeth intends to study for a career in medicine.
9
10
11
Mr. Dahl, in his response to our petition, comments that post-secondary support was
not ordered for our two younger daughters. Amanda, our oldest, did not pursue education
12
after high school. Our second daughter, Sarah, did. However, Mr. Dahl asked me not to
13
formally petition for post-secondary support for Sarah. He did not want his employer to find
14
out about his child support obligation. I am not sure why that was.
15
3. Elizabeth has participated in advanced placement classes in English, Environmental
16
Science, French and Pre-Calculus. She maintains an overall grade point average of 3.6 to 3.7.
17
She attended, in the summer of 2013, a 10-day youth leadership forum in medicine at the
18
University of North Carolina at Chapel Hill. In summer, 2014, she attended a national youth
19
leadership forum in medicine at Johns Hopkins University in Baltimore. Her eligibility to

20
attend the Johns Hopkins forum required her previous attendance at the University of North
21
22
23
Carolina event. Elizabeth wishes and is well qualified to pursue academic education after high
school graduation.
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Documents and certificates attesting to Elizabeth's achievements in academics and

2
athletics are attached as Exhibit 1.
3
4
5
6
7
4.
The Child Support Order in effect now was entered March 26, 2014. It has never been
modified. A principle reason for my not attempting until now to modify the child support
order has been that I knew that any attempt would be met with the most intense resistance from
my ex-husband. Since I knew that Mr. Dahl would interpose as many obstacles and objections
that he could bring about to modifying support, I have refrained from asking for an increase
9
until the present time. I have, however, never waived any claim which may exist to modify
10
that support order or to request a judgment for unpaid and delinquent support. All sums
11
12
received by me from Mr. Dahl were received from him (and as often as not, by him giving the
13
check to one of the children to give to me), not from the Washington Support Registry. I have
14
kept records of the amounts of support actually received from my ex-husband. Those amounts
15
are submitted along with this declaration. Although not paid through the support registry, I am
16
willing to give Mr. Dahl credit for the amounts that he has paid. But he has underpaid his
17
support obligation to a great and significant extent and I request judgment for amounts owed.
18
19
5. The 2004 order of support requires Mr. Dahl to pay the sum of 928.12 per month.
20
21
22
23
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Although, at the time it was entered, the support order applied to our three children, Amanda,
2
Sarah, Elizabeth, the order does not break down or itemize support obligations among the
three children (Specific amounts for total support for each of the girls is set out in the
worksheets as is an amount of $400 per month for daycare). The support order itself has no
reference to daycare and simply states a specific "total" amount for the three children. I am
completely unable to make sense of the statement Mr. Dahl puts in his response to the extent
7
that" ... he divided the total (which included an extra $400.00 for daycare that wasn't being
8
9
10
used) by three." (Response of James R. Dahl, July 3, 2014, at Paragraph 1.3)

6. In paragraph 1.5 and 1.6 of his response to the modification petition, Mr. Dahl says
11
there should no modification of child support "based on the recently agreed relocation
12
modification." I did not mention the issue of support in the process of the relocation action.
13
Mr. Dahl also did not address the issue of support. I never intended to waive or give up any
14
claim or opportunity to address support modification or seeking judgment for back unpaid
15
support. I also realize and acknowledge that any modification of support can, at the earliest,
16
17
only begin with the date of my filing the current support modification petition.
The
relocation issue was settled at a settlement conference with Judge Stolz. The issue of support
18
did not come up.

19
7. It is hard for me to make sense of the statement of Mr. Dahl (paragraph 1.6) that
20
"There are no prior outstanding amounts owed to Petitioner." The simple arithmetic of the
21
22
23
situation is that the 2004 order requires the Respondent to pay a total of $113,230.64 from
the time of the order to the time of filing. Mr. Dahl has paid a total of $30, 180.80. This
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
leaves the amount of unpaid support $83,049.84. My record of payment is attached to this
2
declaration as Exhibit 2.
myself to do anything but for him to follow the terms of the 2004 order. He simply has not
4
5
There was no such "rational decision" between Mr. Dahl and
paid all the support he has been ordered to pay and has not ever asked to change the amount
he is responsible to pay.1
8. I absolutely did not "accept" the amounts paid by Mr. Dahl on a regular basis without
notice that those payments were not an agreed upon amount. There are indeed outstanding
9
amounts of child support owed by Mr. Dahl. When we did communicate with regard to
10
11
12
support, his comments were such as "I will make up the difference next month;" or "I will
pay you when I get my tax return;" or some other similar comment. Mr. Dahl requested that
13
I not use the child support registry and that he would give me the "rest of the support" which,
14
of course, did not happen.
15
There were definite communications between he and I any time I received from him
16
17
support that was not in the full amount. That is probably the reason that often he gave a
18
check in an envelope to the children to give to me, so as to avoid this sort of conversation.
19
20
1
21
22
23
Although our original petition requests payment for the $6,031.48 judgment for unpaid support from the 2004
order, that obligation has been satisfied. In reviewing the court file, a satisfaction of judgment in the amount of
$6,552.10 was filed on September 4, 2012. That amount was received because it was a judgment and needed to
be paid out of escrow in a real estate transaction that Mr. Dahl was attempting. This judgment satisfaction was
to satisfy unpaid support from 2002 until March, 2004, during the time that our divorce proceeding was
pending.
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
There was indeed notice to Mr. Dahl with regard to support payments being deficient and
2
requesting make up of unpaid amounts of child support.
I certainly accepted what he paid because it was better than getting nothing on many
5
6
7
occasions. His comments were such as "that is all I have right now and I will make it up to
you."
9. I have requested judgment for interest on the unpaid support in the amount of
$52,307.86. This is calculated on the amounts owed subsequent to the entry of the 2004
Order. No claim is included for interest on the judgment amount form that order of
10
$6031.48. As stated in paragraph 7, (footnote 1) this amount has been satisfied. I have
11
12
calculated interest ascertaining the amount of unpaid support for each year and calculating
interest from the end of that year to the time of filing. The interest calculation is therefore
13
slightly in favor of Mr. Dahl.

14
Signed this __
day of September, 2014, at
15
16
17
18
19
20
21
22
23
24
25
THOMAS A. CENA, JR
Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Fax Server
9/12/2014
2:38:57 PM
PAGE
3/003
2
l certainly accepted what he paid because it was better than getting nothing on many
5
6
occasions. His comments were such as "lhat is nil I have right now and l will make it up to
you."
Order.
10
$6031.48.
II
12
lJ
No claim is included for interest
the judgment amount form that order of
As stated in paragraph 7, (footnote I) this amount has been satisfied. I have
interest from the end of that year to the time of filing, The interest calculation is therefore
14
1s
011
Signed this
1.L. day of September, 2014, at _J.}~~"":...~-~~-------
16
17
&JLL~j_Af . .
JR
-----. - - ---
19
20
21
22
23
24
25
Declaration of Deborah Dahl 6
THOMAS A. CENA, JR.

Attorney at Law
39.29 Bridgeport Way Wesl, 1130

(253) 5725120 Fax.: (253) 593450
.MAIL: TomCSS@11ve111urt:.con
I
L"Ji!!!!iii!~"'c s ma
-~>is!t'!Wl'i!fe/1!!'i!_.,JI
2
3
4
5
6
1
Countyof Pierce
In re:
No. 02-3-02768-6
DEBORAH J. DAHL,
RE FAX TRANSMITTAL
10
Petitioner,
11
and
12
JAMES R. DAHL,
13
Respondent.
14
15
16
SS.
County of Pierce
17
18
19
matter. That I have examined the attached Declaration of Deborah J. Dahl, which is
20
21
22
23
24
25
Affidavit - 1
THOMAS A. CENA, JR
Attorney at La
(253) 572-5120 Fax: (253) 593-4503
being filed with the above-entitled Court.

2
This document consists of nine (9) pages
(including his affidavit) and it is co
3
4
THO i\S A. CENA, R., WSBA NO. 6539

5
6
7
~q day of September, 2014.
\_/r!JiunAA i,~cvJ
k_

Tacoma.
10
5. . u-r,
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Affidavit -2
THOMAS A CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
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~XHIBIT_/~~
North Carolina Report Card

~rj.5,
'2014
'. .
'
.
Winston-Salem/Forsyth County Schools
Dahl, Elizabeth R -12672413
Mount Tabor High School
Dr. Beverly Emory, Superintendent
342 Petree Road

Winston Salem, NC 27106-4400
ade: 11 Homeroom: 1104 Childers Rm 526
ParentsiGuardians
of
Elizabeth Dahl
. 4907 Tiffany Av
vyif1ston-Salem,
~336) 703-6700
Principal: Ed V Weiss
N.C27104 .
. -~~_l!rs!.Jltle _;~~-1.!Q~!!uctor__.
. PRE;CALCULUS HN
FaltynsklPrivette.
..
-. ~ . - .
. .
Carol A
101
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BUilding -
Leaders "
Member Certificate
Elizabeth Dahl
Name
is an active member of the Builders Club at

School/Organization
President
GbtY"t&sj V<:vvter H-lig VI Sek oob
Date
JY1faa ~
Advisor
V7-/J
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Date 2004 Amt. 2004 Date 2005 Amt. 2005 Date 2006 Amt. 2006 Date 2007 Amt. 2007 Date 2008
8/10/04 (P
200
Mar-06
450
Feb-07
928
Jan-08
8/20/2004
400
Apr-06
928
Mar-07
928
Feb-08
Apr-07
928
Mar-08
928
Apr-08
1-May
900
Jun-06
600 6/1/2007
Jun-06
300
Jun-07
464 7 /2008 (foi
Aug-06
400
Jun-07
464 9/2008 (to:
Sep-06
400 11/2007 (f1
Sep-06
Oct-06
Oct-06
Nov-06
Dec-06
400 11/2007 (f1

464
Dec-07
464
928
928
620 10/1/2008
620
Oct-08
620 11/2008 (f1
Amt. 2008 Date 2009 Amt. 2009 Date 2010 Amt. 2010 Date 2011 Amt. 2011 Date 2012 Amt. 2012
620 1/1/2009 (
Unknown
620
Feb-10
400
Jan-11
400
Feb-12
400
2/2009 (Io:
620
Mar-10
500
Apr-11
400
Aug-12
400
620 4/2009 (fo:
620
Aug-10
400
Aug-11
600
Oct-12
400
620 5/1/2009 (
620
Nov-10
300
Sep-12
400
620 6/2009 (fo:
620
Nov-10
300
Dec-12
400
630 8/2009 (fol
620
630
Sep-09
620
725
620
EXHIBIT___
Date 2013 Amt. 2013

1-Mar
1-Sep
Date 2014 Amt. 2014

800
1-Jan 309.38 (For Jan)
309.38 (For April)
1-Sep 309.38 (For May)

1-Sep 309.38 (For June)
1-Sep 309.38 (For July)
1-Aug 309.38 (For Aug)
1-Sep 309.38 (For Sept)
i-o
309.38 (For Oct)
I-Nov 309.38 (For Nov)

30-Dec
309.38 (For Dec)
EXHIBIT
2,__
E-FILED
October 02 2014 8:47 AM
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
4
5
6
8
9
10
11
In re
COUNTY OF PIERCE
NO. 02-3-02768-6
DEBORAH DAHL
Petitioner,
and
[ X] PETITIONER
] RESPONDENT
JAMES DAHL
Respondent.
12
(FNDCLR)
Name: Deborah Dahl
Date of Birth: July 29, 1957
13
14
15
Declarant's Total Monthly Net income (from 3.3 below)
$4,968.46
Declarant's Total Monthly Household Expenses (from 5.9 below)
$4,549.90
16 Declarant's Total Monthly Debt Expenses (from 5.11 below)
$728.00
Declarant's Total Expenses (from 5.12 below)
$5,277.90
17
Estimate of the other party's gross monthly income (from 3.1 g below) [ X]
18
[ l
$4,719.00
unknown

19 2.1 Occupation:
Research Nurse Manager
20 2.2 The highest year of education completed:
18
2.3 Are you presently employed? [ X] Yes
] No
21
a. If yes: (1) Where do you work
22
Wake Forest School of Medicine

Winston-Salem, NC 27157
23
24
25
(2) When did you start work there (month/year)?
January 2013
b. If no: (1) When did you last work (month/year)?

(2) What were your gross monthly earnings?
26
(3) Why are you presently unemployed?
RCW 26.18.220 (1)
LAW OFFICE OF
Thomas A. Cena, Jr.
(253) 572-5120

2
3
If child support is at issue, complete the Washington State Child Support Worksheets, skip paragraphs
3.1 and 3.2. If maintenance, fees, costs or debts are at issue and child support is NOT an issue this
entire section should be completed. (Estimate of other party's income information is optional.)
3.1
6
7
8
9
10
11
GROSS MONTHLY INCOME

If you are paid on a weekly basis, multiply your weekly gross pay by 4.3 to determine your monthly
wages and salaries. If you are paid every two weeks, multiply your gross pay by 2.15. If you are
paid twice monthly, multiply your gross pay by 2. If you are paid once a month, list that amount
a.
b.
c.
d.
e.
f.
g.
Wages and Salaries

Business Income
Spousal Maintenance From Other Relationships
Other Income
Imputed Income
Total Gross Monthly Income (add lines 3.1a through 3.1f)
h. Actual Gross Income (year to date)

3.2 MONTHLY DEDUCTIONS FROM GROSS INCOME
a. Income Taxes
13
b. FICA/Self-employment Taxes
14
c. Fed MED/EE
12
15
d NC Withholding
16
e. Fed OASDI/EE
f. Mandatory Retirement Contributions
g. Voluntary Retirerrent Contributions
17
18
19
h. Normal Business Expenses

i.
Total Deductions from Gross Income (add 3.2a thru 3.2h)
3.3 MONTHLY NET INCOME (line 3.1g minus line 3.2i or

line 3 from the Child Support Worksheets).
20 3.4 MISCELLANEOUS INCOME

21
b. Other miscellaneous income (list source and amounts)
22
\\
23
24
Petitioner
$7,583.33
$0.00
$0.00
$0.00
$0.00
$0.00
$7,583.33
Respondent
$0.00
$0.00
$0.00
$0.00
$0.00
$4,719.00
$4,719.00
$0.00
$0.00
$1,318.76
$0.00
$105.31
$361.00
$450.30
$152.00
$227.50
$622.92
$361.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$2,614.87
$983.92
$4,968.46
$3,735.08
$0.00
$0.00
$0.00
$0.00
\\
\\
\\
\\
25
\\
\\
26
c. Total Miscellaneous Income (add lines 3.4a thorugh 3.4b)
FINANCIAL DECLARATION 2
RCW 26.18.220 (1)
LAW OFFICE OF
Thomas A. Cena, Jr.
(253) 572-5120
3.5 INCOME OF OTHER ADULTS IN HOUSEHOLD

2
3
$0.00
$0.00
$150.00
$0.00
$10,000.00
$0.00
4.3 Stocks and Bonds, cash value of life insurance
$0.00
$0.00
4.4 Other liquid assets
$0.00
$0.00
3.6 If the income of either party is disputed, state monthly income

you believe is correct and explain below:
4
5
4.1
4.2 On deposit in banks
Cash on hand
8
9
10

Monthly expenses for myself and 1 dependents are: (expense should be calculated for the future,
after separation, based on the anticipated residential schedule for the children.)
11 5.1
12
13
HOUSING
Installment payments for other mortgages or encumbrances
Taxes and insurance (if not in monthly payment)
Total Housing
14 5.2 UTILITIES
Heat (gas and oil)
15
Electricity
Water,
sewer, garbage
16
Telephone
17
Cable
Other
18
Total Utilities
19
5.3 FOOD AND SUPPLIES
Food for 2 people
20
Supplies (paper, tobacco, pets)
21
Meals eaten out
Other
22
Total Food and Supplies
23
5.4 CHILDREN
Day Care/Babysitting
24
Clothing
25
Tuition (if any)
other child related expenses
26
Total Expenses Children
RCW 26.18.220 (1)
$700.00
$0.00
$269.77
$969.77
$103.00
$100.00
$83.00
$119.00
$95.00
$46.71
$546.71
$600.00
$75.00
$300.00
$0.00
$975.00
$0.00
$150.00
$281.00
$0.00
$431.00
LAW OFFICE OF
Thomas A. Cena, Jr.
(253) 572-5120
5.5 TRANSPORTATION
Vehicle payments or leases
Vehicle insurance and license
3
Vehicle gas, oil, ordinary maintenance
Parking
4
Other transportation expenses
5
Total Transportation
2
$0.00
$147.74
$500.00
$40.00
$0.00
$687.74
5.6 HEALTH CARE (omit if fully covered)

Insurance
7
Uninsured dental, orthodontic, medical, eye care
Other uninsured health expenses
8
Total Health Care
9 5.7 PERSONAL EXPENSES (not including children)
$249.00
$42.00
$0.00
$291.00
Clothing
Hair care/personal care expenses
Clubs and recreation
Education
Books, newspapers, magazines, photos
10
11
12
$150.00
$50.00
$200.00
$0.00
$70.00
$100.00
Gifts
Other
Total Personal Expenses
13
14
15 5.8
$50.00
$620.00
Life insurance (if not deducted from income)
16
\\
17
\\
18
19
20
21
5.9 TOTAL HOUSEHOLD EXPENSES (the total of paragraphs 5.1 through 5.8)
Creditor
Description
Balance
Last payment
5.11 ADDITIONAL DEBTS AND MONTHLY EXPENSES NOT INCLUDED IN 5.1 THROUGH 5.8
Creditor
1. Allegacy Credit Union
Description
living expenses
23
2. Bank of America
living expenses
24
3. Capitol One
living expenses
26
$28.68
$4,549.90
5.10 INSTALLMENT DEBTS INCLUDED IN PARAGRAPHS 5.1 THROUGH 5.8
22
25
$28.68
Balance
Total Monthly Payments for other Debts and Monthly Expenses

5.12 TOTAL EXPENSES (add paragraphs 5.9 and 5.11)
RCW 26.18.220 (1)
Last payment Monthly amt.
$7,975.00
APR 1,2014
$160.00
$3,000.00
APR 1,2014
$168.00
APR 1,2014
$400.00
$469.00
$728.00
$5,277.90
LAW OFFICE OF
Thomas A. Cena, Jr.
(253) 572-5120
$0.00
6.1 Amount paid for attorney fees and costs to date

2
6.2 The source of this money was
6.3 Fees and costs incurred to date
6.4 Arrangements for attorney fees and costs are
5
6
$0.00
6.5 Other
I declare under penalty of perjury under the laws of the State of Washington that the contents of this
FINANCIAL DECLARATION and ATTACHMENTS are true and correct.
7
8
9
Signed at
on
10
11
Signature
12
Print or Type Name Deborah Dahl
13
The following financial records are being provided to the other party and filed separately with the
court:Financial records pertaining to myself: DO NOT ATTACH THESE FINANCIAL RECORDS TO
14
THE FINANCIAL DECLARATION. THESE FINANCIAL RECORDS SHOULD BE SERVED ON THE
OTHER PARTY AND FILED WITH THE COURT SEPARATELY USING THE SEALED FINANCIAL
15
SOURCE DOCUMENTS COVER SHEET (WPF DRPSCU 09.0220). IF FILED SEPARATELY
USING THE COVER SHEET, THE RECORDS WILL BE SEALED TO PROTECT YOUR PRIVACY
16
(ALTHOUGH THEY WILL BE AVAILABLE TO THE OTHER PARTIES IN THE CASE, THEIR
ATTORNEYS, AND CERTAIN OTHER INTERESTED PERSONS. SEE GR 22 (C)(2)).
17
18
19
20
21
22
23
24
25
26
RCW 26.18.220 (1)
LAW OFFICE OF
Thomas A. Cena, Jr.
3929 Bridgeport Way W ., #304
(253) 572-5120
9/27/2014 10:48:24
Fax Server
6.2 The source of this money was
6.3 Foes and costs Incurred to dato
6.4 Arrangements
PAGE
3/010
6.1 Amount paid for attornoy fees and costs to dato
AM
$0.00
$0.00
for attorney fees and costs are
6.5 Other
I declare under penally of perjury under the laws cf the State of Washington that the contents
or this
FINANCIAL DECLARATION and ATTACHMENTS are true and correct.

7
6
9
Signed at .i)}.n==..L.M,J."'-'-'- ~~)
~"~>U-"~'""'"""t4n~,- on----..t-';;..._d=:......,.~.......u3-"-4-_()[_j__
10
1(\,,
11
Slgnature_ . .
12
~d
/lAAl.___. , _
Print or Type Name Deborah Dahl

13 Tho followlng flnanclal records are being provided to the other party and flied separately with the
court:Flnanclal records pertaining to myself: DO NOT ATTACH THESE FINANCIAL RECORDS TO
14
THE FINANCIAL DECLARATION. THESE FINANCIAL RECORDS SHOULD BE SERVED ON THE
OTHER PARTY AND FILED WITH THE COURT SEPARATELY USING THE SEALED FINANCIAL
15 SOURCE DOCUMENTS COVER SHEET (WPF DRPSCU 09.0220). IF FILl:D SEPARATELY
USING THE COVER SHEET, THE RECORDS WILL BE SEALED TO PROTECT YOUR PRIVACY
16 (ALTHOUGH THEY WILL BE AVAILABLE TO THE OTHER PARTIES IN THE CASE, THEIR
ATIORNEYS, AND CERTAIN OTHER INTERESTED PERSONS. SEE GR 22 (C)(2)).
17
18
19
20
21
22
23
24
25
26
RCW 26.16.220 (1)
LAW OFFICE OP
Tticmuo A. C11na, Jr.
3929 Brtdgeport Wrr;W., 1Kl04
UnlvaralLy f'tllc::a, WA 96486
f'lli"i)
RT? R1'll)
2
3
4
5
6
7

County of Pierce
Inre:
No. 02-3-02768-6
DEBORAH J. DAHL,
10
Petitioner,
RE FAX TRANSMITTAL
11
and
12
JAMES R. DAHL,
13
Res ondent.
14
15
SS.
County of Pierce
16
17
18
19
matter.
20
21
22
That I have
examined the attached Financial Declaration, which is being filed
23
24
25
Affidavit - 1
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
with the above-entitled Court.

2
This document consists of eight (8) pages (including this
affidavit) and it is complete and legible.
3
4

5
6
SUBSCRIBED AND SWORN TO BEFORE ME this /},qday of September, 2014.
'-t?~enM j ~L

Tacoma.
~ 1. I
10
11
-r~.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Affidavit
-2
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
E-FILED
October 02 2014 8:47 AM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
WASHINGTON
STATE CHILD SUPPORT SCHEDULE WORKSHEETS
Proposed by [ X ] DEBORAH DAHL
MOTHER
COUNTY
FATHER
CASE NO.
DEBORAH DAHL
PIERCE
JAMES DAHL
02-3-02768-6
Children and Ages: Elizabeth 17

(child and parent ages calculated using September 26, 2014) (custody with Deborah}
Part I: Income (See Instructions, page 6)
Father
Mother

a. Wages and Salaries
$0.00
$7,583.33
b. Interest and Dividend Income
$0.00
$0.00
c. Business Income
$0.00
$0.00
d. Maintenance
$0.00
$0.00
$0.00
$0.00
Received
e. Other Income
f. Imputed Income
$4,719.00
$0.00
g. Total Monthly Gross Income (add lines 1a through 1f}
$4,719.00
$7,583.33
$622.92
$1,318.76

James: Single, 1 exemption,
[2014 tax table]
O child credits
b. FICA (Social Security plus Medicare)!Self-Employment
-- FED MED/EE
Taxes
$361.00
$0.00
-------------r--------r-------1
~- NC Withholding
Fed OASDI/EE
e.
$0.00
$105.31
$0.00
$361.00
$0.00
$450.30
f. Voluntary Retirement Contributions
g. Mandatory
$0.00
$152.00
---=--=---:---.--;;--~.---------i---~---1--~~~-1
Retirement
Contributidms
1----
h. Normal Business Expenses
$227.50
0.00
i. Total Deductions from Gross Income (add lines 2a through 2h)

3. Monthly Net Income (line 1 g minus line 2i)
$0.00
(add parent's monthly net incomes from line 3)
5. Basic Child Support Obligation (enter total amount in box-->)

Elizabeth
$1,454
0.00
$983.92
$2,614.87
$3,735.08
$4,968.46
$8,703.54
$1,454.00
(presumptive)

(each parent's net income from line 3 divided by line 4)
WSCSS-Worksheets - Mandatory (CSW/CSWP} 07/2013 page 1 of 5
Original
LAW OFFICE OF
2:37PM
Part II: Basic Child Support Obligation
(See Instructions, page 7)
7. Each Parent's Basic Child Support Obligation without consideration of

low income limitations. (Multiply each number on line 6 by line 5)
Father
Mother
$623.91
$830.09
8. Calculating low income limitations: Fill in only those that apply.

Self-Support Reserve: ( 125% of the Federal Poverty Guideline)
a. Is Combined Net Income Less than $1,000? If yes, for each parent
enter the presumptive $50 per child.
b. Is Monthly Net Income Less Than Self-support Reserve? If yes, for that
parent enter the presumptive $50 per child.
c. Is Monthly Net Income equal to or more than Self-support Reserve If yes, for
each parent subtract the self-support reserve from line 3. If that amount is less
than line 7, enter that amount or the presumptive $50 per child, whichever is
reater.
9. Each parent's basic support obligation after calculating applicable limitations.
For each parent enter the lowest amount from line 7, Sa - Sc. but not less than
the presumptive $50 per child.
Part Ill: Health Care, Day Care, and Special Child Rearing Expenses
$1,216.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$623.91
$830.09
(See instructions, page 8)
10 Health Care Expenses

a. Monthly Health Insurance Premiums Paid for Child(ren)
$0.00
$149.00
b. Uninsured Monthly Health Care Expenses Paid for Child(ren)
$0.00
$20.00
c. Total Monthy Health Care Expenses (line 10a plus line 10b)
$0.00
$169.00
$169.00
(add parents's totals from line 10c)
11. Day Care and Special Child Rearing Expenses

a. Day Care Expenses
$0.00
$0.00
b. Education Ex enses
$0.00
$20.00
c. Long Distance Transportation Expenses
$0.00
$94.00
d. Other Special Expenses (describe)
$0.00
$0.00
e. Total Day Care and Special Expenses (add lines 11a through 11d)
$0.00
$114.00
12. Combined Monthly Total of Day Care and Special Expenses

(add parent's day care and special expenses from line 11e)
$114.00
13. Total Health Care, Day Care, and Special Expenses

(line 10d plus line 12)
$283.00
14. Each Parent's Obligation for Health Care, Day Care, and Special Expenses
$121.44
$161.56
$745.35
$991.65
(multiply each number on line 6 by line 13)
15. Gross Child Support Obligation (line 9 plus line 14)

Part V: Child SupportCredits
(See instructions, page 9)
16. Child Support Credits

a. Monthly Health Care Expenses Credit
b. Day Care and Special Expenses Credit
WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2013 page 2 of 5
$0.00
$169.00
$0.00
$114.00
16. Child Support Credits (continued)

c. other Ordinary
Expenses
Father
Mother
Credit (describe)
$0.00
$0.00
d. Total Support Credits (add lines 16a through 16c)
$0.00
$283.00
Part VI: Standard Calculation/Presumptive Transfer Payment (See instructions, page 9)

17. Standard Calculation (line 15 minus 16d or $50 per child whichever is greate
$745.35
$708.65
$1,680.79
$2,235.81
Part VII: AdditionalInformational Calculations

18. 45% of each parent's net income from line 3
19. 25% of each parent's basic support obligation from line 9
$155.98
$207.52
Part VIII: AdditionalFactors for Consideration (See Instructions, page 9)

20. Household Assets (List the present value of all major household assets.)
a. Real Estate
b. Investments
c. Vehicles and Boats
d. Bank Accounts and Cash
e. Retirement Accounts
f. Other (describe)
21.
Household Debt (List liens against household assets, extaordinary debt)
22. other Household Income

a. Income of Current Spouse or Domestic Partner
(If not the other parent of this action.)
Name
Name
Name
Name
c. Gross income from overtime or second jobs the party is
asking the court to exclude per instructions, page 8
d. Income of Children (If considered extraordinary)
Name
Name
Father's
Household
Mother's
Household
22. Other Household
Income (continued)
e. Income From Child Support

Name
Name
f. Income From Assistance Programs
Program
Program
g. Other Income (describe)
23. Non-Recurring Income (describe)
24. Child Support Owed Monthly, for Biological or Legal Child(ren)
25. Other Children Living In Each Household (First names and ages)
Imputed Income (1f) for James Dahl based upon Median Monthly Census Income
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Father's
Household
Mother's
Household
Other Factors For Consideration
(continued)
(attach additionalpages as necessary)
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Signature and Dates

contained in these Worksheets is complete, true and correct.
Father's signature
Mother's signature
Date
City
Date
City
Date
This worksheet has been certified by the State of Washington Administrative Office of the Courts.
2001-14 THOMAS E. JAFFE
9/27/2014 10:48:24
Fax Server
AM
PAGE
4/010
Other F'actors For Consideration (continued) (attach addltlonal pages as necessary)

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Signature and Dates

I declare, under penalty of perjury under the laws of the State of Washington, the Information
contained In these Worksheets Is complete, true and correct.
1MOther'SSiinat~
Father's signature
bf.u21,JrJI tll~
~te
City
J~~------
Date
City
Date
This worksheet has been certified by the State of Washington Administrative Office of the Courts.
Photocopying of the workshoot Is permitted.
WSCSSWoti<shell~ Moodatory (CSW/CSWP) 071201 :I pGga !I of 5
Cl 20G114 'THOMAS E. JAFFI';
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County of Pierce
Inre:
No. 02-3-02768-6
DEBORAH J. DAHL,
RE FAX TRANSMITTAL
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Petitioner,
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and
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JAMES R. DAHL,
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Respondent.
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STATE OF WASHINGTON )
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SS.
County of Pierce
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matter.
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That I have examined the attached Washington State Child Support Schedule
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Affidavit -1
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Worksheets, which is being filed with the above-entitled Court.
This document consists

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t8 q
day of September, 2014.
~unMj,
NOT ARY PUBLIC in and for the

T~oma
C (
My Commission Expires: :; -- ( .--{
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Affidavit
-2
THOMAS A. CENA, JR.

Attorney at Law
(253) 572-5120 Fax: (253) 593-4503
E-FILED
October 08 2014 10:46 AM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
No. 02-3-02768-6
Petitioner(s),
vs.
JAMES R DAHL
Respondent(s)
Phone: (253) 272-0566

Show Cause
Nature of Hearing: Child Support,CHLD~Child Support
CALENDAR DATE: Thursday, December 11, 2014 9:00 AM

DATED:
October 8, 2014.
Signed:
NAME:
Phone:
(253) 572-5120
WSBA#:
For:
6539

1 of 1
E-FILED
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
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4
5
6

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9
10

DEBORAH J. DAHL,
11
12
13
NO. 02-3-02768-6
Petitioner,
and
Motion & Memorandum to Dismiss

Petition, to Remove Attorney Cena, for a
Protection Order regarding Financial
Disclosures to Cena & for Fees
JAMES R. DAHL,
Respondent
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COMES NOW Respondent, James R. Dahl; by and through his attorney of record, Sandra
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E. Johnston, and moves this Court to dismiss the Petition filed by Petitioner on June 10, 2014, as
17
having been recently negotiated and settled almost a year prior on April 1, 2013 and with the
18
assistance of the Honorable Judge Katherine M. Stolz, who now has exclusive jurisdiction on post
19
settlement relief.
20
Respondent further moves that this Court remove and disqualify Attorney Tom Cena from
21
acting as thee opposing party's legal counsel, because Mr. Cena's long ti.me business partner,
22
Attorney Scott Candoo, was Mr. DahPs attorney in this very same matter, having withdrawn herein as
23
recently as January 28, 2013. Certainly Attorneys Candoo and Cena do not make a habit of talcing
24
opposing parties' litigation in their own office. Mr. Dahl claims a conflict based upon former client
25
conflict under RPC 1.9(b), as regardless of the status of the individual businesses of Cando and
MOTION & MEMORANDUM TD DISM1ss Prnr10N, ro
REMOVE ATIORNEY CENA, FOR A PROTECTION ORDER
REGARDING FINANCIAL DISCLOSURES & FOR FEES
Page 1of8

705 s. 9th Street, Suite 104
Phone
253-272-0566; FAX 253-572-4137
Cena. Attorneys Cena and Candoo share financial obligations through shared office space and
reception for over the last two decades. Their financial relationship is so inextricably linked that it
3
4
is the conflict equivalent of two lawyers in the same firm. Further Mr. Cena directly gave Mr. Dahl
legal advice on the matters with the same party he now represents. For example, whenever Mr.
Dahl came into their shared office space, he was directed to speak to Mr. Cena for assistance. Mr.
6
Dahl should not now be forced to share his confidential financial data with an attorney's office that
7
he chose to terminate.
8
9
Finally Respondent moves the Court for the payment of his actual attorney's fees, which he
10
has incurred and will incur as a result of having to defend this matter. An affidavit of fees will be
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submitted regarding the same upon the ruling of this Court.
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Respectfully submitted this I" day of November, 2014.
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MEMORANDUM
1. Matter PreviouslyLitigated & Settled
On November 18, 2003 the parties entered into a CR2A Agreement that was negotiated by
Scott Candoo on behalf of Father and which subsequently allowed Father to make up any back
support obligation with the sale of a real property (Contra Costa rental). See language in paragraph
3.22 of the OCS filed on 3/26/04.
On March 26, 2004, the final Order of Child Support with Worksheets was entered in this
matter pursuant to agreement. It is the current support order under which the parties have operated
for the last 11 years. At that time, Amanda was 14 years old, Sarah was 11, and Elizabeth was 6.
25
MOTION & MEMORANDUM TO DISMISS PETITION, TO
Page 2 of 8

705 S. 9111 Street, Suite 104
Phone 253-272-0566;
FAX 253-572-4137
On September 30, 2005, a satisfaction of judgment for $25,000 was filed by Mother in full
satisfaction of Father's debts for the benefit of Mother. 'Ibis payment was in satisfaction for the
Tacoma rental property that was listed for sale at the conclusion of the divorce on March 26, 2004,
but was not able to be sold. As a courtesy to Mother, Father paid her $25,000 out of his own llO~el
and which was the anticipated value (if any value actually remained at that time in 2005).
On April 26, 2007, Mother filed a Petition to Modify Child Support that was never pursued.
In it she requested additional "child support'' for Amanda while she was going to "live at Mother's
home" and go to college. Amanda dropped out of high school. She did not remain living at her
mother's. Although Elizabeth had increased an age bracket, Petitioner dropped her petition to
10
11
modify child support and for post-secondary support.

In May 2010, Sarah graduated from high school and attempted college. Mother did not ask
12
to modify child support or for post-secondary support. Father paid every other month of college
13
for Sarah until she dropped out.
14
On September 4, 2012, a satisfaction of judgment for $6,522.10 was filed by Mother in full
15
satisfaction of debts by Father for the benefit of Mother. 'Ibis payment cured Father's back child
16
support obligation.
17
On October 25, 2012, Mother filed her Notice of Relocation to move to North Carolina.
18
On December 5, 2012, Respondent filed his Objection to Relocation to Petitioner's Notice
19
20
that she was moving with the child to North Carolina.

On April 1, 2013, the parties appeared before the Honorable Judge Katherine M. Stolz and
21
negotiated a settlement agreement, which included and took into consideration the fees and costs
22
associated with the new travel, concurrent with and in light of, Father's child support obligation.
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On June 10, 2014, Mother filed a Petition for Modification of Support, continuance of child
support, payment of post-secondary support and claimed arrearages over a ten year period from
25

Page 3 of 8

705 S. 9t11 Street, Suite 104
Phone 253-272-0566; FAX
253-572-4137
beginning March 26, 2004 (the entry date of the order of child support) and June 1, 2014 (the month
she filed). Mother is claiming $89,081.32 in child support arrearages!
At the time the OCS was entered in 2004, it was not common practice to list out the
individual child support amounts for the children in the order of support itself. In this case, the
children were listed individually in a Worksheet Synopsis, which designated the amount of support
for each child and which was the first document attached to the order of support.
At the time the order was entered, also included in the child support calculation was a $400
payment for daycare for the three girls. It has been more than 5 years since there was any daycare
utilized for the children herein. Further, the oldest girl was already babysitting her younger sisters at
10
the time of the entry of the child support order. Because Father's percentage of income was 37% as
11
compared to Mother's 63%, his additional payments for daycare accrued at the rate of $154.69 per
12
month. Finally, since circa 2006, Mother has insisted on claiming all three girls as tax deductions,
13
despite the entry of the OCS in 2004 which requires them to share that benefit equally.
14
To go back and try to itemize the inequities in this matter would be nearly impossible.
15
Mother had ample opportunity to bring actions to modify support and/ or to raise this issue during
16
the prior litigation, wherein Father agreed to a fair order that allowed Mother to move to North
17
Carolina. Mother currently works as Research Nurse Manager, RN, MSN for Wake Forrest
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University, School of Medicine. Elizabeth will be allowed to attend school at Wake Forrest at
19
virtually no cost to Elizabeth because her mother is staff at the School of Medicine.
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It is because of these facts that just a year ago, the parties entered an agreed order that
21
allowed the child support payments to remain at what Father was voluntarily paying. Father had
22
reduced his payment to $309.37, exactly 1/3 of the total child support obligation of $928.12, which
23
was the combined support level for all three girls, plus davcare. Technically, Father would have
24
been well within his right to pay .374 % of the total obligation for solely Elizabeth, that is, .374 % of
25
$639 which equals $238.99. Father has paid far and above what his obligation actually was and
REMOVE ATTORNEY CENA, FOR A PROTECTION ORDER
Page 4of 8

705 s. 9th Street, Suite 104
Phone
253-272-0566;
FAX
253-572-4137
allowed Mother to squeeze $25,000 out of him for a Tacoma rental property that ,&1.1 not ha-i.<1. q;~q.nity
2
ill it equal to the $25,000 that she received.
This matter was only recently litigated. Mother had every opportunity to raise the issue of
child support prior to her departure to North Carolina and chose not to do so. The Court should
dismiss because a) it was just recently litigated; b) mother chose not to ask for a new order of child
support; c) the last orders have all been by agreement; and d) because Father has been
extraordinarily reasonable. Father asks the Court to deny Mother any further changes to the ~mom
of support provided by Father, including whether to end support at age 18. TIUs is what the parties
negotiated, agreed to and entered as their final order. It should remain as agreed.
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2. Attorney Cena's Conflict

The following matters were decided by the Washill.gton State Bar Association and were
12
excerpted from another matter, but compiled by Attorney and former Chief Disciplinary Counsel,
13
Washill.gton State Bar Association, Leland Ripley ill his supporting brief thereto.
14
Pierce County
15
Vernon v. Busberg, No. 02-2-10114-9. Affidavit ill Opposition to Defense Motion for
16
Summary Judgment. Opinion included whether a conflict of interest existed.
17
uveridge v. Overby, No. 01-2-043957-8. Affidavit ill Support of Plaintiffs' Counsel's Motion
18
for Order Permitting Representation of Plaintiff, The court disqualified a lawyer
19
based upon a prior representation many years before and a brief conversation with
20
defendant that counsel did not even recall and had nothing to do with current case.
21
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Snohomish County
Hansen v. Leach, No. 02-2-004472-5. Declaration ill Opposition to Defense Motion for
23
Summary Judgment. Opined there was a conflict because lawyer for party to
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transaction acted as escrow for transaction and thus owed duties to both sides of
25
transaction.
Page 5 of 8

Phone 253-272-0566;
FAX 253-572-4137
Wilron v. Dawson, No. 02-2-07593-1. Declaration in Opposition to Motion to Disqualify
Defense Counsel. The motion was based upon an alleged prior attorney client
relationship.
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6
7
8
9
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Cowlitz County
Carrigg v. Cam"gg, No. 03-2-00230-6. Declaration in Support of Disqualification of defense
counsel based upon previous representation of plaintiff.
Grays Harbor County

Batchelder et. al u: Adams et. al Declaration in Opposition to Motion to Exclude Attorney.
The motion was based upon RPC 1. 7 & 1. 9. Also testified at hearing on renewed
motion.
11
Stevens Counnr
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Kane & Curry v. Matting!J. Declaration in Support of Motion to Recuse Attorney. Motion
13
based upon former client conflict under RPC 1.9.
14
United States District Court for the Eastem District of Washington
15
Wilron v. Paafie Forest Trust, No. CS -02-00069-FVS. Declaration in Opposition to Summary
16
Judgment. Offered opinion that there was a conflict of interest because lawyer
17
employed by the trust caused plaintiff to believe that he was also plaintiffs lawyer
18
because he did not adequately explain his role.
19
United States v. Thomas Stanko Marks, CR-02-0138-WFN Declaration in Support to Motion to
20
Dismiss Indictment based upon invalid state conviction. Declaration stated that
21
defense counsel in state court had a conflict of interest in representing two
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defendants and the trial judge failed to adequately inquire about potential conflict.
23
Indictment dismissed with prejudice.
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25

Page 6 of 8

705 S. gth Street, Suite 104
Phone 253-272-0566; FAX 253-572-4137
United States District Court for the Western District of Washington
Kirk Loe v. Vashon Fire & Rescue et. al, No. CV 004-0005-Z. Declaration in Support of
Motion to Disqualify defense law firm, because plaintiff briefly consulted with lawyer
in defense firm. and provided otherwise confidential information which prevented
defense firm. from later representing defendant.
Disqualification of counsel for a "conflict of interest" is premised upon both the need to
protect the attorney/ client relationship and the need to develop and maintain the public's respect
8
9
for and confidence in our legal system. Intercapital Corp u: Intercapital Corp., 41 Wn. App. 9, 700 P.2d
1213, review denied, 104 Wn.2d 1015 (1985), reu'd on other grounds sub nom, first Small Bus. Inv. Co. of Cal
10
u: Intercapital Corp. of Or, 108 Wn.2d 324, 738 P.2d 263 (1987). See also, In re Firestorm 1991, 129
11
Wn.2d 130, 140, 916 P.2d 411 (1996).

12
This interest is similar to the requirement in quasi-judicial matters that the proceeding not
13
only be fair, but also to appear to be fair. The general rule for the appearance of fairness doctrine
14
is that a reasonably prudent and disinterested observer would conclude that the proceeding was fair
15
16
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and impartial. E.g. Medical Disciplinary Board v. Johnston, 99 Wn.2d 466, 663 P.2d 457 (1983).
Herein, Father feels that his confidences are violated because the very attorneys who
18
provided him services in the matter that is herein contested are now representing his wife. It is
19
because of this that the Court should require Attorney Cena to withdraw as counsel for Mother.
20
3. Protection Order from Discovecy
21
Father seeks the Court's protection from having to produce discovery regarding his financial
22
data to Attorney Cena because Father already terminated his financial relationship with Attorney
23
Scott Candoo. Mr. Candoo and Mr. Cena are financially linked. Further, Mr. Cena provided actual
24
advice and counsel to Mr. Dahl during the period of Mr. Candoo's representation in this matter.
25
Because of this, Father should not have to provide confidential financial information to Mr. Cena.
Page 7 of 8

Phone
253-272-0566;
FAX 253-572-4137
4. Attomey's Fees
Father seeks payment of his attorney's fees, to be proven at a later date via an affidavit from
his current counsel. Were this matter to have been raised during the relocation action, it would not
4
5
have likely increased Father's costs in that action. Further, Father believed that this was addressed
during prior litigation. In the negotiated and agreed parenting plan, mother agreed to pay for 75%
of the cost of travel because she earned 75% of the combined incomes. It is mother who should
7
assist father with his legal fees. Notwithstanding the intransigence nature of this motion, Mother
8
has the ability to pay Father's fees and Father needs assistance.
9
10
It is for the following reasons that Father seeks:

11
a. Dismissal of this matter;

12
13
14
b. Removal of Attorney Cena because of his conflict and obligation to Father;

c. Protection from disclosure of financial documents to a conflicted lawyer; and
15
d. Attorney fees and costs, to be proven via affidavit.
16
Respectfully submitted this I" day of November, 2014. --~
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Page 8 of 8

Phone 253-272-0566; FAX 253-572-4137
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IN AND FORTHECOUNTY OF PIERCE
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DEBORAH J. DAHL,
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NO. 02-3-02768-6
Petitioner,
and
ORDER RE DISMISSAL, REMOVAL,

PROTECTION OF FINANCIAL
DISCOVERY & AW ARD OF ATTORNEY
FEES &COSTS
JAMES R. DAHL,
Respondent
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THIS MATTER having come on regularly for hearing before the above-entitled court;
16
and the Respondent appearing in open Court by and through his attorney, Sandra E. Johnston,
17
and the Petitioner appearing, and having heard arguments from counsel, read the motion herein,
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19
and therefore it is
ORDERED that
20
1. Respondent's motion to dismiss this matter is GRANTED I DENIED I GRANTED IN

21
PART;
22
2. Respondent's motion to remove Attorney Cena due to a conflict of interest created by the
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relationship of Mr. Dahl's former counsel herein, that is, Attorney Scott Candoo, is
GRANTED I DENIED;
ORDER RE DISMISSAL, REMOVAL, PROTECTION

OF FINANCIAL DISCOVERY & AW ARD OF
ATTORNEY FEES & COSTS
Page 1 of2

Phone 253-272-0566;
FAX 253-572-4137
DENIED;
3
4
GRANTED IN PART I RESERVED
..5. Resprmden_t is lhereb'y awarded
in Attorney's fees, which shall be
-payable to R.espo:nderrt
oi1or
before
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The Honorable Judge Katherine M. Stolz

21
Presented By;
Agreed as to Form,
Presentation Waived;
Sm1.dm. B. J,C;Jhn'$lOiik/ WSBA #271 p,
Thomas A. Cena I WSBA #6539

22
23
24
AHomey for Respondent

25

OF FINANCIAL DISCOVERY & AWARD OF
A'!"l'ORNEY FEF..S k COSTS
r~g~ 2on

Phone 253-272-0566;
FAX 253-572-4137
E-FILED
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6

DEBORAHJ. DAHL,
NO. 02-3-02768-6
Petitioner,
10
and
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JAMES R. DAHL,
Respondent
12
13
14

ISO MOTIONS TO DISMISS,
REMOVE CONFLICTED COUNSEL,
PROTECT PRODUCTION OF
DOCUMENTS, & AWARD FEES
I, James R. Dahl, do declare as follows. I am competent to testify regarding the contents

herein and make this declaration on personal knowledge. Any attachment hereto is hereby adopted
15
by reference. Any and all assertions that are made in response to this sworn declaration are hereby
16
denied unless I have the ability to specifically address them. Finally, I have reviewed the facts as
17
presented in Ms. Johnston's motion, do affirm those same facts to be accurate and true and do
18
hereby adopt them by reference herein.

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I respectfully ask the Court to dismiss the current Petition filed on June 10, 2014, which I
20
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answered on July 7, 2014. In addition to asking for an increase in child support, the Petition also
sought the following relief on page 3 (with emphasis added),far which I had alreatfy/Jaid on August 9,
2012 and for which Deborah filed a full satisfaction of lien on September 4, 20 12:
1.6.3 Interest on unpaid child support totals $52,30786, which includesthe sum of
$7298.09asinterestuponthe judgment for unpaid child supportof$6.031.48, which
judgment is included in the order of child support filed March 26, 2004.
24
25
DECLARATION OF JAMES R. DAHL ISO MOTIONS

TO DISMISS, REMOVE CONFLICTED COUNSEL,
PROTECT, & AWARD FEES
Page I of9

Phone
253-272-0566;
FAX
253-572-4137
2
3
In addition to the above, I ask the Court to remove Attorney Cena from this matter. Mr.
Cena has an inextricably linked relationship with my former lawyer who represented me on this
very matter until 2013, Attorney Scott Candoo. I should not have to provide sealed confidential
documents to my former lawyer or Mr. Cena. I ask the court to protect me from any financial
5
discovery requests from Mr. Cena.

6
Finally, I seek my legal fees and costs for having to respond to this matter, for which I
7
8
9
already had obtained final reliefover a vear ago.

It was my understanding that when Deborah and I negotiated our last order in 2013, that
10
it was to be the final order ever entered on this matter. During the settlement conference, we
11
discussed financial support, including our health insurances, because my insurance will not
12
provide double coverage, but would have provided out-of-state (but in network) coverage
13
because they are a national company. Deborah chose to not use my insurance, which provides
14
more coverage and is a free benefit to me. Deborah did not want to drop her coverage, even
15
16
after her insurance benefits out. My company would have picked up where Deborah's stopped,
if she would have allowed Elizabeth to transfer to mine.
17
Neither the final dissolution orders and/or subsequent modifications by Deborah have
18
been adjudicated by the trial court. All of our final orders were entered by agreement, including
19
the last order regarding relocation of my child entered on April 1, 2013. The following is a
20
21
22
23
briefhistory of the litigation and how we got to the entry of our last and final order.
Agreements re Financial Obligations
The first big payment of money to Deborah was not related to child support but was
24
given in resolution of a property division. In 2005, after my attempts to sell the Tacoma rental
25
property, Deborah convinced me to just give her the $25,000 out of the house that we figured
Page 2 of9

705 S. gtti Street, Suite 104

Phone
253-272-0566; FAX 253-572-4137
would be her share i(it sold. Deborah complained that she was tired of waiting for "her share"
of the house's equity. So we settled. I gave her what we had figured was the equity in the
3
4
house. I had to take money off credit cards to come up with that lump sum payment, but I made
it happen.
I certainly overpaid Deborah in 2005, because the house would not sell. There was a
6
clause included in our Decree for a lesser payment if the house wasn't worth the equity that we
7
anticipated. Deborah convinced me to go ahead and pay her $25,000, so I did.

8
9
Deborah signed a Quit Claim deed to me on September 24, 2005 for my payment of
10
$25,000 for her interest in the Tacoma rental located at 228 Contra Costa Avenue. See Exhibit
11
A, Quit Claim Deed. She then entered a Full Satisfaction of Judgment two days on September
12
26, 2005 (filed herein on September 30, 2005). Several years later, Deborah started demanding
13
another $25,000 from me on the same property. See Exhibit B, emails from Deborah dated
14
August 28, 2013 and July 22, 2013.
15
History of Child Support payments
16
The first time Deborah moved to modify support was in 2007. Our oldest Amanda was
17
turning 18. Deborah filed to modify support for all three girls and for post-secondary support
18
for Amanda. Amanda dropped out of high school. She never went to college. At that time
19
Sarah was 15 years old and Elizabeth was 10, just about ready to enter a new age bracket.
20
21
Deborah did not pursue the support modification.
22
After Amanda turned 18, that same year, I reduced the total support amount I was
23
paying ($928.12) by a third to $618.75 (for one less dependent child). At the time, I had no idea
24
why Deborah dropped her petition to modify support. Now, almost ten years later, I find out
25
that the reason Deborah dropped her Petition to Modify Support was because I was already
Page 3 of9

705 S. 9th Street, Suite 104
Phone
253-272-0566;
FAX
253-572-4137
2
3
paying far more than/ should have been paying. I didn't know that each child had her own
child support calculated amount and I certainly didn't know that I was still paying my
proportional share for daycare that had long since stopped. Deborah has always been way more
savvy at figuring these things out than I am. I took the simple approach and divided by 3.
5
Because there was a current support modification pending, Deborah had every opportunity to
6
adjust child support and chose not to do so.

7
In 2010, our second daughter, Sarah, graduated high school. Deborah did not bring a
8
9
petition to modify support for Elizabeth or for post-secondary support for Sarah. Instead
10
Deborah and I came to an agreement about post-secondary support for Sarah. I paid every other
11
month for Sarah to attend TCC, until Sarah dropped out. Sarah briefly lived with me on Vashon
12
Island after she turned 18, but she didn't like living so far away from her friends and activities.
13
She was bored at my house. I don't blame her. Vashon is a slow pace life for a teenage girl. At
14
that time Elizabeth was 13 years old. Again, Deborah did not move to modify child support.
15
16
Now that the support wagon is getting ready to run out, Deborah is grasping at ways to
keep me paying her. Deborah didn't tell the Court that she works as the Research Nurse
17
Manager. RN. MSN for Wake Forrest University, School of Medicine and that Elizabeth will
18
get to go to college there virtually free of charge.

19
As of December 31'2014, I should have no further support obligation to Deborah.

20
21
Elizabeth turns 18 on January 1, 2015. If she needs something, she knows that I will help.her, I
22
have assisted my older two daughters as adults whenever they asked. I also currently pay
23
Elizabeth's phone bill, although I am not obligated to do so, and will continue to pay it. I do
24
that for my daughter, not to support Deborah.
25

PROTECT, & AW ARD FEES
Page4 of9

Phone 253-272-0566;
FAX 253-572-4137
2
3
My Overpayments
I have consistently overpaid Deborah pursuant to our original order of support. I did not
realize that I was still paying my percentage for daycare. If the Court dismisses this petition, I
will not seek reimbursement for my overpayments, which I understand I am allowed to do so by

5
law. Additionally, I will also continue to pay the remaining two months of support at $309.48
6
per month, which is the same amount I have been paying since our second daughter, Sarah,
7
came off child support in 2010.

8
9
It may interest the Court to know that Deborah often waits weeks to cash my checks.
10
She has always made more income than I do. It is my understanding that Wake Forrest
11
University paid her to relocate to North Carolina. The truth is that my financial need is greater
12
than Deborah's, as I incurred more debt as a result of our final agreements. My standard of
13
living deteriorated after the divorce; not Deborah's. For example, I only recently was able to
14
get up dry wall in the house where I live. I still have not been able to completely finish it.
15
I am asking that this current petition be deemed an attempt to circumvent our agreement
16
regarding Deborah's relocation, which was done with the assistance of the Honorable Judge
17
Katherine M. Stolz just last year. I am asking your Honor to dismiss it. However, if the Court
18
agrees that a recalculation is appropriate for the duration of my remaining support obligation, I
19
ask the Court to offset any remaining obligation by giving me credit for ten years of daycare
20
21
that was never used and the overpayment beyond what the Worksheet Synopsis required me to
22
pay, which Deborah had ample opportunity to modify but did not do so (probably because my
23
support would have been even less than what I was already paying her!).
24
25
In order to calculate my overpayments, just since September 2012, I took Elizabeth's

basic support obligation of $639 and multiplied it by my .374 percentage, which equals a
Page 5 of9

705 s. 9t11 Street, Suite 104
Phone
253-272-0566;
FAX
253-572-4137
monthly payment of$238.99. See Exhibit C; a spreadsheet of those payments that I made after
the last satisfaction oflien was entered in this matter beginning September 2012. Since
September 2012, I made 26 months of payments or $6,213.74 in overpayments. If the Court
allows this matter to go forward, I ask that I be given a credit for all overpayments that I can
5
prove I made. For purposes of this motion, I have only gone back to September 2012, but can
6
attempt to obtain bank records several years back to cover all those years that Elizabeth was no
7
8
9
10
11
12
longer in daycare. I know that is at least five years, as the same was confirmed to me by our
former daycare provider.
Petition seeks Double Payment for 2004 Judgment
The claimed delinquency of$6,031.86 and interest thereon of$7,298.09 is an attempt to
collect this amount twice and should be sanctioned under CRll.
13
The final agreed order of support entered on March 26, 2004 granted Deborah a
14
judgment for $6031.48 in back child support plus $490.62 in interest. This back support
15
covered a period during the dissolution when I was laid off work and had no funds to pay child
16
support. My attorney, Scott Candoo, recommended that I agree to pay this back amount in
17
order to settle my matter, even though I was not employed when it accrued. Mr. Candoo did not
18
assist me in reducing my obligation during that period. I now understand that my failure to pay
19
support during that time was not contempt because I could not control being laid off and that I
20
21
was entitled to a reduction in support and may have also been entitled to spousal maintenance
22
due to the vast disparity in our incomes. Nonetheless, with Mr. Candoo's assistance, I entered
23
into an agreed obligation and judgment totaling $6522.10.
24
25
On August 9, 2012, I paid Deborah $6,522.10. I was refinancing my real property to try
to get my mortgage payment down to something that I could afford. That is when the old
Page 6 of9

Phone 253-272-0566;
FAX 253-572-4137
1
2
judgment came to my attention. I was only able to pay it off in a lump sum because of my
refinance. On September 4, 2012, Deborah filed a full Satisfaction of Judgment for the same.
This judgment was satisfied two vears ago. I also ask the Court to find that because Deborah
entered a "full satisfaction" through June 20, 2012, it qualifies as a complete satisfaction of any
5
prior debt.
6
Deborah petitioning me to pay a debt that was already satisfied by Deborah is

7
8
9
10
sanctionable and should be sanctioned by this Court under CRH. Further, Mr. Cena had an
obligation to read the court file and discover this satisfaction.
Mr. Candoo withdrew after that satisfaction on January 28, 2013. I never received a
11
final billing from Mr. Candoo, who I expect may be given a copy of this document to read.
12
This one of many examples regarding the manner in which I feel Mr. Cena is conflicted and
13
why I feel violated.
14
15
Our agreed resolution of Deborah's relocation of Elizabeth (who Deborah called

"Rizzy" in Exhibit B) was filed on April 1, 2013. In the final Parenting Plan on page 8 of 10,
16
Deborah was granted sole decision making with the caveat that "neither parent shall
17
unilaterally obligate the other parent to financial expenses." Since that time, Deborah decided
18
to get Elizabeth braces. Braces were not medically required for Elizabeth. Deborah got them
19
for Elizabeth two years ago. Those braces were a purely cosmetic procedure. I told Deborah at
20
21
that time that I could not afford braces. My idea was to drop Elizabeth from Deborah's
22
insurance, at which point my insurance would pick up the balance. I confirmed this with my
23
insurance and told Deborah to send me a confirmation that the dental insurance was dropped.
24
She never got back to me but now is telling me that I owe her the balance of the procedure. I
25
should not have to be ordered to pay for a non-emergent procedure that could have been free to
Page 7 of9

Phone 253-272-0566;
FAX 253-572-4137
me if Deborah had cooperated. It is Deborah's right to do as she pleases, but she should not be
able to create financial obligations for me where none needed to exist; especially {Or a purely
cosmetic procedure.
Further, Deborah's failure to discuss braces with me likely increased her cost. At our
5
settlement conference, we discussed that my insurance would not cover an out-of-state child and
6
that I was not going to be able to continue to carry her. Nonetheless, if Deborah discussed this
7
with me before she unilaterally entered into a contract with a North Carolina dentist, I could
have made arrangements to put Elizabeth back on my dental insurance during the summer and
9
10
gotten her braces done in Washington for substantially less than what Deborah is now
11
demanding I pay her.

Deborah has always maintained a higher standard ofliving than me. Yet, I have
12
13
managed to consistently financially help my older two daughters (Sarah currently living in
14
Germany and Amanda still here in Washington) when they have needed help. I maxed out my
15
credit cards to pay Deborah $25,000 in 2005 and have been slowly digging out of that hole. I
16
was able to pay the agreed child support judgment by for refinancing my real property. I am not
17
happy with the advice I was given in my divorce by Mr. Candoo and now find that I am dealing
18
with the attorney who I was told was his partner and with whom I have previously discussed this
19
very matter. It does not matter whether Mr. Cena remembers what he talked about with me. I
20
certainly remember him. Whenever I stopped by their office, when Mr. Candoo was not
21
available, Mr. Cena helped answer my questions regarding this very matter.
22
Further, because of a change in the way my company complies with federal regulations
23
24
regarding the trucking industry, as of October2014, I am no longer allowed to work the
25
equivalent of 6 days a week. My schedule is reduced to driving no more than 5 days a week, as

Page 8 of9
II

PhOl'le
253-272-0566;
FAA
253-572-4137
2
3
I will now have to count "wait time" as on-duty time. See ExhibitD, letter from Reddaway
(signed original left on file with company). This loss in time and mileage will significantly
reduce my current income. My first paycheck with this reduction will begin in November 2014.
If I am allowed to end support this year (as was anticipated when we entered agreed orders), it
5
will be a wash for me.

6
Finally, I deserve to be free of Deborah and her constant demands and controlling
7
8
9
behavior. This Christmas may be the last time I get to see my child for some time. Pursuant to
the final Parenting Plan which will expire at the end of this year, Elizabeth is supposed to fly
10
out for my visitation on December zo", as that is the day after school lets out. Instead Deborah
11
got her tickets to fly out on the 23rd. Deborah took away three days of visitation with my
12
daughter because it worked out for Deborah to do it that way. It has always been Deborah's
13
way or the highway.
14
15
It is for these reasons that I seek the Court's dismissal of this Petition and to order
Deborah to pay all of my legal fees and costs. I also seek the Court to order that neither Scott
16
Candoo or Tom Cena can ever act again as Deborah's legal counsel should something else
17
come up that causes her to drag me back to Court over our grown children or the conditions of
18
our divorce.
19
20
21
22
Signed and sworn in Tacoma, Washington on this l " day
23
es R. Dahl, Respondent
24
J /-ot - ~o/'f
25

Page 9 of9


Phone 253-272-0566;
FAX 253-572-4137
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BY AGREEMeN'.f.-Ol: ~ P~TIES, THE GRANTOR., DEBORAH J. D.Am., a 11inste oman, for

good and valuablo'consi~on,and in:.ha{mony with a Decree of Dissolution. Pierce County Cauae No .
02-3-02768-6, co~.!Jitd ciuit Gl~1t1;_!0 .fAMES R. DAJll,. a single man, as bis separate property, all of
her interest in the followicis deplbe(ral estate, situated in the County of Pierce, State ofWasbinglon,
together with all aftd-~
titl~-di'1he grantor herein: The Property located at 228 Contra Costa
Aveooe, Tacoma. Washjnaton..9846'furtberlegally described as:
Section l 1 Tow'n.shfji.2fJ~Q2 ~er
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I certify that I know or have satisfactory evidencUhat1)BBbRAH ). DAHL is the person who
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and acknowledged it to
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COUNTY FEE:$0.00
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STATE FEE:$5.00
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Sandra E. Johnston
From:
Sent:
To:
Subject:
[email protected]
Saturday, November 01, 2014 12:58 PM
[email protected]
Fw: Funds from Contra Costa sale
Sent from Yahoo Mail on Android

From: Deborah Dahl <[email protected]>;
To: James Dahl [[email protected]]
<[email protected]>;
Subject: Funds from Contra Costa sale
Sent: Wed, Aug 28, 2013 8:19:54 PM
Jim,
Hope all is well. Now that Rizzy is back to NC and in school, I would like to discuss the repayment of the
money from the sale of the house on Contra Costa. The amount still owed is $25,000. What are your thoughts
on a repayment schedule?
Deb
Sandra E. Johnston
From:
Sent:
To:
Subject:
[email protected]
Saturday, November 01, 2014 1:05 PM
[email protected]
Fw: Re: RE: Rizzy's travel plans for the summer
Sent from Yahoo Mail on Android

From: James Dahl <[email protected]>;
To: [email protected] <[email protected]>;
Subject: Re: RE: Rizzy's travel plans for the summer
Sent: Mon, Jul 22, 2013 9:17:49 PM
Will have to think about it preferably after Elizabeth here and gone. Really have enough on my mind right now
without thinking about that. I know we did little talking about but not much.
From: Deborah Dahl <[email protected]>;
To: [email protected] <[email protected]>;
Subject: RE: Rizzy's travel plans for the summer
Sent: Mon, Jul 22, 2013 8:11:25 PM
Any thoughts about the money from the Contra Costa house?
Deb
Deborah Dahl RN, MSN

Roena B. Kulynych Center for Memory & Cognition Research
Department of Internal Medicine

Division of Gerontology and Geriatric Medicine
Wake Forest University School of Medicine
Medical Center Boulevard, Winston-Salem, NC 27157-1207
Tel: 336-713-3432 I Fax: 336-713-8826
[email protected]
1
DAHL CHECKS/PAYMENTS
CK#
Date
Amount
2025
8/9/2012
$6,522.10
2027
2028
2029
2030
9/23/2012
10/31/2012
11/30/2012
1/1/2013
$400.00
$400.00
$400.00
$400.00
Sept
3/20/2013
$800.00
Jan I Feb
from above]
$542.72
2068
2067
2066
2065
2064
2063
2062
2070
2071
9/1/2013
9/1/2013
9/1/2013
9/1/2013
8/1/2013
9/1/2013
10/1/2013
11/1/2013
12/1/2013
$309.38
$309.38
$309.38
$309.38
$309.38
$309.38
$309.38
$309.38
$309.38
March
April
May
June
July
August
Sept
Oct
Nov
2072
2073
2074
2075
2077
2078
2079
2080
2081
2082
1/20/2014
2/15/2014
3/15/2014
4/30/2014
5/30/2014
6/30/2014
7/30/2014
8/10/2014
9/10/2014
10/31/2014
$309.38
$309.38
$309.38
$309.38
$309.38
$309.38
$309.38
$309.38
$309.38
$309.38
Description
2012
sansra cnon or
Judgement
Oct
Nov
Dec
2013
2018
[overpayments
Dec
2014
Jan
Feb
March
April
May
June
July
August
Sept
Oct
Changesin Child Support
3/26/2004
4/28/2008
6/23/2010
$ 928.12
$ 618.75
$ 306.38
Employee#:
---------
Post and Distribute

DATE:
October 21, 2014
TO:
All drivers
FROM: Dave Yonemoto; Director of Safety
~SUBJECT: Hour of Service - Logging all on duty activities

All of our drivers must comply with the Department of Transportation Hours of Service regulations found
in Part 395 of the Federal Motor Carrier Safety Regulations. Whenever a driver is on duty, the time must
be logged as on duty. All of a driver's time must be logged accurately and in the proper status.
The following is a list of on duty activities as defined in 395.2.
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
All time waiting to be dispatched

All time inspecting (pre-trip, post trip & in-route) a commercial motor vehicle
All driving time as defined in the term driving time;
All time in or on a commercial motor vehicle, other than:
(i) Time spent resting in or on a parked vehicle;
All time loading or unloading, supervising, or assisting in the loading or unloading, attending a commercial
motor vehicle being loaded or unloaded, giving or receiving receipts for shipments;
All time repairing, obtaining assistance, or remaining in attendance upon a disabled commercial motor
vehicle;
All time spent for Drug and Alcohol testing, including travel time to and from the collection site, to comply with
the random, reasonable suspicion, post-crash, or follow-up testing
Performing any other work for Reddaway and
Performing any compensated work for a company even one which is not a motor carrier (e.g., a second job).
A tractor operated without a trailer for personal use (e.g., driving to and from a motel or restaurant for
short distances) is consider being used as personal conveyance. This is an off duty activity and should
be logged as off duty.
These, including the items listed above, are our On Duty activities and must be logged as On duty:
(1) Driving
(5) Breakdowns and attending vehicle as it is
(2) Chargeable wait time
(3) Fueling
(4) Pre-Trip, Post Trip and In-route inspections
being repaired
(6) Loading and unloading
(7) Drop and picks
(8) Road closures
Driver Acknowledgement
I. have received a copy of this memo and understand that I will abide by the DOT Hours of Service
Regulations.
Signature
Print Name
DomicileTenninal
Image to HR
Original filed in employee's terminal file
E,,J_.
&.-1"14 '1f f
/)
Employee#
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
No. 02-3-02768-6
Petitioner(s),
vs.
JAMES R DAHL
Respondent(s)
Phone: (253) 272-0566

Motion
Nature of Hearing: Compel
CALENDAR DATE: Friday, November 14, 2014 9:00 AM

Submitted by:
DATED:
November 4, 2014.
Signed:
NAME:
Phone:
(253) 572-5120
WSBA#:
For:
6539

1 of 1
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7

County of Pierce
In re:
DEBORAH J. DAHL,
Petitioner,
10
and
11
MOTION OF PETITIONER TO
COMPEL DISCOVERY
JAMES R. DAHL,
12
Respondent.
13
14
No. 02-3-02768-6
COMES NOW Petitioner, DEBORAH J. DAHL, by and through her attorney,

THOMAS A. CENA, JR., and moves this Court, under Civil Rule 37, for an order compelling
15
the Respondent to immediately comply with the Requests for Production of Documents
16
submitted by the Petitioner, dated September 16, 2014.

17
Petitioner further moves for an award of her reasonable attorney fees incurred in the
18
19
20
21
preparation and presentation of the instant motion.
I
I
22
23
24
25
Motion of Petitioner to Compel Discovery-I
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
This Motion
2
is based upon the files and records
of this proceeding
and upon the
declaration of Petitioner's counsel submitted herewith.
3
4
5

6
7
8
DECLARATION OF COUNSEL
9
10
I, THOMAS A. CENA, JR., do hereby certify and declare, under penalty of perjury,
11
under the laws of the State of Washington, that the following statements are true and correct, to
12
the best of my knowledge and belief.
13
1. The requested discovery concerns the Petition of Deborah Dahl, the Petitioner, for
14
modification of support, filed June 10, 2014. That matter is scheduled for hearing before the
15
Commissioner on December 11, 2014.
16
17
2.
The requested discovery is for production of documents comprising the
Respondent's paystubs for the previous six months, and his federal tax returns for tax years
18
2011, 2012 and 2013 (Exhibit 1).
The attorney for Respondent received the request for
19
document production on September 17, 2014 (Exhibit 2).

20
3.
Counsel for Petitioner received no objection to the production of these requested
21
22
23
24
25
Motion of Petitioner to Compel Discovery -2
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
documents within the 30 day period prescribed under CR 34(b)(3)(A).

2
3
4
Also, attorney for
Respondent forwarded an email dated October 6, 2014 (Exhibit 3) stating "I will get in touch
with Mr. Dahl and let you know regarding the discovery issue."
4. Petitioner's counsel forwarded a letter to the Respondent's attorney (Exhibit 4)
asking for the documents requested on October 30, 2014. The attorney for Respondent received
6
this letter on October 31, 2014 (Exhibit 5). This was done prior to Petitioner's receiving notice
7
that Respondent was seeking to avoid providing this discovery material, as stated in his motion
8
9
10
for protection order regarding financial disclosures November 1, 2014.

5.
Petitioner herein requests the Court to order Respondent to immediately comply
11
with Petitioner's request for document production. It is submitted that, under the circumstances
12
of the instant matter, the requirement of a previously held rule 26(i) conference, be waived.
13
14
15
6. Petitioner requests the Court to award to her reasonable attorney fees in connection
with the preparation and presentation of this motion.
Signed this 4th day of
14 at University Place, Washington.
16
17
18
19
20
21
22
23
24
25
Motion of Petitioner to Compel Discovery -3
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
2
3
4
5
6

County of Pierce
In re:
DEBORAH J. DAHL,
and
No. 02-3-02768-6
Petitioner,
I0
JAMES R. DAHL,
11
PETITIONER'S REQUEST FOR

PRODUCTION OF
DOCUMENTS
Respondent.
12
TO:
13
AND TO:
SANDRA E. JOHNSTON, Respondent's Attorney
14
YOU AND EACH OF YOU are hereby requested, pursuant to the Rules of Superior
15
Court, Rule 34, to furnish the undersigned attorney, legible copies of the following documents
16
in your possession or control:

17
1.
All pay stubs for the previous six (6) months;
18
2.
years, 2011, 2012 and 2013.
19
20
21
OMAS A CENA, JR., WSBA NO. 6539

22
23
24
25
Petitioner's
Request for Production
I
EGUBIT--......,.,.,..,.
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120
Fax: (253) 593-4503
E-MAJL: [email protected]
oo+
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ss avrcs s : )
www.abclegal.com
SEATTLE
TACOMA
EVERETT
OLYMPIA
(206) 521-9000
(253) 383-1791
(425) 258-4591
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FIRM NAME
PHONE
THOMAS A. CENA,
BELLEVUE
JR.
EMAIL (SECRETARY)
EXT.#
253-572-5120
ADDRESS
ATTY
3929 BRIDGEPORT WAY WEST. #304, UNIVERSITY PLACE, WA
Cena
SECRETARY
Rhonda
YOUR ABC ACCT. No.
CASE NAME
dahl
DAH
CAUSE NO.
CLIENT MATTER#
DATE
9/16/2014
8:27 AM
DOCUMENTS
PETITINER'S
REQUEST FOR PRODUCTION OF DOCUMENTS
TURN CONFORMED ABC SUP DNLY
0RETURNCONFORMED COPY
DcoNFORM OR1G1NAL Do NOT F1LE
SANDRA E. J
ATTORNEY A LAW
705 SO. 9TH S REET, SUTIE 104
TACOMA
SUPERIOR
COURT
DISTRICT COURT
(INDICATE DISTRICT)
Appeals COURT
FEDERAL COURT
AUDITOR
1-(SEA)
11-(TAC)
CIVIL
BANKRUPTCY
SE
A
TAC
D D
STATE
SUPREME
COURT
SEC.
STATE
CORP.
ABC Legal Services, Inc. (ABC) assumes no liability for errors caused in whole or in part by the improper filling out of this messenger service request form, including but not limited to, omission of a last
day date/time, filings not marked in the proper and designated filing boxes, illegible pnnt or script, etc. All messenger requests are double-checked for accuracy and completion prior to returning to the
requester, however: it is the responsibility of the requester to also check the completed request form for accuracy and to notify us immediately if there are any questions or discrepancies. Usage of this
form constitutes a contract between lhe requester and ABC and acknowledgment and acceptance by the requestor of lhe terms set forth above.
THIS FORM NOT FOR PROCESS

011G{07/0B)
S[p 1 7 A.M.
EXHIBIT
_.,_ --. .
10/6/2014
AOL Mail - Print Message
From:
To:
Subject:
Date:
Tom Cena <[email protected]>

rtbirdmom <[email protected]>; 'Deborah Dahl' <[email protected]>
FW: In re Dahl - scheduling
Mon, 6 Oct 2014 12:00 pm
FYI
From: Sandra E. Johnston [mailto:sej0)tacomatrialwa1Tior.com]

Sent: Monday, October 06, 2014 11:06 AM
To: 'Tom Cena'
Subject: RE: In re Dahl - scheduling
Thank you.
I will get in touch with Mr. Dahl and let you know regarding the discovery issue.
Kind Regards,
Sandra E. Johnston
Attorney At Law
Office: 253-272-0566
Fax: 253-572-4137
From: Tom Cena [mailto:[email protected]]

Sent: Monday, October 06, 2014 9:59 AM
To: 'Sandra E. Johnston'
Subject: RE: In re Dahl - scheduling
https://mail
.aol.com/38771-416/aol-6/en-us/Lite/PrintMessage
DHIBIT-~~~
.aspxPuser=dfc
1 pdE l-8z& folder=NewMail&uid=29806603
1/3
Law Office of
THOMAS A. CENA, JR.

Phone: (253) 572-5120
Fax: (253) 593-4503
E-Mail: [email protected]
October 30, 2014
Ms. Sandra Johnston

Attorney at Law
818 So. Yakima Ave., Suite201
Tacoma, WA 98405
RE:
Marriage of Dahl
Pierce County Cause No. 02-3-02768-6
Dear Ms. Johnston:]

I noticed that we show your receipt of our Request for Production of Documents, that request being
dated September 16, 2014, being received by you on the 1 i11 of that month. As of yet, I have received
no response with respect to that request. Would you please supply the documents requested at your very
earliest opportunity. Alternatively, we should participate in a Rule 26(i) conference by phone
concerning this discovery request.
Thank you for your prompt response.
Very truly yours,
THOMAS A. CENA, JR.

TAC/rd
Cc: Deborah Dahl
D:MIBIT_L/
__
ooo)curn """"'')
www.abclegal.com
SEATTLE
TACOMA
EVERETT
OLYMPIA
BELLEVUE
(206) 521-9000
(253) 383-1791
(425) 258-4591
(360) 754-6595
(425) 455-0102
PORTLAND
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LOS ANGELES
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(415) 908-3800
(213)
(714) 541-4133
(619) 232-1920
SACRAMENTO
STOCKTON
VAN NUYS
VENTURA
RANCHOCUCAMONGA
(916) 449-8990
(209) 937-0348
(818) 787-0422
(805) 477-4321
(909) 919-2435
621-9999
EXT.#
FIRM NAME
PHONE
THOMAS A. CENA, JR.
253-572-5120
EMAIL (SECRETARY)
ATTY
ADDRESS
3929 BRIDGEPORT
WAY WEST.
#304,
UNIVERSITY PLACE, WA
SECRETARY
Cena
Rhonda
CASE NAME
YOUR ABC ACCT. NO.
Dahl
CLIENT MA TIER#
CAUSE NO.
DATE
10/30/2014 4:07 PM
DOCUMENTS
LETTER TO SANDRA JOHNSTON
SIGNATURE
REQUIRED
,0"'-', 31
0
ON DOCUMENTS
RETURN CONFORMED
ABC SLIP DNL Y
0RETURN
CONFORMED
COPY
LJu
OcoNFORM
OR1G1NAL
Do NoT FILE
OTHER INSTRUCTIONS
ice ors
SANDRA JOHNSTON
ATTORNEY AT LAW
818 SOUTH YAKIMA, SUITE
TACOMA
705 S. 9th Stre~

E. Joi.... ~
2
Tacorna W. t, Su;te 104 ~INlOIJ
53-2l2-os55.'
)\ 98405
201
,Fax.: 2
COUNTY
SUPERIOR
COURT
DISTRICT COURT
(INDICATE DISTRICT)
Appeals
COURT
FEDERAL COURT
AUDITOR
1-(SEA)
11-(TAC)
CIVIL
BANKRUPTCY
SE
A
TAC
D D
STATE
SUPREME
COURT
SEC.
STATE
CORP.
ABC Legal Services. Inc. (ABC) assumes no liability for errors caused in whole or in part by the improper filling out of this messenger service request form, including but not limited to, omission of a last
day date/time, filings not marked in the proper and designated filing boxes, illegible print or script, etc. All messenger requests are double-checked
for accuracy and completion prior to returning to the
requester, however; it is the responsibility of the requester to also check the completed request form for accuracy and to notify us immediately if there are any questions or discrepancies. Usage of this
form constitutes
a contract between
the requester
and ABC and acknowledgment
and acceptance
by the requester
of the terms set forth above.
THIS FORM NOT FOR PROCESS

011G(07108)
EXMIBIT-b
E-FILED
November 04 2014 2:43 PM
.:!.
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5

6
7
DEBORAHJ. DAHL,
NO. 02-3-02768-6
Petitioner,
and
10
JAMES R. DAHL,
Respondent
11
12
13
14
15
OBJECTION, REQUEST FOR CRt 1

SANCTIONS/FEES, & DECLARATION
OF COUNSEL RE MOTION TO COMPEL
DISCOVERY
Comes now Respondent James R. Dahl in Objection to the motion to compel discovery
and moves the Court to dismiss said motion as 1) it is not ripe, 2) a CR26(i) conference has not
been held by Petitioner's own admissions, and 3) Mr. Dahl's discovery is ready but awaiting Judge
Stolz' ruling, as her order may render said production moot. Specifically, Mr. Dahl challenges
16
whether he must provide private financial data to a firm who had assisted Attorney Scott Candoo,
17
who Mr. Dahl previously fired, in light of the fact Mr. Cena advised him in this very matter.
18
Mr. Dahl respectfully seeks CRt 1 sanctions, attorney's fees and costs for having to respond
19
prematurely to this motion. The information requested from him is the same information that Mr.
20
Dahl will have to provide in response to Temporary Orders, but only if this matter is not dismissed
21
22
23
and not likely to Attorney Cena who has provided my client legal advice on this very matter.
Respectfully Submitted this 4th day of Novemb
, 014 in Tacom
24
WSBA#27313
25
OBJECTION, REQUEST FOR CRl l SANCTIONS/

FEES, & DECLARATION OF COUNSEL RE MOTION
TO COMPEL DISCOVERY
Page 1 of2

Phone
253-272-0566;
FAX
253-572-4137
1
2
I, Sandra E. Johnston, Attorney for Respondent, James R. Dahl, do hereby declare as
follews, I make this declaration as to personal knowledge and am over the age of 18.
Mr. Cena and I initially spoke about the conflict of interest Mr. Dahl asserted back when
5
6
concerns that his representation was conflicted. I assumed that Petitioner's lengthy delay in
7
seeking temporary orders was related to Attorney Cena's investigation of whether there was a
8
conflict. Certainly Mr. Dahl believes there to be one; (}s:pec.iiiUy ia li.ght

1
10
of the-. fille1E tbat Mr
OaJtl
remembers previously having conversations with Mr. Cena about this matter. Further, Mr. Cena
11
admitted to me that he and Mr. Candoo spoke about the matter. It is Mr. Dahl's assertion that
12
Mr. Cena.cannot now represent his wife in opposition to a former client's interests.
13
The email that I sent to Mr. Cena was meant to indicate whether Mr. Dahl objected to Mr.
14
Cena h;:ivi:og Mr. IJaJbl,s cunfidentini and' sealed fi11am::i;.il da.t~:. Mr. D~hl bad a rigbt to fire J:ij's.
15
prier counsels without having to share this confidential information thereafter.
16
17
Certainly, if the Court denies his request to dismiss Petitioner's request for more money,
Mr. Dahl will be required to provide sealed financial data. He is prepared to do so. He just
18
should not be required to provide it to a conflicted attorney prior to the Court's ruling. It is for
19
these reasons that Mr. Dahl seeks the Court's award ofCRl 1 sanctions, attorney's fees and
costs,
20
21
22
23
foregt.ii:ng is true and correct to the best of my knowledge.

Signed and sworn in Tacoma, Washington on this 4th day of November, 2014.
24
25
OBJECTION, REQUEST FOR CRl 1 SANCTIONS/

FEES, & DECLARATION OF COUNSEL RE MOTION
TO COMPEL DISCOVERY
'Pege:l of2

Phone
253-272-0566;
FAX 253-572-4137
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7
8
9
10

County of Pierce
Deborah J. Dahl,
11
12
13
Petitioner,
and
James R. Dahl
Res ondent.
14
I. Motion
15
16
No. 14-3-02632-2
MEMORANDUM IN RESPONSE
TO MOTION TO DISMISS
PETITION
Respondent filed a motion to dismiss the Petition for Modification of Child Support, to remove
17
Attorney Cena, grant a Protection Order Regarding Financial Disclosures, and attorney fees. Based on the
18
following, that motion should be denied.
19
II. Basis
20
Respondent filed a motion asking to dismiss the petition, remove Attorney Cena, issue a
21
22
23
24
protection order regarding financial disclosures, and awarding Respondent attorney fees. Each of these
shall be addressed in tum.
Motion to Dismiss Petition
25
Petitioner filed a Petition for Modification of Child Support to adjust the transfer payment and
26
seek Post-Secondary support for the youngest child. Respondent asks this court to dismiss that petition
27
.
28
- Page - 1 -
THOMASA. CENA,JR.
Attorney at Law
3929 Bridgeport Way W, Ste 304
(253) 572-5120
based on arguments of no past due child support being owed and Petitioner, and for Petitioner's failure to
ask for this modification during the relocation proceedings recently before the court. By necessity, these
arguments must fail.
4
5
6
Petitioner is legally allowed to seek modification for post-secondary. This right was specifically
reserved in Section 3.14 of the March 26, 2004 Order of Child Support, as long as it was exercised prior
to termination of support. The child is currently 17, turning 18 on January 1, 2015, and due to graduate
7
spring of 2015. This request was clearly exercised prior to termination of support, which terminates, as
8
per the 3/26/04 order, once the child turns 18, which is not until 111/15.
9
10
Petitioner is under no obligation to ask for post-secondary at Respondent's convenience. Nor is
11
she obligated to seek post-secondary in any year other than senior year. Respondent argues that when the
12
parties were recently before the court, Petition should have sought post-secondary support. To bring an
13
action for post-secondary at such an early stage is premature and open to multiple issues, the least being
14
whether the child is attending or was accepted to college. Post-secondary requests are routinely sought
15
during a senior year. Here, Petitioner started her action late in the child's junior year.
16
17
18
The argument of whether or not past due support is owed is not before the court in this motion,
nor would it be relevant if it was. Past due support has no bearing on the ability to bring a legitimate
modification petition. As established, Petitioner has the legal right to seek post-secondary support. It also
19
should not be dismissed because Respondent may or may not owe past support, which has yet to be
20
21
22
23
24
25
26
determined. Finally, Petitioner's action includes a request to modify prospective support in addition to its
request to provide post-secondary support and determine past due child support. Respondent's arguments
supporting a motion to dismiss are in error.
Motion to Remove Attorney Cena
Respondent asks this court to remove Attorney Cena for reasons that show no prejudice to
himself and which appear to be wholly self-serving. Respondent, through his attorney, makes several
27
Page - 2 -
28
THOMASA. CENA,JR.
Attorney at Law
(253) 572-5120
questionable statements and provides no competent cited authority on the issue. This Motion by the
Respondent should be denied
Respondent alleges he met and spoke with Attorney Cena regarding his matter. He claims to
have a recollection of such events happening approximately 10 years ago. The Respondent however
5
6
supports this with nothing but his own self-serving statements. In fact, attorney Cena has seldom, if ever,
spoken to Attorney Candoo's clients in Candoo's absence. To the extent this has ever happened, it would
7
have tended to be in the nature of an emergency, not routine, discussion regarding legal advice. He also
8
has no evidence to support his claims, merely his own self-serving statements. Attorney Cena and
9
10
11
12
13
Attorney Candoo have worked only on one case together in their 19 years of office sharing. This matter
was completely unrelated to the instant case and was sent out to another law office after preliminary
discussions between attorneys and clients before any complaint or claim for damages was filed.
Attorney Cena has absolutely no recollection with regard to any conversations with Respondent.
14
He has never viewed the file or files from Attorney Candoo' s representation of the Respondent. Attorney
15
Cena and Attorney Candoo have shared office space but have been completely legally separate for all of
16
the time that they have occupied the same office suite. They have had, for the entire time, separate
17
18
assistants and staff and have kept their files in separate areas of the office space. At this time, any
remaining documents or files that Attorney Candoo retains concerning the Respondent, are kept in a
19
storage area separate from the shared office space. Attorney Cena has no access to that area. As such,
20
21
22
23
there is no conflict based on the Respondent's assertion that he met and spoke with Attorney Cena. If
theoretically such a conversation existed, any conflict would be involving Attorney Cena's representing
the Petitioner. The Petitioner in this matter has been aware of the office sharing arrangement between
24
Attorney Cena and Attorney Candoo from the beginning of Attorney Cena's representation of her. She
25
specifically has requested Attorney Cena to represent her. She has no concerns whatsoever that her
26
27
- Page - 3 -
28
THOMAS A. CENA,JR.
Attorney at Law
(253) 572-5120
representation by Attorney Cena would or will be compromised in any way by the fact that he shares
office space with the Respondent's former attorney.
3
4
5
6
Opposing counsel then argues that Attorney Cena and Attorney Candoo are longtime business
partners, yet two sentences later acknowledges their separate business statuses. Attorneys Cena and
Candoo are not business partners. They are each separate legal business entities, as evidenced by a
Washington State corporation search.
7
Opposing counsel also cites their shared financial obligations and claims they have an
8
9
10
11
inextricably linked fmancial relationship. In fact, the financial circumstances, including bank accounts,
payroll, taxes, insurance, association dues and all other financial matters are completely separate. The
only relationship between the two attorneys are that they are co-tenants on the lease for their office space
12
and jointly rent space to a sub-letting sole practitioner attorney. The only joint contribution that is made
13
is for the monthly lease payment and for the purchase of office supplies.
14
Respondent cites ten trial court cases as authority to support his motion to dismiss attorney Cena.
15
Petitioner has been unable to access the Washington State Superior Court cases in any county other than
16
that of Pierce County. The two Pierce County cases cited by Respondent are Vernon v. Buds berg, 02-2-
17
18
0114-9 and Loveridge v. Overby, 01-2-04395-7. The former case, Vernon, dealt with an attorney who
billed and received money from two clients with adverse interests in one case. The second, Loveridge,
19
dealt with a motion to dismiss an attorney based on prior representation. Attorney Cena has never
20
21
22
represented the Respondent in this matter.1 Respondent's authority is either inapplicable, irrelevant, or
definitively not authority.
With respect to the cases referred to above, there is no explanation of the facts, no application of
23
24
the facts, no argument, or application of the argument to the current case. In fact, Respondent does not
25
26
27
28
Attempts will be made to review the federal cases if time permits.

' Page - 4 -
THOMAS A. CENA, JR.
Attorney at Law
(253) 572-5120
reference the ruling in the majority of her cited cases, but instead refers to affidavits or declarations. As
such, Respondent's motion to dismiss Attorney Cena must be denied.
Respondent discusses briefly discusses the standard for a disqualification for conflict of interest,
based on cited case law. However, none of the cases cited by opposing counsel are particularly on point.
5
6
Nor does opposing counsel actually cite language from the proffered cases with directive citations.
Intercapital dealt with an attorney who had actually met with potential clients for 2 hours, discussing
7
pertinent details and confidential information, before declining representation due to already representing
8
another client against the same defendant. That attorney was then associated with the law firm later
9
10
representing the defendant. Plaintiff moved for disqualification based on the previous meeting. The court
11
ruled both the attorney and law firm should be disqualified, do to access to confidential information.
12
Attorney Cena has no memory of ever talking to the Respondent and believes that he never did so.
13
Attorney Cena did not receive confidential information, nor had access to any confidential information,
14
as Attorney Candoo's files were maintained apart from Attorney Cena's.
15
First Small Bus. Inv. Co. of Cal. was a consolidated case with Intercapital heard by the
16
17
18
Washington Supreme Court. They overturned the appeal court's decision regarding disqualification based
on the standard that "there is no evidence McDonald or Jones,Grey and Bayley used any confidential
19
information obtained from ICO." First Small Bus. Inv. Co. of Calv. Intercapital Corp. of Or, 108 Wn.2d
20
324, 332 (1987). Again, this case is distinguishable because there has been no use of confidential
21
information obtained by Attorney Candoo, nor evidence that such use has occurred. Nor has there been a
22
specific allegation that Respondent provided any confidential information to Attorney Cena. Indeed, it
23
should be noted that there are no details regarding such a conversation, or what information Respondent
24
supposedly gave Attorney Cena .
25
26
27
28
Firestorm addressed a situation where disqualification was ordered because plaintiff's attorneys
met with an expert that the Defendant claimed was their expert. The lower court ordered disqualification,
- Page - 5 THOMAS A. CENA, JR.
Attorney at Law
(253) 572-5120
but the appeals court reinstated the representation, based on the expert approaching plaintiff's attorneys,
and exigent circumstances. Again, this case is distinguishable because there is no use of expert witnesses
retained by opposing party.
4
Finally, opposing counsel cites a case that is clearly indistinguishable from the motion at hand.
5
6
Johnston dealt with a disciplinary proceeding by the Washington State Medical Disciplinary Board, a
quasi-judicial proceeding. Counsel, nor the court, should be in the habit of applying non-judicial
standards to judicial proceedings. Counsel is perplexed how such a case is relevant, and cannot even look
to opposing counsel's argument or application of said case, as there is none. Johnston facts were that 3
10
members of the 7 member disciplinary board had investigative powers, or were involved to a degree in
11
the investigation. In upholding the board's findings, the court stated that, alone, having investigative and
12
13
adjudicative powers was not enough to substantiate an allegation of violating the appearance of fairness.
E.g. Medical Disciplnary Board v. Johnston, 99 Wn.2d 466, 479 (1983).
14
15
ProtectionOrder
Respondent asks for a protection order from discovery so as not to tum over his financial
16
17
documents to counsel. This issue is inextricably tied in to the motion to dismiss, so much so that if the
18
motion to dismiss Attorney Cena is denied, the protection order, by necessity, must be denied. If the court
19
20
chooses to dismiss Attorney Cena, counsel concedes that there would be no objection to a protection
order from discovery, but also no requirement for one as well, since he would no longer be attached to the
21
case.
22
AttorneyFees
23
24
25
Respondent lastly seeks attorney fees of an undisclosed amount. Respondent's motion is brought
in error, is frivolous and should be denied. Consequently, Petitioner should be awarded her reasonable
26
attorney fees in connection with her response to the motion of Respondent.
27
above, this motion is baseless and must needs be denied. Respondent's motion is frivolous, vindictive,
Page - 6 THOMAS A. CENA, JR.
Attorney at Law
3929 Bridgeport WayW, Ste 304
(253) 572-5120
28
As has been established
serves no aim other than to frustrate a legitimate proceeding, and completely baseless. Any award of
attorney fees should be to Petitioner for having to respond to-sueh- ridiculous motion.
3
4
Dated: November 7, 2014

ena, Jr., WSBA #6539
5
6
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, - Page - 7 -
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THOMAS A. CENA, JR.

Attorney at Law
(253) 572-5120
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7
County of Pierce
In re:
DEBORAH J. DAHL,
10
11
Petitioner,
and
JAMES R. DAHL,
12
13
14
15
No. 02-3-02768-6
Respondent.
FOR PETITIONER IN
RESPONSE TO THE MOTION
OF REPONDENT TO REMOVE
ATTORNEY FOR PETITIONER
I, THOMAS A. CENA, JR., do hereby certify and declare, under penalty of perjury,
under the laws of the State of Washington, that the following statements are true and correct, to
the best of my knowledge and belief.
16
1. Attorney Scott Candoo and I have shared office space, in four locations, for about 19
17
years. We have always been legally separate. We have worked together on only one matter,
18
19
20
about 10 years ago. That concerned preliminary work on a claim against a state agency. That
process and collaboration ended when the clients decided to engage another law firm. The
21
clients sought and found their new attorneys themselves.
We did not refer the matter to new
22
counsel or participate in any way after the clients left our office.
23
24
25
Declaration of Counsel -1
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
2.
2
3
4
Since we have separate practices, Mr. Candoo and I seldom, if ever, discuss legal
matters with the clients of the other attorney. The only circumstances which normally would
cause this to happen would be if the attorney who represented the client was unavailable, and
the situation constituted an emergency.
3. I have absolutely no recollection of ever discussing Mr. Dahl's matter with him. I
6
further very much doubt whether I did so. hi the very unlikely event that I did talk to him, I
7
retain absolutely no recollection of any such conversation. I further have no knowledge of any
8
9
10
fact whatever which Mr. Dahl intended to be confidential, or knowledge of any fact from any
such possible conversation at all.
I have absolutely no information which I would have acquired by reason of my office
11
12
sharing with Scott Candoo which in any way would prejudice Mr. Dahl.
4. The representation of Ms. Dahl began in the Spring of 2014. She knew Mr. Candoo
13
14
was Mr. Dahl's former attorney. She had no objection to my representing her in the present
15
matter.
16
17
I was contacted by counsel for the Respondent shortly after my representation of Ms.
Dahl began. I disagreed with counsel as to whether I was entitled to continue to represent Ms.
18
Dahl.
19
The allegations which have been filed in the past one or two weeks, concerning my
20
alleged conversations with Mr. Dahl were never mentioned until the current motion was filed,
21
22
on November 2, 2014. It seems odd that, if Mr. Dahl remembered conversations with me, that
23
24
25
Declaration of Counsel -2
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
the first allegations of such were made more than five months after my representation of Ms.
2
3
4
Dahl began.
5.
I have absolutely no recollection of having any conversation with Mr. Dahl or ever
having met him. I am informed that any remaining files or records concerning Mr. Candoo's
representation of Mr. Dahl are no longer in our shared office space. They moreover were absent
6
from the office space when I began my representation of Ms. Dahl. These are located in a
7
storage location maintained by Mr. Candoo to which I have no access.

8
9
10
11
I have never under any circumstances viewed any file or record which was maintained
or developed concerning Mr. Candoo's representing Mr. Dahl.
Signed this fJ_ day of November, 2014 at University Place, Washington.
12
13
14

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21
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25
Declaration
of Counsel -3
THOMAS A CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
4
5
6
7

County of Pierce
Inre:
DEBORAH J. DAHL,
No. 02-3-02768-6
Petitioner,
10
and
11
DECLARATION OF FORMER
COUNSEL FOR RESPONDENT
JAMES R. DAHL,
12
Respondent.
13
14
15
16
17
Scott Candoo hereby declares under penalty of perjury by the laws of the state of
Washington following is true and correct:
I did represent James R. Dahl in 2003. During that time opposing party was Craig Beetham
and, as I recall, the matter was resolved in mediation Pierce County Center for Dispute Resolution.
To the best of my recollection at no time did I seek legal advice from Mr. Thomas Cena.
I have reviewed the declaration of Mr. Cena and agree with his description of our legal
18
interaction.
19
He and I have not discussed this case whatsoever. My file in this matter has been closed and
20
21
22
in storage for over a decade. Further, I've not discussthis with Mr. Cena whatsoever and I have no
independent recollection of any of the issues in this case.
23
24
25
Declaration of Former Attorney for Respondent -1
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
I also have no recollection of any circumstance in which there was conversation between
Mr. Dahl and Mr. Cena.
2
3
Signed this
day of November, 2014 at University Place, Washington.
~7815
6
7
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9
10
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24
25
Declaration of Former Attorney for Respondent -2
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
E-FILED
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7

County of Pierce
Inre:
DEBORAH J. DAHL,
10
11
No. 02-3-02768-6
Petitioner,
and
JAMES R. DAHL,
12
Respondent.
PETITIONER'S RESPONSE TO
MOTIONS TO DISMISS,
REMOVE COUNSEL, FOR
PROTECTION ORDER AND
ATTORNEY FEES
13
14
15
16
17
best of my knowledge and belief
1. Judgment for $6,031.48 (Reference.
Respondent's
declaration of 11-1-14, "RD"),
18
Page 1, Page 6, line 10-Page 7-line 13).

19
My original Petition for Modification of support and for back support included a
20
21
demand for payment of the sum of $6,031.48,
which was the judgment for past due support
22
contained in the child support order entered on March 26, 2004, at the time of the finalization of
23
the dissolution. After filing the petition, it became clear that that amount had in fact been paid.
24
25
Petitioner's Response -1
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
I have already acknowledged this in my declaration filed October 2, 2014 (Exhibit 1, at if7 and
2
at p. 5, note 1). I have adjusted that claim accordingly.'
2. Resolution of the Relocation matter in 2013 (Reference. RD, page 2, lines 9-17; page
5, lines 15-17).
The question of child support was not discussed or resolved during the proceeding for
6
relocation. In that process, including the settlement phase with Judge Stolz, Respondent and I
7
discussed relocation exclusively, not support.

8
With one month prior to my relocation, my previous attorney, Eric Berg, and I were on a
9
10
time schedule to get the relocation taken care of and not child support. He advised that child
11
support should be a separate issue and not adding it to the relocation since I have only a short
12
period of time before the move. He agreed the child support issue should be filed separately. (I
13
obtained from Tom Cena as my new attorney due to personal issues with Eric was having, not
14
because I was not happy with his counsel).
15
16
Through his present attorney, Respondent filed a document entitled Objection to

Relocation/Petition for Modification of Custody Decree/Parenting Plan/Residential Schedule on
17
December 5, 2012. At Section 3.3 (Page 2) under the hearing "Child Support," Respondent's
18
document states "Does not apply."

19
The discussion with regard to health insurance regarded our daughter, Amanda, not
20
21
22
23
Elizabeth. I kept Amanda on my coverage because the Respondent could not provide specifics
with regard to his insurance concerning medical issues that Amanda needed to have covered.
1
Exhibit 1 is included with only its exhibit #2 attached.
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Since, for that reason, I kept Amanda on my insurance, I kept all three girls on because it cost
2
3
4
me no more to insure three than it did to insure one.

3. Sale of Contra Costa Property (Reference. RD Page 2, line 22-Page 3, line 14)
In 2004-2005, I was under tremendous pressure at work due to changes in my job duties
and raising the girls. I wanted to sell the house and Jim asked me to hang on to it and sell it
6
back to him. After a period of time talking about selling the house, we agreed and I sold it back
7
8
9
to him for $50,000 and he assumed the prior mortgage. He paid me $25,000 and I was told he
would give me the additional $25,000 within a year or so. When we went down to sign the
10
papers, he was in a hurry to get to work and said ''just sign the papers or I'll walk out the door."
11
I signed the papers to keep peace and not upset him. I received the first $25,000 that day and
12
have not seen the final payment of $25,000. The $25,000 was paid to me by Jim and was given
13
to him by his mother (she told me he had gotten the money from her). The payment was not a
14
courtesy from Jim, it was payment for the Contra Costa property.
15
16
Regardless of how Respondent characterizes the award of the Contra Costa property, in
our final decree and settlement, I received no more than one-half of the value of that property.
17
For that reason, no part of the $25,000 that I received can and should be credited to any child
18
support obligation on the part of the Respondent.

19
4. History of Child Support Payments. (Reference. RD, Page 3, line 15-Page 4, line 19)
20
21
The history of child support paid by the Respondent is set out at Exhibit 2 of my
22
23
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Declaration of September 11, 2014, attached to this document as Exhibit 1. Respondent has
2
seriously underpaid his support obligation. With regard to other comments in the Respondent's
declaration, I make this response.
Amanda did not finish high school at the time although she did continue to live with me.
When I would ask Jim for child support, he would state "he didn't have it" or I would get a
6
check for less than the amount he was obligated to and he would say "it's all I have." Again, he
7
made life unhappy for the girls and tell them "your mother is taking all my money." They
8
9
10
11
would come home and tell me statements he had made and they would seem depressed. I did
not pursue additional support to keep him from being angry at the girls. I wanted him to not
take out his anger on the girls and just be nice to them, be a father.
12
Sarah granted from high school and was not sure she wanted to go to college. I did not
13
ask to modify the child support because he told me he would help pay for her tuition. He
14
provided one check for her tuition.
15
16
17
The payment for $6,522.10 was payment and satisfaction of the judgment, as stated
above, for back child support incurred for the two years prior to the divorce being final, 2002 to
2004.
18
One very strong reason that I did not previously move to modify support was because
19
the Respondent was terrible to the girls, when he had them, and when he was angry. He made
20
21
22
them feel so bad that they would cry. Also, for a long period of time, I did not know that I was
permitted to ask to modify support.
23
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
1
2
3
4
5. Cost of College. (Reference. DR, page 4, lines 15-18)

The Respondent is in error to say that Elizabeth will be able to attend Wake Forest at
virtually no cost. I work at Wake Forest and the tuition concession is a benefit which changes
for year-to-year. Regardless of where Elizabeth attends college, she (and I) will be fully
responsible for room, board, fees, travel and all other of her expense. The summary of costs of
6
attendance at Wake Forest University is attached as Exhibit 2.

7
6. Respondent's alleged over payments. (Reference. RD, page 5, line 1-page 6, line 9
8
9
10
There are no overpayments.

I was not paid to relocate to North Carolina. I received a portion of my moving
11
expenses, less than half of the total of those expenses. The Respondent's "reduced" standard of
12
living has included his purchase of a BMW and a newer truck. His assertions of what his
13
support payments should be (e.g. $639.00, times a factor of 0.374) are ones he could have made
14
if he had moved to modify his support obligation, which has been his prerogative all along. It
15
also is difficult to determine what an appropriate amount of child support would be for the
16
17
Respondent as he refuses to provide his pay stubs and tax returns. Instead he asks the Court for
a protection order to allow him not to do so.
18
7. Orthodontia. (Reference. DR, page 7, line 14-page 8, line 4)

19
Elizabeth's orthodontia was not only cosmetic. Braces were recommended to be in

20
21
22
23
place for a short time. The contract for orthodontia (Exhibit 3) was signed on May 1, 2013.
The child had braces for about two years.
The braces were initially put on by a Tacoma
orthodontist on 4/2112011. The total amount paid to that orthodontist was $5,600.00. Both my
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
older daughters had braces, in Washington, which cost more than Elizabeth's. Finally, the
2
Respondent agreed to pay for a share of Elizabeth's orthodontia. (Exhibit 4).
8. Alleged Controlling Behavior. (Reference RD, Page 9, lines 6-18)
I do not consider it to be "controlling" to ask for child support for my daughter.
In the revised parenting plan, after my relocation, Respondent was awarded visits every
month for a four day period in North Carolina. He has never exercised that portion of his
7
parenting time. The parenting plan additionally calls for Elizabeth to fly to Tacoma to visit
8
9
10
Respondent on specified holidays and for summer vacation. She has travelled to Tacoma on
those appointed times. However, several of her trips have been shorter in length at her request
11
and after discussions between Elizabeth and the Respondent. With regard to all of these trips,
12
the discussion has been between Elizabeth and the Respondent. The length of time for the visits
13
have been agreed between them. I do not decide the dates, I only purchase the travel tickets.
14
With regard to the Christmas visit, Respondent was to purchase air fare and it was up to
15
me to reimburse him. Previously, on the first trip to Tacoma, the ticket was also scheduled to be
16
17
purchased by the Respondent. The ticket was a last minute ticket, expensive and on a red-eye
flight. I was concerned since I was paying 75% of the fare. Elizabeth requested that I purchase
18
the tickets because I would get a better flight for her and not a red-eye. I corresponded with the
19
Respondent and he agreed to let me schedule her trips and that he would reimburse me for his
20
portion of the cost. Incidentally,I only received the reimbursement checks from the Respondent
21
22
23
for the summer of2014 and Christmas of2014 on November 10, 2014.
I
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
9.
2
3
4
Attorney Fees.
As above-stated, I have scheduled a hearing before the Commissioner for modification
of support, post-secondary support for Elizabeth and for unpaid child support for December 11,
2014. These instant motions filed by the Respondent seem to be an attempt to short circuit or
completely prevent my pursuit of these remedies. I have expended a considerable amount of

6
effort and money to respond to these motions of the Respondent which I submit are frivolous. I
7
am asking that the Court award me my reasonable attorney fees in connection with my being
8
required to respond to these motions of the Respondent.

9
10
Signed this_
day of November, 2014 at Winston-Salem, North Carolina.
11
12
13

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25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
of support, post-secondary support for Elizabeth and for unpaid child support for December 11,
2
2014. These instant motions filed by the Respondent seem to be an attempt to short circuit or
completely prevent my pursuit of these remedies. I have expended a considerable amount of
effort and money to respond to these motions of the Respondent which I submit are frivolous. I
am asking that the Court award me my reasonable attorney fees in connection with my being
required to respond to these motions of the Respondent.

7
8
Signed this j1_ day of November, 2014 at Winston-Salem, North Carolina.
9
10
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25
TIWMAS A. CENA, JR
Attorney at La
(253) 572-5120 Fax: (253) 593-450
2
3
4
5
6
7

County of Pierce
8
In re:
9
No. 02-3-02768-6
DEBORAH J. DAHL,
10
11
12
Petitioner,
and
DECLARATION
J. DAHL
OF
DEBORAH
JAMES R. DAHL,
Respondent.
13
14
15
16
best of my knowledge and belief.
17
1.
I am asking for modification of the child support responsibility with respect to my
18
youngest daughter, Elizabeth (Rizzy).
19
will be 18 years old on January 1, 2015.
20
21
Elizabeth lives with me in Winston-Salem,

Her date of birth is January 1, 1997.
NC and
At that time
she will still be in high school, a senior. I am also asking for the court to order Elizabeth's
father, James Dahl, to be responsible for post-secondary support for Elizabeth while she is
22
attending college.
23
24
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
25
XiUB\T-.. ::-__
f
2.
I am specifically asking for an order of support for Elizabeth, not only for her tuition
and college expenses but for her living expenses at school plus an amount to be paid to me
directly because Elizabeth
will continue
to live with me when not at school.
dependent child and will be a dependent adult when she turns 18.
She is a
She has and will have no
income and will be completely dependent on me for her expenses. Her expenses will include
(but not be limited to) room, board, clothing, health care, transportation,
tuition, books,
college fees, and personal items
It would be difficult for her to work and at the same time
attend to her post high school education. Elizabeth intends to study for a career in medicine.
9
Mr. Dahl, in his response to our petition, comments that post-secondary support was
10
11
not ordered for our two younger daughters.
12
after high school.
13
formally petition for post-secondary support for Sarah. He did not want his employer to find
14
out about his child support obligation.
15
16
17
3.
Amanda, our oldest, did not pursue education
Our second daughter, Sarah, did.
However, Mr. Dahl asked me not to
I am not sure why that was.
Elizabeth has participated in advanced placement classes in English, Environmental
Science, French and Pre-Calculus.
She maintains an overall grade point average of 3 .6 to 3. 7.
She attended, in the summer of 2013, a 10-day youth leadership forum in medicine at the
18
University of North Carolina at Chapel Hill.
In summer, 2014, she attended a national youth
19
leadership forum in medicine at Johns Hopkins University in Baltimore.
Her eligibility to
20
attend the Johns Hopkins forum required her previous attendance at the University of North
21
22
23
Carolina event. Elizabeth wishes and is well qualified to pursue academic education after high
school graduation.
24
25
~XHl6ff__j_~
THOMAS A CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Documents and certificates attesting to Elizabeth's achievements in academics and

2
athletics are attached as Exhibit 1.
3
4
5
6
4.
The Child Support Order in effect now was entered March 26, 2014. It has never been
modified.
A principle reason for my not attempting until now to modify the child support
order has been that I knew that any attempt would be met with the most intense resistance from
my ex-husband.
Since I knew that Mr. Dahl would interpose as many obstacles and objections
that he could bring about to modifying support, I have refrained from asking for an increase
9
until the present time.
I have, however, never waived any claim which may exist to modify
10
11
12
that support order or to request a judgment for unpaid and delinquent support.
All sums
received by me from Mr. Dahl were received from him (and as often as not, by him giving the
13
check to one of the children to give to me), not from the Washington Support Registry. I have
14
kept records of the amounts of support actually received from my ex-husband.
15
are submitted along with this declaration.
16
willing to give Mr. Dahl credit for the amounts that he has paid.
17
support obligation to a great and significant extent and I request judgment for amounts owed.
Those amounts
Although not paid through the support registry, I am

But he has underpaid his
18
19
5.
The 2004 order of support requires Mr. Dahl to pay the sum of 928.12 per month.
20
21
22
23
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Although, at the time it was entered, the support order applied to our three children, Amanda,
2
3
4
Sarah, Elizabeth, the order does not break down or itemize support obligations among the
three children (Specific amounts for total support for each of the girls is set out in the
worksheets as is an amount of $400 per month for daycare). The support order itself has no
reference to daycare and simply states a specific "total" amount for the three children.
I am
completely unable to make sense of the statement Mr. Dahl puts in his response to the extent
7
that" ... he divided the total (which included an extra $400.00 for daycare that wasn't being
8
9
10
used) by three." (Response of James R. Dahl, July 3, 2014, at Paragraph 1.3)

6.
In paragraph 1.5 and 1.6 of his response to the modification petition, Mr. Dahl says
11
there should no modification
12
modification."
13
Mr. Dahl also did not address the issue of support. I never intended to waive or give up any
14
claim or opportunity to address support modification or seeking judgment for back unpaid
15
16
of child support "based on the recently agreed relocation
I did not mention the issue of support in the process of the relocation action.
support. I also realize and acknowledge that any modification of support can, at the earliest,
only begin with the date of my filing the current support modification petition.
The
17
relocation issue was settled at a settlement conference with Judge Stolz.
The issue of support
18
did not come up.

19
7. It is hard for me to make sense of the statement of Mr. Dahl (paragraph 1.6) that
20
21
22
23
"There are no prior outstanding amounts owed to Petitioner."
The simple arithmetic of the
situation is that the 2004 order requires the Respondent to pay a total of $113,230.64
from
the time of the order to the time of filing.
This
Mr. Dahl has paid a total of $30, 180.80.
24
25
Declaration
of Deborah Dahl -4
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
leaves the amount of unpaid support $83,049.84.

2
3
4
declaration
as Exhibit 2.
My record of payment is attached to this
There was no such "rational decision"
between Mr. Dahl and
myself to do anything but for him to follow the terms of the 2004 order.
He simply has not
paid all the support he has been ordered to pay and has not ever asked to change the amount
he is responsible to pay.
8.
I absolutely
did not "accept" the amounts paid by Mr. Dahl on a regular basis without
notice that those payments were not an agreed upon amount.
There are indeed outstanding
amounts of child support owed by Mr. Dahl.
When we did communicate with regard to
10
11
support, his comments were such as "I will make up the difference next month;" or "I will
12
pay you when I get my tax return;" or some other similar comment. Mr. Dahl requested that
13
I not use the child support registry and that he would give me the "rest of the support" which,
14
of course, did not happen.
15
There were definite communications between he and I any time I received from him
16
17
support that was not in the full amount.
18
check in an envelope to the children to give to me, so as to avoid this sort of conversation.
That is probably the reason that often he gave a
19
20
1
21
22
23
Although our original petition requests payment for the $6,031.48 judgment for unpaid support from the 2004
order, that obligation has been satisfied. In reviewing the court file, a satisfaction of judgment in the amount of
$6,552.10 was filed on September 4, 2012. That amount was received because it was a judgment and needed to
be paid out of escrow in a real estate transaction that Mr. Dahl was attempting. This judgment satisfaction was
to satisfy unpaid support from 2002 until March, 2004, during the time that our divorce proceeding was
pending.
24
25
THOMAS A. CENA, JR.

Attorney at Law
(253) 572-5120 Fax: (253) 593-4503
2
I certainly accepted what he paid because it was better than getting nothing on many
occasions.
you."
His comments were such as "that is all I have right now and I will make it up to
$52,307.86.
Order.
10
11
This is calculated on the amounts owed subsequent to the entry of the 2004
No claim is included for interest on the judgment
$6031.48.
amount form that order of
As stated in paragraph 7, (footnote 1) this amount has been satisfied.
I have
12
interest from the end of that year to the time of filing.
The interest calculation is therefore
13

14
Signed this __ day of September, 2014, at
15
16
17
18

19
20
21
22
23
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25
Declaration
of Deborah Dahl -6
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
tax ::Jerver
811LIL014
2:08:57
PM
PAGE
3/003
2
requesting make up ofunpaid amounts of child support.
I certainly accepted what he paid because it was better than getting nothing
5
6
occasions. His comments were such
'1S
011
many
"lhat is all I have right now and l will make it up to
you."
9. l have requested judgment for interest on the unpaid support in the amount of
Order,
10
II
No claim is included for interest on the judgment amount form that order of
$6031.48. As stated in paragraph 7, (footnote 1) this amount has been satisfied.
I have
calculated interest ascertaining the amount of unpaid support for each year ond calculating
12
interest from the end of that year to the time of filing. The interest calculation is therefore
1J

14
Signed this
J_.l._ day of September,
20 l 4, at _J).J!l14/!1&:.
. . ~~1J)_fL_
IS
lli
17
_&J.mwj/J&
.
19
20
21
22
23
24
25
THOMAS A. CENA, JR.

Attorney ut La1\
3929 Bridgeport Wny we, 1130
University Pince, WA 9846
(251) 572-5120 Fax: (253) 59J-450
E-MA1L: TomCS5@nvcnturc:.con
Date 2004 Amt. 2004 Date 2005 Amt. 2005 Date 2006 Amt. 2006 Date 2007 Amt. 2007 Date 2008
8/10/04 (P
200
Mar-06
450
Feb-07
928
Jan-08
8/20/2004
400
Apr-06
928
Mar-07
928
Feb-08
1-May
900
Apr-07
928
Mar-08
Jun-06
600 6/1/2007 (
928
Apr-08
Jun-06
300
Jun-07
464 7 /2008 (fo:
Aug-06
400
Jun-07
464 9/2008 (fo:
Sep-06
400 11/2007
Sep-06
Oct-06
Oct-06
Nov-06
Dec-06
400 11/2007 (ft

464
Dec-07
464
928
928
(ft
620 10/1/2008
620
Oct-08
620 11/2008 (ft
Amt. 2008 Date 2009 Amt. 2009 Date 2010 Amt. 2010 Date 2011 Amt. 2011 Date 2012 Amt. 2012
620 1/1/2009 (
620
Feb-10
400
Jan-11
400
Feb-12
400
2/2009 (fo:
620
Mar-10
500
Apr-11
400
Aug-12
400
620 4/2009 (fo:
620
Aug-10
400
Aug-11
600
Oct-12
400
620 5/1/2009 (
620
Nov-10
300
Sep-12
400
620 6/2009 (fo:
620
Nov-10
300
Dec-12
400
630 8/2009 (fo1
620
Unknown
630
725
620
Sep-09
620
Date 2014 Amt. 2014
Date 2013 Amt. 2013

1-Mar
1-Sep 309.38 (For April)
1-Sep 309.38 (For May)
1-Sep 309.38 (For June)
1-Sep 309.38 (For July)
1-Aug 309.38 (For Aug)
1-Sep 309.38 (For Sept)
1-0ct 309.38 (For Oct)
1-Nov 309.38 (For Nov)
30-Dec 309.38 (For Dec)
800
1-Jan 309.38 (For Jan)
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Form-Im.
FAFSACode
002978
==
''6f===
hllp:iilinancialaiJ. wfu.edu/cosr-of-atrendance/] 11!7i2014
11 :23:59 AM]
Date:S/1/2013
Contract N~.313066
I
Patient:Elizabeth
Dahl
.left' L. Rlckabilugh, DD, MDS, PA
This treatment fee includes:

1. Initial Exam and Consultation.
2. Diagnostic Records.
,
3. Placement of appliances and adjustment appo!ajments
including any emergency appointments.
4. Removal of orthodontic appliances.
5. Initial Retainers which includes 2 years ofRet4er Adjustments
and Final Records.
''
T*s treatment fee does NOT include:

1. \Required6 month dental cleaningsand
I exams.
2. \Restorations, extractions and any other
I Non-orthodontic dental procedures.
'
3. \Replacement Retainers.
This agreement establishes

D r. R'ao kabaugh
fees and charg~s for the orthodontic
treatment plati recommended by
~:
t\
;:
Initial Examination and Consultation

l'
Diagnostic Records
1.
2.
3.
4.
~:
Active Treatment
Estimated Insurance
Total Fee
5.
$148.00 for 8
Last Payment
j
i
:-:
'
No Chartre
$
Due when Service is rend$red

months
:
!
$ll84.0)
$2,590.00
Advance notice of 48 hours is requested to cancel an appointment. There is a minimum charge of $35 for ~issed appointments.
Payments arc due on the 1st of each month regardless
$111. 00
$1295.00
PATIENT IS RESPONSIBLE FOR l'\NY UNPAID PORTION
$35
df scheduled appointments. A late fee of $25 will ~e charges for late payments.$25
There is a charge for all returned checks or drafts and thei!e will be NO further checks or drafts allowed forthis contract.
~
$32
ll&.
/GJ}'
&kt
Generally, active treatment is completed within th~ prescribed period. If treatment extends beyond the "estimated treatment time", dhe
to factors beyond the Doctor's control (such as m~sed or rescheduled appointments, lack of cooperation, excessive breakage of
\
appliances, poor oral hygiene, not following presc~\bed instructions, etc)., there may be an additional monthly charge of the current f~e
until treatment is complete.
:..
\.
$179 ;t&f:L
\'
Should it be necessary to enforce the provisions oflfuis Agreement through an attorney or by !~gal proceedings, the undersigned
.
promises to pay all cost of collection, including a r~asonable attorney's fee and all court costs. \The contracted fee must be paid in i
full before removal of the orthodontic applianc~ regardless of remaining and unpaid ins~rance benefits. Transfer fees,
I
collection fees, and /or discontinuation fees will be~harged in accordance with a "fees for services rendered" scale which includes anl
unpaid balance of the deferred down payment. Piere ask the financial coordinator for details.\
Initials_M_
The person who signs this agreement on behalf of th~ patient named above accepts sole responsiJ,ilityfor the full contract balance less an*
porti?n paid directly to the doctor by the patient's in~'U.ran~e company. *~If insurance does not cor.er orthodontic bene~~s,ismelled or\
terminated for any reason, I understand that I am res~ons1blefor the entire balance of the contract.
Initials
THIS PATIENT HAS COMPLETED DENT AL CLEANING, EhMINA T!ON AND NECESSARY TREATMENT. \
Initials_&.
I herby certify that I have read and received a copy of the foregoing disclosure statement. ~ agree to and accept the terms and
concli/l.uQ::~:re~.
_'Yd_Jff'!Af\
/O
lJ~
.A
Sig11lltJre of Responsible Party
J; 1-Date13
('
i;...
i :
i
I
Deborah Dahl RN, MSN

Roena B. Kulynych Center for Memory & Cognition Research
Department of Internal Medicine

Division of Gerontology and Geriatric Medicine Wake Forest University School of Medicine
(Sticht Center)
1 Medical Center Boulevard, Winston-Salem, NC 27157-1207
Tel: 336-713-3432 I Fax: 336-713-8826
[email protected]
[cicl:[email protected]]
From: [email protected] [mailto:[email protected]]
Sent: Sunday, June 08, 2014 11:43 AM
To: Deborah Dahl
Cc: Jim Dahl
Subject: Re: Rizzy
When I was talking to Elizabeth about 2014 Christmas from your request we came up with
Christmas week for my visit. She asked you and you said fine. So you knew what week.
About orthodontic work, we discussed that already and conditions. Yes you we get my part. Jim
From: Deborah Dahl <[email protected]<mailto:[email protected];

To: [email protected]<mailto:[email protected]>
<[email protected]<mailto:[email protected]>>;
Cc: Deborah Dahl <[email protected]<mailto:[email protected]>>;
Subject: Rizzy
Sent: Tue, Jun 3, 2014 12:56:53 PM
Jim,
On March 29th, I sent a receipt for Rizzy's orthodontia expenses and I have not heard back
~egarding payment for your portion. Will you be sending your part of her orthodontia work?
Also, I sent an e-mail regarding travel for her Christmas holiday. Tickets at this point are
inexpensive and I would like to purchase the ticket before the prices go up. Have you talked
to Rizzy about when she wants to come to Seattle?
1
2
3
4
5
6
7
8
County of Pierce
10
DEBORAH J. DAHL,
No. 02-3-02768-6
Petitioner,
11
and
DECLARATION RE SIGNATURE
ELECTRONIC DOCUMENT
ON
12
JAMES R. DAHL,
13
Respondent.
14
15
I, RHONDA L. DURHAM, declare under penalty of perjury, under the laws of the
16
State of Washington, that the foregoing electronic document attached to this declaration,
17
which consists of twenty-two (22), including this declaration page, is a complete and legible
18
19
image that I am have examined personally and that was received by me via email.
Signed this lib day of November, 2014 at University Place, Washington.
20
~~~
21
22
RHONDA L. DURHAM
23
24
25
Declaration
THOMAS A. CENA, JR
Attorney at La
(253) 572-5120 Fax: (253) 593-4503
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
4
5
6
7
8
9

County of Pierce
Inre:
No. 02-3-02768-6
DEBORAH J. DAHL,
AFFIDAVIT OF ATTORNEY FEES
10
11
12
13
14
Petitioner,
and
JAMES R. DAHL,
Respondent.
SS.
15
County of Pierce
16
17
1. I am the attorney for Petitioner, Deborah J. Dahl, in the above-entitled matter.

18
19
20
21
Below is an itemized listing of the time that I have expended in representing Ms. Dahl
regarding motions filed by the Respondent for protection order, to remove counsel, to
dismiss and for attorney fees; and motion by Petitioner to Compel Discovery.
22
23
24
25
Affidavit re Attorney Fees -1
THOMAS A. CENA, JR
Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Date
Description
11/03/14
Review Respondent's Motion, Memorandum and Respondent's

Declaration
.40
11/04/14
Prepare Motion to Compel Discovery; review court rules;

Rule 37; review file
.80
Prepare Declaration of counsel regarding Respondent's

Motion to Remove Counsel
.40
3
4
5
11/07/14
Time
11/07/14
Prepare Memorandum in Opposition
.20
11/07/14
Prepare Memorandum in Opposition to Motion to

Dismiss
.30
11/07/14
Tel. from client
.20
11/07/14

Dismiss
.70
11/07/14
Research re conflict of interest
.50
11/11/14
Prepare declaration of counsel; prepare responding

Declaration of Petitioner; review file
3.90
TeL to client; prepare declaration of client; review

File
1.10
9
10
11
12
13
14
15
11/12/14
16
17
18
19
20
21
22
I
I
I
I
I
I
I
/
I
I
I
23
24
25
THOMAS A. CENA, JR
Attorney at La
(253) 572-5120 Fax: (253) 593-4503
11/12114
2
3
Tel. to client; proofread and revise declaration
.20
TOTAL HOURS
8.70
8.70 hours at $250.00 per hour - $2,175.00
Q~
THOMAS A.CENA,JR., WSBA NO. 6539

8
9
SUBSCRIBED AND SWORN TO BEFORE ME this_
10
NOTARY PUBLIC
in and for the State
Of Washington, residing at Tacoma.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
THOMAS A CENA, JR.

Attorney at La
(253) 572-5120
Fax: (253) 593-4503
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7
8
9
Countyof Pierce
Inre:
No. 02-3-02768-6
DEBORAH J. DAHL,
AFFIDAVIT OF ATTORNEY FEES
10
11
12
13
14
Petitioner,
and
JAMES R. DAHL,
Respondent.
SS.
15
County of Pierce
16
17
1. I am the attorney for Petitioner, Deborah J. Dahl, in the above-entitled matter.

18
19
20
21
Below is an itemized listing of the time that I have expended in representing Ms. Dahl
regarding motions filed by the Respondent for protection order, to remove counsel, to
dismiss and for attorney fees; and motion by Petitioner to Compel Discovery.
22
23
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Date
Description
11103/14
Review Respondent's Motion, Memorandum and Respondent's

Declaration
.40
11104/14
Prepare Motion to Compel Discovery; review court rules;

Rule 37; review file
.80
Prepare Declaration of counsel regarding Respondent's

Motion to Remove Counsel
.40
3
4
Time
11/07/14
6
7
11107/14
Prepare Memorandum in Opposition
.20
11/07/14

Dismiss
.30
11107/14
Tel. from client
.20
11107/14

Dismiss
.70
11107/14
Research re conflict of interest
.50
11111/14
Prepare declaration of counsel; prepare responding

Declaration of Petitioner; review file
3.90
TeL to client; prepare declaration of client; review

File
1.10
9
10
11
12
13
14
15
11/12114
16
17
18
19
20
21
22
I
I
I
I
I
I
I
I
I
I
I
23
24
25
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
11112114
2
3
Tel. to client; proofread and revise declaration
.20
TOTAL HOURS
8.70
8.70 hours at $250.00 per hour - $2,175.00
Q_a
5
6

7
8
SUBSCRIBED AND SWORN TO BEFO ,
l;;;:_f_
day
10
NOTARY PUBLIC
in and for the State
Of Washington, residing at Tacoma.
11
12
5-/ /, . - /j
13
14
15
16
17
18
19
20
21
22
23
24
25
THOMAS A CENA, JR.

Attorney at La
(253) 572-5120
Fax: (253) 593-4503
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
No. 02-3-02768-6
Petitioner(s),
vs.
JAMES R DAHL
Respondent(s)
Phone: (253) 272-0566

Show Cause
Nature of Hearing: Child Support,CHLD~Child Support
CALENDAR DATE: Tuesday, December 23, 2014 9:00 AM

DATED:
November 17, 2014.
Signed:
NAME:
Phone:
(253) 572-5120
WSBA#:
For:
6539

1 of 1
~::,- - ~-1.-- --(TI~T~

-:
I
02-3-02768-6
43643509
111. 11
11 I
ORCNT
11-17-14
3
4
(I;
u,
r-
6
7

DEBORAH
J DAHL,
Petitioner(s)
Cause No: 02-3-02768-6
ORDER
(OR)
vs.
10
JAMES
R DAHL,
():
11
12
13
14
15
16
17
18
19
20
DATEDthis--0-ty
21
22
23
24
25
9-
Attorney for laintiff/Petitioner

WSBA# (o..(s q
of
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6

7
8
9
10
11
In Re the Marriage of:

DEBORAH J. DAHL,
Petitioner,
And
12
JAMES R. DAHL,
13
Respondent.
14
)
)
)
)
)
)
)
NO. 02-3-02768-6
DECLARATION OF ATTORNEY ERIC V. BERG
)
)
)
)
15
16
I, Eric V. Berg, declare as follows based upon my personal knowledge. I am an attorney licensed to
17
practice in the State of Washington, WSBA No. 28011. I was previously the attorney ofrecord for
18
petitioner Deborah J. Dahl in the above-captioned action. On April 1, 2013, I attended, as Ms. Dahl's
19
attorney, a settlement conference in connection with the above action before the Honorable Katherine M.
20
Stolz. Ms. Dahl's former husband (the father of the child whose custody was at issue) James Dahl, was
21
present and was represented by Sandra Johnston, who was also present. The parties reached agreement on
22
the issues and the Court entered, on April 1, 2013, its "Order re Modification/Adjustment of Custody
23
24
25
Decree/Parenting Plan/Residential Schedule" (hereinafter the "Relocation Order").

THOMAS A. CENA, JR.
Attorney at La
(253) 572-5120 Fax: (253) 593-4503
My understanding is that Ms. Dahl has since retained Mr. Tom Cena to represent her in connection
with, inter alia, her request for the Court's directive regarding past child support and post-secondary
education contribution by Mr. Dahl.
At the April 1, 2013, settlement conference, there was no oral or written agreement that any
obligation - by either party- to pay any child support or post-secondary educational support was to be
6
released or modified. In fact, to the contrary the Relocation Order (which was initially drafted by Ms.
7
Johnston) states at Paragraph 2.7, in pertinent part:

8
"Mother has taken a new job in North Carolina and.father agrees that the child may move
deviation/or his cost of travel or other costs and/or changes to the prior Order of Child
Support filed on March 26, 2004." (Emphasis added.)
10
11
12
The March 26, 2004, Order of Child Support to which the above court-ordered language refers
states, in pertinent part, at Paragraphs 3 .13 and 3.14:
Paragraph 3:13: "Support shall be paid ... until the children reach the age of 18, except as
otherwise provided below in Paragraph 3.14. "
13
14
Paragraph 14: "The right to petition/or post secondary support is reserved, provided that
the right is exercised before support terminates as set forth in Paragraph 3.13. "
15
16
17
18
19
At the April 1, 2013, settlement conference, there was no agreement by the parties or their counsel
to deviate from the above-quoted Orders.
I declare under penalty of perjury under the laws of the State of Washington that the foregoing is
20
true and correct and that this declaration is signed on the date indicated below at&'/
21
Washington.
4// A._
22
23
24
25
Dated: December 2::-2014

THOMAS A. CENA, JR.
Attorney at La
(253) 572-5120 Fax: (253) 593-4503
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7

NO. 02-3-02768-6
DECLARATION OF PETITIONER DEBORAH DAHL
IN OPPOSITION TO RESPONDENT'S MOTION
TO DISMISS AND FOR ADDITIONAL RELIEF
15
16
17
I, DEBORAH DAHL, do hereby certify and declare, under penalty of perjury, under the laws ofth
State of Washington, that the following statements are true and correct, to the best ofmy knowledge an
belief.
18
1. Introduction. I am the Petitioner in this proceeding, Deborah Dahl. This declaration is to

19
clarify issues concerning the Respondent's pending Motion to Dismiss my Petition for Modification o
20
Child Support, Unpaid Child Support and for Post-Secondary Support of our daughter, Elizabeth.
21
22
23
24
25
2.
Child Support not settled during proceeding for relocation. (Reference Declaration of
James Dahl, filed November 3, 2014, page 2, line 9 ff).

Declaration -1
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
During the negotiation and settlement conference prior to my relocation to North Carolina, th
discussion and negotiation was concerning relocation only and not child support. In fact, my previou
3
4
attorney, Eric Berg, advised me not to combine the child support issue along with the relocation one. M
ex-husband, Mr. Dahl, seemed to be in agreement with relocation until approximately one month prior t
the time of my move. I therefore had only a short period of time to bring the matter to court prior to m
6
move with Elizabeth.

7
Exhibit 1 shows a page of the Court's docket in this proceeding. Marked are the relevan
8
9
10
documents concerning the relocation proceeding beginning in October of 2012. The Notice of Intende
Relocation of Children, filed by Petitioner, has no mention of any issue concerning support. Nor does th
11
declaration of James R. Dahl, the Respondent, filed on December 5, 2012. However, the Respondent'
12
document entitled Objection to Request for Relocation, filed December 5, 2012, does make reference t
13
child support. In the Respondent's document, filed by current counsel for Respondent, paragraph 3.3
14
entitled "Child Support" states "does not apply." The parenting plan later entered on April 1, 2013
15
contains no mention of child support. However, the order on modification, (Exhibit 2), also prepared b
16
17
18
19
Respondent's current attorney, states at paragraph 2.7:

Substantial change in circumstances.
Mother has taken a new job in North Carolina and father agrees that the child may move
deviation for his cost of travel or other costs and/or changes to the prior order of child
support filed March 26, 2004.
20
In connection with the Respondent's argument that the child support provision was settled durin
21
22
23
24
25
negotiation for the relocation, please also refer to the Declaration of Attorney Eric V. Berg, dated Decembe
2, 2014 and filed herein.
Declaration -2
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Notwithstanding the many references pointing to no discussion or settlement concerning chil
support, Respondent's counsel argued at the November 14, 2014 hearing, as follows:
Ms. Johnston: Well, it's too convenient that the - - Ms. Dahl got rid of the lawyer that
could address these issues because he was there. That's not Mr. Cena's fault but certainly a
good strategy to use ...
(Verbatim Transcript of Proceedings, November 14, 2014, page 8, lines 3-6)

6
The allegation concerning the issue of child support being settled in the Respondent's favor durin
negotiations for the relocation of Petitioner and the parties' daughter, is completely without any basis i
fact.
10
11
At the settlement conference, we did not discuss :financialsupport. I did not ask the Respondent t
obtain health insurance for Elizabeth as she and our other two daughters were covered under my plan wit
12
my employer. At that time there was no discussion as to Mr. Dahl providing health insurance for Elizabeth.
13
After the relocation, in 2013, our other, older daughter, Amanda, experienced medical problems. She and
14
15
16
discussed the issue and if it would be beneficial for her to be on the Respondent's insurance since her out
of-network deductibles would be high.
I contacted the Respondent but he could not provide an
17
information concerning his insurance, what was and was not covered. Amanda is an adult and he
18
participation on my insurance is not an issue here. Elizabeth is the subject of the current petitio
19
concerning child support. Any discussion regarding medical insurance was about Amanda.
20
21
22
23
24
25
3.
Disposition of the Contra Costa house has no bearing on issues of child support.
(Reference Respondent's Declaration, page 2, line 22, ff)

At the time of our dissolution and before, I managed the rental property. That property wa
awarded to me, with a $25,000.00 lien in favor of the Respondent. (Decree of Dissolution, March 29, 2004
Declaration -3
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
if 3.2)
me to keep it in my ownership and possession because he eventually wanted it back. I did not convince hi
3
4
2, 3.3(2)). Despite language in the Decree, the Respondent did not want the property sold. He aske
to give me $25,000.00 if the house sold; it was never on the market. Our discussion was that I did not wan
to keep it any longer and was thinking of options. Respondent said he wanted the house. In September
2005, I sold the property back to the Respondent for $56,000.00 (Exhibits 3 and 4). He provided me with
6
check for $25,000.00.
The substance of the transaction was that Respondent was to pay me a ful
$56,000.00 for the property. He told me he would give me the rest later. He has paid nothing in addition t
8
9
10
the $25,000.00 on the basis of my sale of the property back to him. The Respondent has definitely no
overpaid me concerning the Contra Costa house. I have not "demanded" the remainder of what he owe
11
me. I have asked for it as a part of our agreement a number of times. Respondent's response has alway
12
been "I'll give it to you when I can," or "I thought I would give it to you when I sell the property," or som
13
other variation. I have sent Respondent emails as a repayment schedule for the remaining $25,000.00.
14
have always been cordial with him in trying to resolve this issue. As far as the source of the funds that I di
15
receive, the Respondent states he took the money from his credit cards. Whether or not this is true, hi
16
mother told me that she gave him the $25,000.00.
17
4.
Respondent's history of child support payments show substantial underpayment.
18
(Reference Declaration at 3, line 15, ff)

19
In 2007, I did pursue support modification for Amanda prior to her turning 18, for post-second
20
educational support. I did this because the Respondent did not want to pay for her any longer. Amanda di
21
22
23
24
25
not drop out of school. However, she did fail her senior year and did not want to continue her education
At this point, modification for post-secondary support was discontinued.
With respect to modification o
Declaration -4
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
current and future support (non-post-secondary), I did not know that I had the right to ask for tha
2
3
4
modification. The Respondent says that he has no idea why I dropped the modification petition fo
Amanda. He did in fact know. He knew I was seeking to modify support for Amanda's post-seconda
education. Again, I did not realize that I could have asked for a modified support order for the othe
children who were, at that time, entitled to current support.

6
It is simply false on the part of the Respondent when he states "almost ten years later" that he wa
7
paying more than he should have. He is not and has not overpaid. Again, also, he knew each child had he
8
9
10
11
own support calculation as this was set out in the original set of worksheets accompanying the 2004 chil
support order. This clearly states the support amount for each individual child.
The Respondent did not pay every other month for Sarah to attend Tacoma Community College.
12
have no record of him doing so. If he has done so, he should provide documentation of this. It is simpl
13
not the case.
14
15
16
17
Payment from the Respondent was given to me directly by check and sporadically. I never kne
when to expect it. Generally, it was given to one of the girls to give to me. I would hear comments lik
"It's all I have," "I can't give you anymore," "I'll make it up to you," and statements to the affect that
should be lucky to get what I got. Respondent specifically asked me not to go through DSHS because h
18
would get fired and then I would get nothing.

19
The Respondent accuses me of bringing my petition for support when the "support wagon is gettin
20
21
22
to run out." I am not doing so. The money that I am asking for is for the current, future and unpaid bac
support that the Respondent was ordered to pay.
23
24
25
Declaration -5
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
To accuse me of not telling the Court I work as a research nurse for Wake Forest University. This i
2
3
4
simply not the case. At if 1.2(page 2 of the Notice of Intended Relocation that was filed on October 25,
2012, I stated exactly that. One part of that document is as follows: "I have been offered the job of Clinica
Nurse Manager with the new clinical and research program at Wake Forest. It is also untrue that Elizabe
will be able to go to college "virtually free of charge." There is a tuition concession for limited number o
6
schools but not all. Elizabeth may decide to go to a university that does not have tuition concessions. Also
7
the benefit is for tuition only, not room, board, fees, books, transportation and other expenses. All of thes
8
9
10
expenses will need to be taken care of by her, me and hopefully by the Respondent.
I am seeking a continuation in child support payments until Elizabeth graduates in June of 2015. A
11
that time, she will be 18. The Respondent states that if Elizabeth needs something that she knows that h
12
will help her. This may or may not be true. The Respondent has helped the older girls when it has bee
13
convenient, but not always. I have also helped the older girls with phone bills, rent, food and othe
14
expenses. Also, I am not asking for support for me, I am asking it for our daughter, Elizabeth. Th
15
Respondent wants support for Elizabeth to end when she reaches 18, limited to the payment of he
16
17
telephone bill which in fact he does pay.

It is not of any consequence that I may have waited to cash the support checks that I did receiv
18
from the Respondent. The fact that I make more money than he does is also not a deciding factor. Chil
19
support is and was based on our combined incomes. It is true that Wake Forest did provide some funds fo
20
my relocation but not for all of those expenses. My expenses for the move was more than Wake Fores
21
22
23
24
25
paid. I was out-of-pocket for the move. The question of the Respondent's financial need is not a part ofth
calculation or decision concerning child support, including past due unpaid child support.
Declaration -6
Attorney at La
(253) 572-5120 Fax: (253) 593-4503
"deteriorated" standard of living has included his purchasing a used BMW and a truck. I am also no
2
3
attempting to circumvent an agreement concerning relocation. The relocation happened by agreement an

there was no agreement connected with it concerning child support in any way.
On Page 5, line 24 of his declaration, the Respondent calculates a theorical support paymen
obligation. This has nothing to do with the child support order entered in 2004. The support order state
6
the amount of child support that the Respondent owes per month.
Respondent has always had th
opportunity and ability to ask for a modification of that support order. He has chosen not to do so.
8
5. Respondent has not paid all child support due nor has he made any overpaymentwith
9
10
respect to his support obligation. (Reference Declaration, Page 5, line 2, ff)

In my declaration of September 11, 2014 (Exhibit 1 to my declaration of November 12, 2014),
11
12
show that, at the time of the declaration, the child support obligation on the part of the Respondent wa
13
$113,230.64.
14
are then $83,049.84.1
15
16
Respondent had, by that time, paid $30,180.80. The arrears calculated by simple arithmetic
Moreover, the Respondent was ordered to pay to the Washington Support Registry in the 200
order. (2004 Support Order, paragraph 3.11). He has paid nothing through the registry.
I am howeve
17
willing to accept the amount that he did pay directly to me as a credit toward the debt which he now owes
18
The support order recites that interest on unpaid support should be 12% per annum.
19
There has been no agreement verbal or otherwise, with the Respondent where I have agreed tha
20
support that he has actually paid satisfies his obligation. On the spreadsheet (Exhibit 1 to my declaration o
21
22
23
24
25
This sum excludes the Judgment for back support, set out in the September, 2004 support order, of$6,031.48, which has
been satisfied.
Declaration - 7
THOMAS A. CENA, JR.
Attorney at La
(253) 572-5120 Fax: (253) 593-4503
September 11, 2014), I have listed all the payments that he has made. The total of these is $30,180.80 a
set out above.
3
4
As I have previously stated, the Respondent, since the entry of the 2004 support order, has alway
had the prerogative of requesting a modification of that order. He has chosen never to do so.
6. Payment for 2004 Judgment. (Reference Page 6, line 10, ff)

6
I have already stated in my previous declaration that I am not attempting to collect the sum of
7
$6,031.86 twice. This was the judgment included in the 2004 child support order for unpaid past du
8
9
10
support at the time the divorce was final. I do acknowledge that the Respondent has paid that and that
Satisfaction of Judgment has been entered with the Court. My calculations concerning past due support
11
including those set out above, do not include that amount or any interest on that amount. The Responden
12
also states that this amount ($6,031.86) was for back support during the time that he was laid off
13
Regardless of his employment circumstances prior to March 2004, there was entered by the Respondent'
14
agreement, the judgment for past due temporary child support in that amount. Respondent has paid tha
15
amount, has been given credit for it, and the discussion of this amount should be put to rest.
16
17
7. Concerning medical and orthodontic care for Elizabeth.

Elizabeth had braces before we left Tacoma and Respondent knows this. As I explained in a
18
previous declaration, he did not tell me he could not afford braces.

19
The Respondent's idea to drop Elizabeth from my insurance was not in the best interest o
20
21
22
23
24
25
Elizabeth. She still needed yearly exams, cleanings and other dental services. To drop her from m
insurance did not make sense. The Respondent agreed to the braces. It was not a purely cosmeti
procedure, her dentist recommended it because of issues with her bite.
Declaration -8
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Finally, Respondent contradicts himself by stating his insurance would not cover an out-of-stat
2
child. Then previously he states that he could not put her on his insurance. Again, Elizabeth already ha
braces and it was in her best interest to continue orthodontic care.
8.
My behavior has not been controlling. (Reference Declaration, Page 9, line 6, ff)
I have not engaged in constant demands and controlling behavior. I have attempted to solve
6
issues of back support peacefully with Respondent. Any time I brought this up, he labeled it a
7
"controlling." I am doing at this point what I believe is right. I have, over the years, asked th
8
9
10
11
Respondent to become current in his child support to no avail. The DSHS/DCS system was no
involved because Respondent asked me not to involve that agency. I did comply with the Respondent'
requests in that respect so that he would not have to worry about his employment.
The time Elizabeth travels to Seattle was determined between the Respondent and our daughter.
12
13
I have not been involved in these discussions and I advised Elizabeth to have discussions in this respec
14
directly with her father. She may not want to spend a full week in Tacoma. The only thing that I hav
15
requested is the dates for the visits, so that I could purchase tickets. After Elizabeth and the Responden
16
17
decided when she would travel, I would purchase tickets for her.' It is not "my way or the highway.'
The decision with regard to travel and length of stay has been between Elizabeth and the Respondent.
18
9. Attorney Fees. I have had to expend a large amount of money on attorney fees to respond to
19
the motion to dismiss this proceeding and the untrue allegations that no child support is owed. These fee
20
21
are entirely over and above those necessary and utilized to bring the underlying motion for modification o
22
23
24
25
Respondent was ordered to purchase the tickets. He waited until the last minute whereby the prices were very high and he
could only get a red-eye flight. Elizabeth requested I purchase the tickets because I would purchase the airfare ahead oftime
so as to get a reasonable airfare and not a red-eye flight.
Declaration -9
THOMAS A. CENA, JR.
Attorney at La
(253) 572-5120 Fax: (253) 593-4503
support, post-secondary support and for judgment of unpaid support in arreasrs. The filings with respect t
2
3
4
this motion have been frivolous. They have been an attempt to circumvent the process of the legitimat
request for adjustment of support and for payment of back support. False allegations have been made t
support the Respondent's position. I am asking the Court to award me attorney fees that I have had t
expend to respond to the instant motion by the Respondent.

6
Signed this __
day of December, 2014 at Winston-Salem,North Carolina.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Declaration -10
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Fax Server
12/8/2014
12:26:21
PM
PAGE
3/003
support, post-secondary support and for judgment of unpaid support in arreasrs. The filings with respect t
2
this motion have been frivolous. They have been an attempt to circumvent the process of the legitima
request for adjustment of support and for payment of back support. False allegations have been made t
support the Respondent's position.
I am asking the Court to award me attorney fees that I have had t
expend to respond to the instant motion by the Respondent.
Signed this .Di_ day of December, 20.14 at Winston-Salem, North Carolina.

7
8
9
10
II
12
13
14
15
16
l7
18
19
20
21
22
23
24
25
Declaration -10
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-450 .
E-MAIL: 'fomCSS@nventure .cot
81S'lil#WJ!fi:!S2SS~
2
3
4
5
6
County of Pierce
8
9
Inre:
No. 02-3-02768-6
DEBORAH J. DAHL,
RE FAX TRANSMITTAL
10
Petitioner,
11
and
12
JAMES R. DAHL,
13
Respondent.
14
15
STATE OF WASHINGTON )
SS.
16
County of Pierce
17
18
19
matter. That I have examined the attached Declaration of Petitioner, which is
20
21
22
23
24
25
Affidavit
-1
THOMAS A. CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
E-MAlL: [email protected]
being filed with the above-entitled Court.

2
This document consists of thirteen (13) pages
(including this affidavit) and it is complete and legible.
3
4

5
6
7
<l
8
9
10
11
Tacoma.
~ / { /
My Commission Expires: !J.. . ,
- :./
12
13
14
15
16
17
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19
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25
Affidavit
-2
THOMAS A CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
Pierce County Superior
L
MOTION TO COMPEL
06/10/2003
CERTIFICATEOF COMPLIANCE
Public
06/19/2003
NOTICE OF ABSENCELUNAVAILABILITY
Public
06/26/2003
MOTION TO STRIKE
Public
24
06/26/2003
RESPONSE TO MOTION TO COMPEL
Public
12
06/27/2003
CLERK'S MINUTE ENTRY
Public
06/27/2003
~JUDGMENT
Public
07/29/2003
Public
07/29/2003
DISCLOSURE OF WITNESSES
Public
07/29/2003
Public
08/06/2003
DISCLOSURE OF WITNESSES
Public
10/02/2003
NOTICE OF SUBSTITUTION OF COUNSEL
Public
11/12/2003
Public
11/14/2003
NOTICE RE: EVIDENTIARY RULE
Public
11/17/2003
PLAINTIFF'S LIST OF WITNESSES
Public
11/19/2003
SETTLEMENT CONFERENCEREPORT
Public
11/25/2003
NOTICE OF SETTLEMENT AND AUTH TO STRIKE TRIAL DATE
Public
11/26/2003
Public
12/18/2003
Public
01/20/2004
NOTE OF ISSUE
Public
02/05/2004
ASSIGNED TO
Public
02/27/2004
NOTE OF ISSUE
Public
03/11/2004
NOTE OF ISSUE
Public
03/26/2004
Public
03/26/2004
PARENTING PLAN
Public
12
03/26/2004
ORDER FOR SUPPORT WITH WORKSHEETS
03/26/2004
03/26/2004
03/26/2004
14
Public
QUALIFIED DOMESTIC RELATIONS ORDER
Public
QUALIFIED DOMESTIC RELATIONS ORDER
Public
DECREE OF DISSOLUTION
Public
Public
Public
~SUMMONS
Public
Public
Sealed
12/14/2004
04/26/2007
FINDINGS, OF FACT AND CONCLUSIONS OF LAW
04/26/2007
-~~.
Public
03/26/2004
09/30/2005
PETITION FOR MODIFICATION OF SUPPORT W LFEE

CONFIDENTIAL
04/26/2007
Civil Case 02-3-02768-6
INFORMATION
FORM
05/15/2007
Public
07/16/2007
Public
1
1
11/16/2007
Public
09/04/2012
Public
10/25/2012
NOTICE OF INTENDED RELOCATIONOF CHILDREN
Confidential
10/25/2012
PROPOSED PARENTING PLAN
Public
11
11/13/2012
RETURN OF SERVICE
Public
Sealed
CONFIDENTIAL
12/05/2012
INFORMATION
FORM
12/11/2012
0
0
0
0
0
0
0
12/14/2012
ORDER AMENDING CASE SCHEDULE
Public
01/24/2013
ASSIGNMENT TO FAMILY COURT 1
Public
01/24/2013
LETTER FROM DEPARTMENT 16
Public
01/28/2013
0
0
0
0
Public
Public
Public
PROPOSED PARENTING PLAN
Public
11
SEALED JIS/JABS
Sealed
12/05/2012
12/05/2012
~2/05/2012
.-}12/05/2012
12/05/2012
12/11/2012
02/04/2013
03/11/2013
03/29/2013
03/29/2013
Public
Public
OBJECTION TO REQUEST FOR RELOCATIONWLFEE
Public
15
DECLARATIONOF JAMES R. DAHL
Public
ASSIGNMENT - RELOCATION
Public
RETURN OF SERVICE
Public
Public
2
2
REPORT
04/01/2013
Public
....
04/01/2013
PARENTING PLAN
Public
10
04/01/2013
ORDER ON MODIFICATION
Public
https://linxonline.co.pierce.wa.us/linxweb/Case/Civi1Case.cfm?cause_num=02-3-02768-6
EXHIBIT
2/5
\__
1 rn ~mniu1mw-1 ~
02-3..02768-6
40285928
-- ------
ORMDD
04-03-13
--
..,/
3
4
FILED
DE?T. ?.
IN OPEN COURT
A?R -12013
Pierce Co fy Clerk

County of PIERCE
8
9
10
13
No.
DEBORAH J DAHL
and
02-3-02768-6
JAMES R. DAHL
Respondent.
15
17
UTY
Order Re Modification/Adjustment
Of Custody Decree/Parenting
(ORMOD/ORDYMT)
Petitioner,
14
16
In re:
11
12
By-~~--
I.
Basis
This order is based on a petition for an order modifying the pnor custody decree/parenting
plan/residential schedule/judgment establishing parentage and an agreement of the parties.
18
II.
Findings
19
The Court Finds::
20
2.1
Jurisdiction
21
This court has jurisdiction over this proceeding for the reasons below
22
This court has exclusive continuing junsdiction. The court has previously made a child
custody, parenting plan, residential schedule, or visitation determination in this matter
and retains jurisdiction under RCW 26 27.211.
23
24
25
WPF D~PSCU 07 0400 Mandatory (7/2011) - RCW 26 09.260, .270;

26.10.200
Fam1iySoft FormPAK 2012
ORIGINAL

818 S Yakima Avenue, Suite 20 I
Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
tXHIBrr_,_
22909
"1/4/2613
'3B035
1
This state is the home state of the child because: the child lived in Washington with a
2
3
commencement of this proceeding and the child is are absent from the state but a parent
or person acting as a parent continued to five in this state.
4
5
parent have significant connection with the state other than mere physical, presence;
and substantial evidence rs available in this state concerning the child's care, protection,
training and personal relationships and the child has no home state elsewhere.
2.2
ModificationUnder RCW 26.09.260(1 ).(2)

The custody decree/parenting plan/residential schedule should be modified because a
substantial change of circumstances has occurred in the circumstances of the child or
the nonmoving party and the modification is in the best interest of the child and is
necessary to serve the best interest of the child. This finding is based on the factors
below:
10
11
12
The parties agree to the modification.
13
14
The following facts, supporting the requested modification, have arisen since the decree
or plan/schedule or were unknown to the court at the time of the decree or
plan/schedule:
15
16
Mother has taken a new job in North Carolina and father agrees that their
youngest daughter may move with her Mother based on the restdential schedule
negotiated by the parties, albeit the child's two older siblings (sisters) still reside
in Washington State.
17
18
19
2.3
20
21
Does not apply.
2.4
22
23
24
Modificationor AdjustmentUnder RCW 26.09.260(4} or (8}
Adjustmentsto Residential Provisions Under RCW 26.09.260(5}(a} and (b)

Does not apply.
2.5
Adjustmentsto ResidentialProvisions Under RCW 26.09.260(5)(c), (7), (9}

Does not apply.
25
Ord re Mod/Adj of Parenting Pin (ORMDD, ORDYMT) - Page 2 of 4
WPF DRPSCU 07.0400 Mandatory (7/2011)- RCW 26 09 260; .270,
26 10 200
Farn1lySoft FormPAK 2012

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
22989 4/4~2513 9~ti36
1
This section only applies to a person with whom the child does not reside
majority of the time who is seeking to increase residential time.
2.6
Adjustments to Nonresidential Provisions Under RCW 26.09.260(10)
4
The following non-residential aspects of the parentrng plan/residential schedule should
be adjusted because there rs a substantial change of circumstances of either party or of
the child and the adjustment rs in the best interest of the child:
5
6
Decision making.
7
Transportation arrangements.
8
9
2.7
10
Substantial Change in Circumstances

(Complete this part if
2.5.1, 2.5.3 or 2.6).
a modification or adjustment is based on paragraphs 2.2, 2.4,
11
The following substantial change has occurred in the circumstances of either party or of
the child:
12
13
Mother has taken a new job in North Carolina and father agrees that the child may move
deviation for his cost of travel or other costs and/or changes to the prior Order of Child
Support filed on March 26, 2004.
14
15
2.8
Protection Order
16
Does not apply
17
18
19
20
21
22
111.
It
ORDER
is Ordered:
The pennon to modify/adjust the custody decree or parenting plan/residential schedule is
granted. The custody decree or parenting plan/residentral schedule signed by the court
on this date and filed herewith is approved and incorporated as part of this order. This
decree or parenting plan/residential schedule supersedes all previous decrees or
parenting plans/residential schedules.
23
24
25
WPF DRPSCU 07.0400 Mandatory (7/2011) - RCW 26 09.260; 270,
26.10.200
FamslySofl FormPAK 2012

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-413 7
22909
4/~/2013
~8~37
1
2
Other:
Pierce County Superior Court shall retain jurisdiction over this matter until the child
reaches the age of rnajonty and/or is no longer m need of support (including
post-secondary support).
4
5
6
7
Dated:~_l-f_._f._l
3~--
8
9
Pr:esented by:
10
,~
~
11
28011
Lf//; . .,
En V. Berg
Date
Sig ature of Party or Lawyer/WSBA No.
Atto ney for Petitioner
12
13
14
15
Date
16
17
F}LEO
o~frr. ,buR"f
18
\N oPr:.N C
19
~?R - 11\l\1
20
21
22
23
24
25
WPF DRPSCU 07 0400 Mandatory (7/2011) - RCW 26 09.260; .270,
26 10 200
Fam1lySoft
FotmPAK 2012

Tacoma, WA 98405
Phone 253-272-0566 Fax 253-572-4137
mllBiT-~--
I ~1111111~ 11~111111111~ ml ~111111111111 ~111111111111111111111
200509261306 1 PG
09-26-2005 03:21pm $32.00
'- -'- - . .. .>.

__ _ 'JoSeph E. Bassett
.. , "
.. /
PIERCE COUNTY. WASHINGTON
MAIL TO:
_....Alp;RRECORPING
. - _... ;. Attorney at Law

Orchard Street
='."' .: .. }'.acomk,~A 98406
\._. . . . . ~.n2 North

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QUIT CLAIM DEED
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BY AGRE~NT_.OF
T~ PARTIES, THE GRANTOR, DEBORAH J. DAHL, a single woman, for

good and valuable'consideranonand inharmony with a Decree of Dissolution, Pierce County Cause No.
02-3-02768-6, conveysand quit-cla.im~-~o ,!AMES R. DAHL, a single man, as his separate property, all of
her interest in the :fullowirig described reil estate, situated in the County of Pierce, State of Washington,
together with all aftetacCjuir.ed titlp-Of the grant or herein: The Property located at 228 Contra Costa
Avenue, Tacoma, Washiriito9_.98466\_'furth~r legally described as:
Section 11 Township .. 20'RangeQ2 ~arter 12 REGENTS PARK:
REGENTS PARK I:: l l.TI:IJil:J--13 I) 5 SUBJ.TO
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...
ASSESSOR'S PROPERTY . .TAx PARCEL NUMBER: R 7160000710

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Signed this
_dj_ day ofSeptemb:r;Z'~s.- ..
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I certify that I know or have satisfactory evide~~ethat-O~~ORAH J -, DAHL is the person who
appeared before me, and said person acknowledged that she signed ~hiffo.~truiitent and acknowledged it to
be her free and voluntary act for the uses and purposes mentioned i~ this fo~ti:limEl!lt.
...
(D
Dated:
q ;)Y -oi;
NotQrV Public
State of Woshiu;rr.n
ANTJE BALU ;.
My Appointment Expires ;:_,.,,, -;;
....
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Not'."?' Public in al)d, for the S~t!of.Wa~h~~gt-~tt . .

Residing at
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MY, Commission Ex
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09-26-2005 03:18pm RCAROVA
EXCISE COLLECTED:$1,005.70
PRO.FEE $0.00
PAT MCCARTHY, AUDIT~
COUNTY FEE $0. 00
PIERCE COUNTY, WA
STATE FEE $5.00
. . .. .
'
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REAL ESTATE EXCISE TAX AFFIDAVIT
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P.LEAsi;.:r.::PE OR:;:RINT
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FOR USE AT COUNTY TREASURER'S OFFICE
BACIC~AGE
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This form is your receipt

when stamped by cashier.
CHAPTER 82.45 RCW - CHAPTER 458-61 WAC
Form No. 84--0001 B for Reponing Trarufers of Controlling Interest of Entity Ownership to the Department of Revenue)
THIS AFFIDAVIT WILL NOT BE ACCEPTED UNLESS ALL AREAS 1-7 ARE FULLY COMPLETED
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Street
ADDRESS
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and agricultural, or timber)? Chapter 84.34 ~CW
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organization? Chapter 84.36 RCW
Seller's Exempt Reg. No.
Receiving special valuation as historic

property? Chapter 84.26 RCW
~operty Type:
0 land only
~land with previously used building
timber only
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sincipal Use:
D timber
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(RCW 84.33 OR RCW 84.3~)
the new owner(s) of land that is designated as forest land or classified

s current use wish to continue the designation or classification, all new
wner(s) must sign below. The county assessor must then determine if the
-Tnd transferred continues to qualify and will indicate below. If the land
longer qualifies, it will be removed and the compensating or additional
axes will be due and payable by the seller or transferor at the time of sale.
CW 84.33.140
or RCW 84.34. I 08) If the new owner(s) does not desire
continue such designation or classification, all compensating or
CW<lditional ta' shall be due and payable by the seller or transferor at the
::z!l'ne of sale. (RCW 84.33.140 or RCW 84.34. I 08). Prior to signing
C Ue!ow, you may contact your loca1 County Assessor for more information.
Price
State
.~\
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sr.oo is
A MIN.IMUM.OF
/O/ 0. '16
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DUE AS A PROCESSING
3EE ti-isTRUGTit:JNS.FOR
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FEE AND TAX.
INTEREST AND PENALTIES
MFIDAV!T
Perju;:;,
This land
D does
D does
Date
not qualify for continuance.
I Certify Und~.p~;;~\~,;~
Under The Laws ofThe State of
Washington That The For!'g.~ingfs Trlle And Correct. (See back page of this
form).
'
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Signature
DEPUTY ASSESSOR
(2) NOTICE OF COMPLIANCE
(Chapter
84.26 RCW)
If the new owner(s) of property with special valuation as historic property

wish to continue this special valuation the new owner(s) must sign below.
If the new owner(s) do not desire to continue such special valuation, all
additional tax calculated pursuant to Chapter 84.26 RCW, shall be due
and payable by the seller or transferor at the time of sale.
(3) OWNER(S)
of
Gran tor/Agent _z.~~"'l?~{:f!L~....(L~I'..----------
SIGNATURE
Signature of
Grante~Agent:;i&.-.1,.i;t;~"""~~.:ZLL'{J,:.&,l~tf=:'.'....._
Name(print)_--,,..,,__,"'-"'-"'"'-""-"~~.:LA'1<-'"--'--------Date & Place of
~tit
Perjury: Perjury is a class C felony which is punishable by imprisonment

in the state correctional institution for a maxi~urn'i~~.of
ino~~.
than five years, or by a fine in an amount fixed by the court of not more than five thousand dollars ($5,000.00),
or by bot~U:npri9onn\.<;n{and
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fine(RCW9A.20.020(1C)).
'
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'
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Tl-tr<; SPACE TREASURER'S USE ONLY
11111111111111111m111111111111111111111111
4100169 1 PG
09 -26-2005 03: 1 Spm ACAROVA

EXCISE COLLECTED:$1,005.70
PAO.FEE:S0.00
PAT ~ATHY, AUDITOO
COONTY FEE:S0.00
PIERCE COUNTY, WA
STATE FEE:$5.00
\'
v..
counrv u:fEA?t:JRE'R
---
--...----
------ --- -----
1
02-3-02768-6
43789468
CME
12-15-1'1
0
0
.-.
~-)

DEBORAH J DAHL

Petitioner(s)
-J
vs
JAMES R DAHL
(\j
Respondent(s)
Judge/Commissioner: KA THERINE M. STOLZ
Court Reporter: KIMBERLY ONEILL
Judicial Assistant: LINDA SHIPMAN
...
(\j
,_,
DAHL, DEBORAH J
DAHL, JAMES R
SANDRA E. JOHNSTON
DAHL, AMANDA
DAHL. SARAH J
DAHL, ELIZABETH R
Proceeding Set: Motion - Compel
Proceeding Date: Dec 12, 2014 9:47 AM

Resolution:
Clerk's Code: MTHRG
Memornadum
Pagel of 2
of Journal Entry.
~.~.:.~.~:.~. ~.:.:.?..~~.~~?..~ . :.?. ~~.:
..
02-3-02768-6

DEBORAH J DAHL
vs
JAMES R DAHL

/Memorandum
of Journal Entry
Judge/Commissioner: KATHERINE M. STOLZ

Start Date/Time: Dec 12, 2014 9:44 AM

. .:r
r-i
()
(\j
December 12, 2014 09:44 AM - Respondent's motion for protection of financial discovery
argued by Respondent's counsel, Sandra Johnston and Petitioner's counsel, Thomas Cena, Jr. 09:
47 AM - Motion granted. Court retains jurisdiction for the modification.
End Date/Time: Dec 12, 2014 9:47 AM
Memornadum of Journal Entry.

Pagc2 of 2
E-FILED
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASIDNGTON

7
8
DEBORAH J. DAHL,
NO. 02-3-02768-6
Petitioner,
10
and
NOTICE OF ABSENCE &

UNAVAILABILITY
11
JAMES R. DAHL,
Respondent
12
13
Clerk of the Court

Thomas Anthony Cena, Attorney for Petitioner
To:
And To:
14
15
served either upon her or appearances be scheduled, which requires her or the client's attention either
16
in person, by pleading. Because Ms. Johnston is a sole practitioner, she also requests that no action
17
requiring her attention be initially noted or calendared for 2 days immediately following her
18
absence to allow adequate preparation and time to contact her client/ s.

1.
19
December 22, 2014 to January 5, 2015;

Ms.] ohnston cannot supervise or introduce another attorney to the facts involved in this case,
20
during her absence. Terms and sanctions will be requested should any matter requiring her attention or
21
attendance be scheduled as noted above in order for the client/ s to obtain the services of substitute
22

23
Dated this 15th day of December, 2014.
24
25
NOTICE OF ABSENCE &

UNAVAILABILITY
Page 1of1

Phone 253-272-0566;
FAX 253-572-4137
-- .
--------
II
I.
~.-
' .
II
Ir
02-:}-02768-6
43789457
--- ----
11
12-15-!4
OR
2
3
4
5
l'I'"',
\_.!t
6
7
IN THE SUPERIOR COURT OF THE ST ATE OF WASHINGTON

8
9
10
In re the Maniage of:

DEBORAH J. DAHL,
11
12
13
NO. 02-3-02768-6
Petitioner,
and
ORDER RE DISMISSAL, REMOVAL,

PROTECTION OF FINANCIAL
DISCOVERY & AWARD OF ATTORNEY
FEES &COSTS
JAMES R. DAHL,
Respondent
14
15
THIS MATTER having come on regularly for hearing before the above-entitled court;
16
and the Respondent appearing in open Court by and through his attorney, Sandra E. Johnston,
17
and the Petitioner appearing, and having heard arguments from counsel, read the motion herein,
18
and therefore it is
19
ORDERED that
20
1.
Respondent's motion to dismiss this matter is OR AJSJTm:>I DENIED I aft A:fsITEt: ~.
21
flA"fH,
22
2. Respondent's motion to remove Attorney Cena due to a conflict of interest created by the
23
24
25
relationship of Mr. Dahl's former counsel herein, that is, Attorney Scott Candoo, is
GRANTED /-BEfvIB~;
OF FINANCIAL DISCOVERY & A WARD OF
Page 1 of2
ORIGINAL

Phone
253-272-0566;
FAX
253-572-4137
-.
1
3. Respondent's motion to protect his financial data from Attorney Cena is GRANTED I
2
3
4
(@
Dti~HISS~
4.
-r~
~motiorsfor Attorney's
lttspo~fs
fees and costs is W AN'f'ED t Dti?<JI"ECJ:J
"tiR A N I FD Psf t?.\lt"f I RESERVED
5. -Respondent is hereby awarded

f:'ll)
11blc te Respondent on
01
in Attorney's fees, whiefl: skall.be
...
bcm1 e
7
8
9
-..
.- 1
r..J
10
<,.,
11
12
(1
;i
13
14
15
16
17
DATED this
18
19
lz
20
21
Presented By:
22

OF FINANCIAL DISCOVERY & AWARD OF
Page2of2

Phone 253-272-0566; FAX 253-572-4137
\I I
D
(]
02-3-02768-6
43789475
CME
12-15-14

DEBORAH J DAHL
Petitioner(s)
d
VS
JAMES R DAHL
t\J
Respondent(s)
".,
Judge/Commissioner: KATHERINE M. STOLZ

U)
~...
(\]

DAHL, DEBORAH J
DAHL, JAMES R
SANDRA E. JOHNSTON
DAHL, AMANDA
DAHL, SARAH J
DAHL, ELIZABETH R
Proceeding Set: Motion - Dismiss
Proceeding
,.,.<o
Resolution:
//
l.
( \\~
;:_:;.\.~. '2. ~~"{

Q'i:.~ cO
o~f;.~
'\\t\, \

Page! of 2
Date: Dec 12, 2014 9:43 AM
Clerk's Code: MTHRG

i 1,.\\\\.\
'
Amended Resolucton code:
1:0
02-3-02768-6
0
0

j
DEBORAH J DAHL
vs
JAMES R DAHL

Judge/Commissioner:
!-,
KATHERINE M. STOLZ
Start Date/Time: Dec 12, 2014 9:18 AM

-..t
~-1
()
(\I
.O
December 12, 2014 09:18 AM - Respondent's motion to dismiss and motion to remove
attorney argued by Respondent's counsel, Sandra Johnston and Petitioner's counsel, Thomas
Cena, Jr. 09:43 AM - Respondent's motion to dismiss is denied. Respondent's motion to remove
Atty T. Cena, Jr. granted. Attorney fees/costs reserved. Court sets an Assignment to Set Trial
Date for 1/23/15 at 9:00 a.m.
(\J
End Date/Time: Dec 12, 2014 9:43 AM

Pugcz of 2
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
2
3
4
5
6

7
8

DEBORAH J. DAHL,
NO. 02-3-02768-6
Petitioner,
10
11
and
NOTICE OF WITHDRAWAL
AND SUBSTITUTION OF
COUNSEL
JAMES R. DAHL,
Respondent.
12
[CLERK'S ACTION REQUIRED]

13
14
TO:
AND TO:
AND TO:
JAMES R. DAHL
SANDRA E. JOHNSTON, his attorney of record
CLERK OF THE COURT
15
YOU AND EACH OF YOU please take notice that the under-signed, whose
16
address is stated below, hereby withdraws as Attorney of Record for Deborah J. Dahl, the
17
above named petitioner.
18
YOU ARE FURTHER notified that Sophia M. Palmer of the law firm of Benjamin
19
& Healy, P.L.L.C., located at 1201 Pacific Avenue South, Suite C7, Tacoma, WA 98402
20
is hereby substituted as Attorney of Record for the withdrawing counsel.
21
Copies of all further documents and proceedings herein, except original process,
22
shall be served upon the substituted Attorney of Record along with all others above named.
23
24
25
26
NOTICE OF WITHDRAWAL AND

Page 1of2
BENJAMIN &HEALY
A ProfessionalLimited Liability Company
ATTORNEYS AT LAW
1201 Pacific Ave Suite C7
TACOMA, WA 98402
PHONE 253-512-1196
FAX 253-512-1957
This withdrawal and substitution of attorneys is effective immediately.
2
3
DATED this 16th day of December 2014.
4
5
6
7
Thomas Anthony Cena, Jr., WSBA No. 6539
9
10
NEW ATTORNEYS OF RECORD:

Benjamin & Healy, P.L.L.C.,
11
12
13
Attorneys for Petitioner
14
15
16
17
18
19
20
21
22
23
24
25
26
NOTICE OF WITHDRAW AL AND

Page 2of2
BENJAMIN & HEALY

A Professional Limited Liability Company
ATIORNEYS AT LAW
TACOMA, WA 98402
PHONE 253-512-1196
FAX 253-512-1957
2
3
4
5
6
7
8
9

County of Pierce
Inre:
No. 02-3-02768-6
DEBORAH J. DAHL,
DECLARATION RE SIGNATURE
ON ELECTRONIC DOCUMENT
10
11
12
Petitioner,
and
JAMES R. DAHL,
13
Respondent.
14
15
I, RHONDA L. DURHAM, declare under penalty of perjury, under the laws of the
16
State of Washington, that the foregoing electronic document attached to this declaration,
17
which consists of three (3) pages, including this declaration page, is a complete and legible
18
image that I am have examined personally and that was received by me via email.
19
Signed this 16th day of Decembe /2
"
20
21
RHONDA L. DURHAM
22
23
24
25
Declaration
THOMAS A CENA, JR.

Attorney at La
(253) 572-5120 Fax: (253) 593-4503
E-MML: [email protected]
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6
7

8
9
10
NO. 02-3-02768-6
DEBORAHJ. DAHL,
11
Petitioner,
and
12
JAMES R. DAHL,
13
Respondent
DECLARATION OF ATIORNEY
SANDRA E. JOHNSTON RE
PETITIONER'S FAILURE TO
STIUKE SHOW CAUSE IN
COMMISSIONER'S COURT
14
I, Sandra E. Johnston, Attorney for Respondent, do declare as follows. I am competent to

15
testify regarding the contents herein, over the age of 18, and make this declaration on personal
16
knowledge.
17
On December 12, 2014, Judge Stolz kept jurisdiction of this matter and instructed the
18
Petitioner to strike her show cause currently set in Commissioner's Court for December 24,
19
20
2014. Judge Stolz set a return to her Court for January 23, 2015 in order to determine a setting
21
for a full hearing on support modification, support past the age of 18 and post-secondary support.
22
During that hearing Attorney Cena was also instructed to withdraw from the Petitioner's matter.
Attorney Cena failed to strike Petitioner's motion prior to his withdrawal from this
23
24
matter.
25
DECLARATION OF ATIORNEY SANDRA E.
JOHNSTON RE PETITIONER'S FAILURE TO
STRIKE SHOW CAUSE IN COMMISSIONER'S
COURT
Page 1 of2

Phone
253-272-0566;
FAX
253-572-4137
2
3
On December 16, 2014, Petitioner obtained new counsel, Sophia Palmer, for this matter.
That same day I emailed her regarding the above listed information, asking her to strike
Petitioner's show cause motion. I attempted to reach Ms. Palmer again today without success.
My office will be closed the last two weeks of December, including Christmas Eve. My
5
notice of absence is filed herein. Petitioner's motion is still pending in Commissioner's Court.
6
Respondent does herby give notice that if Petitioner appears for the current setting in
7
8
9
10
11
12
13
Commissioner's Court on an exparte basis, Respondent will seek his fees and costs before Judge
Stolz for having to subsequently address Petitioner's contempt of the Court's order and
instruction.
Signed and sworn in Tacoma, Washington on
s 18th day of
14
15
16
17
18
19
20
21
22
23
24
25
DECLARATION OF ATIORNEY SANDRA E.

JOHNSTON RE PETITIONER'S FAILURE TO
STRIKE SHOW CAUSE IN COMMISSIONER'S
COURT
Page2 of2

Phone
253-272-0566;
FAX
253-572-4137
J ~
THE STATE OF WASHINGTON
ERCE COUNTY
r=.
02-3-02768-6
44071365
02-04-15
ORACS
No. 02-3-02768-6
'1
I.
DEBORAH J DAHL
ORDER AMENDING
CASE SCHEDULE
Petitioner(s)
vs.
Type of Case:
Estimated Trial (days}:
Track Assignment:
Assigned Department:
Docket Code:
JAMES R DAHL
Respondent(s)
i<':
tf;
Set Settlement Conference Date with Judge/Commissioner

PCLSPR 94.04)
Plaintiffs/Petitioner's
DIC
1
Dissolution
02 - Judge KATHERINE M. STOLZ
ORACS
KATHRYN J. NELSON (See PCLR 16 &
Disclosure of Primary Witnesses
Defendant's/Respondent's
Disclosure of Primary Witnesses
EP1 2
01'
~~~~~~~~~~~~~~~~~~~-1-~o-~:c0Uv..~,-~~~~~~-
06/30/15
_D_is_c_1o_s_ur_e_o_f_R_eb_u_tt_a1_w_itn_e_s_se_s_.
07121/15
,_\tl oPE''
~--~co---~-1U\~..._ __ ,
_D_e_a_dl_in_e_fo_r_F_il_in_g_M_o_tio_n_t_o_A_dJ_u_st_T_ri_a_lD_a_te
(\j
r L.0
Discovery Cutoff
Exchange of Witness and Exhibit Lists and Documentary
Exhibits
Joint Statement of Evidence

t\l
06/02/15
=" -~.~.....,,
~------~~----------------7'--f\u;i,i~--~----------
1(.
i, j
05/19/15
0_81_0_41_1_5
09/08/15
09/22/15
09/22/15
Settlement Conference (To be held)
Week Of 10/06/15
Pretrial Conference (Contact Court for Specific Date)
Week Of 10/13/15
Trial
10/20/15 9:00
Unless otherwise instructed, ALL Attorneys/Parties shall report to the trial court at 9:00 AM
on the date of trial.
If the case has been filed, the plaintiff shall serve a copy of the Case Schedule on the defendant(s) with the summons and
within five (5) court days of service of the defendant's first response/appearance. If the case has not been filed, but an
All attorneys and parties shall make themselves familiar with the Pierce County Local Rules, particularly those relating to
DATED: 2/3/15
Judge Katherine M. Stolz

Department 02 {25J) 798-7573
~- ..
No. 02-3-02768-6
l'i")
11i DEBORAH J DAHL
ORDER AMENDING
CASE SCHEDULE
Petitioner(s)
vs.
JAMES R DAHL
Respondent(s)
Li,
CC:
Type of Case: DIC

Estimated Trial (days): 1
Track Assignment: Dissolution
Assigned Department: 02 - Judge KATHERINE M. STOLZ
Docket Code: ORACS
SANDRAE. JOHNSTON,Atty
Sophia May Palmer, Atty
L\l
1\j
'-,
(\J
Page 2 of 2
E-FILED
February 19 2015 2:55 PM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
2
3
4
5
6
7
County of Pierce
9
10
In re the Marriageof:
11
Motion and Declarationfor

TemporaryOrder
(MTAF)
Petitioner,
12
and
13
JAMES RICHARD DAHL

Res ondent.
14
I.
15
16
No. 02-3-02768-6
DEBORAH JEAN DAHL
Motion
Based on the declaration below, the undersigned moves the court for a temporary order which
orders child support as determined pursuant to the Washington State child support statutes.
17
18
Dated:
oZJ tJ ':}j) /CJ
19
20
21
22
23
24
25
Mtn/Decl for Temp Ord (MTAF) - Page 1 of 4
WPF DR 04.0100 Mandatory (6/2014)- RCW 26.09.060; .110; .120; .194
FamilySoft Form PAK 2014
BENJAMIN & HEALY

ATIORNEYS AT LAW
TACOMA, WA 98402
PHONE 253-512-1196
FAX 253-512-1957
II.
Declaration
2
I am asking the court to set temporary support in the amount of $974.31 commencing
3
January 1, 2015.
4
Our most recent order of child support was entered March 26, 2004. It requires James to
5
pay child support for our three children in the amount of $928.12 per month. Two of our three
6
children are no longer dependent and therefore no longer subject to the support order.
7
However, our youngest child, Elizabeth is in her final year of high school, still living at home, and
8
still dependent.
9
Pursuant to the March 26, 2004 order, support terminated as follows:
10
13
11
14
12
15
13
16
3.13
TERMINATION OF SUPPORT.
Support shall be paid:
17
14
18
15
19
Until the children reach the age of 18, except as

otherwise provided below in Paragraph 3.14.
3.14
POST SECONDARY EDUCATIONAL SUPPORT.

The right to petition for post secondary support is
reserved, provided that the right is exercised before
support terminates as set forth _in paragraph 3.13.
16
Thus, pursuant to this order, Elizabeth's support terminated January 1, 2015. However,
17
I filed the instant action in June 2014, well before support terminated. Because her support has
18
terminated under the existing order, and trial' is not set in this matter until October 2015, I am
19
asking the court to set temporary support in the amount of $974.31.
20
JAMES' INCOME
21
James is paid bi-weekly, for a total of 26 times per year. In calculating James' income, I
22
used his 12/12/2014 paystub it reads as follows:
23
24
1
25
Because James has raised the issue of reimbursements that Judge Stolz deemed too complex to be
heard on the Commissioner's docket, an actual trial is going to be held in this matter in October 2015 to
determine what exactly is owed, and what reimbursements, if any, James is entitled to.
Mtn/Decl for Temp Ord (MTAF) - Page 2 of 4
BENJAMIN & HEALY
WPF DR 04.0100 Mandatory (6/2014) - RCW 26.09.060; .110; .120; .194
ATTORNEYS AT LAW
TACOMA, WA 98402
PHONE 253-512-1196
FAX 253-512-1957
$21,090.65
$1,283.84
$54,268.58
Mileage
Bonus payout
$750.00
Safety Bonus
$794.75
Triples
$6.71
$641.92
Unused sk PY
Vac Payout
$1,557.20
Vacation
$3,114.40
$83,508.05
However, because he received one more paycheck for 2014 which has not yet provided,
Regular
Holiday
4
5
6
some of his 2014 income is missing. Therefore, I approximated it as follows:
10
Regular
Holiday
11
Mileage
Bonus payout
12
Safety Bonus
Triples
13
Unused sk py
14
Vac Payout
Vacation
15
16
17
18
19
20
$21,090.65 +25
$843.63
$1,283.84
$54,268.58 +25 $2,170.74
$750.00
$794.75
$6.71
$641.92
$1,557.20
$3,114.40
$83,508.05
$86,522.42
$7,210.20
I took the average of his regular and mileage pay by dividing his YTD totals by 25 (the number of
pay periods thus far) to get his per paycheck average. I then added those amounts to his 12/12/14 YTD
total to reach an annual gross income of $86522.42 or $7210.20 per month. However, there may
additional income he received as I do not know if he has received any other additional income for 2014
such as safety bonus, triples, etcetera.
21
The only deduction I included was his $68.96 contribution to his 401 (k). This results in net income
22
to him of $5343.81 per month.
23
24
25
Mtn/Decl for Temp Ord {MTAF) - Page 3 of 4
WPF DR 04.0100 Mandatory (6/2014) - RCW 26.09.060; .110; .120; .194
BENJAMIN & HEALY

ATTORNEYS AT LAW
TACOMA, WA 98402
PHONE 253-512-1196
FAX 253-512-1957
2 .I l. 7 .I 2 0 l. G
4.
4. 4.
7 l.
DM
DAC.
:w:
7 '004.
1
MVINCOME
I am paid a monthly salary of $n35.00. From that, the following is deducted: federal income
taxes, FICA1 North Carolina income taxes, health and dental premiums, a 2% mandatory 403(b) payment,
and a voluntary contribution of $309.40.
1. Gross Monthl Income
----a. Wjl_g~s and Salarle~------- ---

. Tot9I Gross Monthl Income add lines 1 a tnrou h 1 f
MQth r
- .1:!..i1.,_.:.__
$7,7:;15.0D
2. Monthly Deductions from Grass Income

7
8
9
10
11
Also included In my proposed child support worksheets, ls the costs I pay for Elizabeth's
12
medical premiums and dental premiums as follows: the cost for my medical coverage is $105
13
and $325 when I add Elizabeth, making the portion for covering just her $220.00. The cost for
14
my dental coverage is $19 and $46 when I add Elizabeth, making the portion for covering just
15
her $27.
16
Based on the foregoing the monthly transfer payment should be !974.31.
I
17
CONCLUSION
18
I ask the court enter a temporary order of support requiring James to pay $974.31. I ask
19
the start date be January 1 , 2015.
20
21
foregoing is true and correct.
22
Signed at
23
24
w~l,i Labrt..
~0::._:!'
~":J!..-~
Jt\)~L
NC,, JOf1ded-i18'JO~~y
laws :;';he
of
perjury
~D-e".""tb~or"""'a..,h"'!D~a-h-1-.......~~.,~-...-..i....._
electronic
declaration, which consists of ~
S'
complete
'!)"j(Jd':::!_
1gnature of Requesting Party
25
Mtn/Decl for Temp Ord {MTAF) -Pape 4 of 4
under
and legible
page(s) is a
image that I have examined

was received by me via fax
personally and :.h::(\

at the follov
.umber
253-512-1957
or
Dated''--~""-""'"--
WPF DR 04.0100 Mandatory (6/2014}- RCW 26.09.060; .110; .120; .194
~~~~e~~~!!!!l~l\..--A
f=amllySatt FormPAK 2014
the
Si.te
of Washington, that the foregoing
document(s)
attached
to
this
1201 Pacific Ave Suite C.7

TACOMA. WA 98402
PHONE 25:1-512-1196
FAX 2S'.JSl219S7
via
E-FILED
February 19 2015 2:55 PM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
No. 02-3-02768-6
Petitioner(s),
vs.
JAMES R DAHL
Respondent(s)
Phone: (253) 272-0566

Motion
Nature of Hearing: Other MOTION FOR TEMPORARY ORDERS
CALENDAR DATE: Friday, February 27, 2015 9:00 AM

Submitted by:
DATED:
February 19, 2015.
Signed:
/s/ Sophia May Palmer
NAME:
Sophia May Palmer
Phone:
(253) 512-1196
WSBA#:
For:
37799
ADDRESS: 1201 Pacific Ave Ste C7

Tacoma, WA 98402-4393
1 of 1
E-FILED
February 25 2015 8:30 AM
l
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5
6

7
8
DEBORAH J. DAHL,
Petitioner,
10
and
ll
JAMES R. DAHL,
MOTION & DECLARATION OF

ATTORNEY SANDRA E.
JOHNSTON RE RESPONDENT'S
MOTION TO CONTINUE
Respondent
12
13
MOTION
14
15
E. Johnston, and moves this Court for an order continuing the hearing currently set for February
16
1.1
18
19
Respondent further moves the Court for the payment of his actual attorney's fees, which he
has incurred and will incur as a result of having make said motions. An affidavit of fees will be
21
22
Respectfully submitted this 24th day of February, 2015.

23
24
25
Mt1TION & DECLARATION OF AITORNEY

SANDRi\ E. JC'rn:TNSTON !tE R'ESl?'(uNlClEN'f"S
MO.TICH' TO CON'l'lf:iJUE
Page l cif 3

705 s. gtti Street, Suite 104
Phone 253-272-0566; FAX 253-572-4137
2
3
4
DECLARATION
knowledge. Finally, I do hereby adopt by reference those attachments hereto.
On or about Thursday, February 19, 2015, Attorney Palmer and I discussed whether a
6
motion for temporary orders would be appropriately brought before Judge Stolz. I informed Ms.
7
Palmer that it was my belief that the Court wanted to hear testimony on it prior to extending child
8
support beyond the child's 18 birthday, as the order limiting child support to age 18 was an agreed
9
order entered ~y the lJarties and material to my client's entry ofsaid order. I told Ms. Palmer that was my
10
11
12
understanding from the hearing before Judge Stolz on 11/14/14, regardless of what she read to me
from the subsequent hearing on 12/12/14 and one of the reasons why we were both surprised that
13
the trial was set October 20, 2015 (although being mindful and sympathetic of the Court's already
14
burgeoning trial calendar).
15
I asked Ms. Palmer to set her hearing for some time in the middle to end of March (as would
16
be the normal calendaring if we were to have the matter heard in Commissioner's Court as would be
17
the ordinary course but for the Court keeping jurisdiction of the matter). I explained that I was
18
preparing to go out for a special set criminal trial on Tuesday, March 3rd. Apparently Ms. Palmer
19
ignored my request and set it for her first available Friday, on February 27, 2015.
20
21
Also on February 19th, I immediately called Kim O'Neill, the Court Reporter for this matter,
and left a message requesting a transcript of the 11/14/14 hearing. She emailed me that she was out
22
ill, but would let me know when she would be back and available. See attached email.
23
On Friday, February 20th, I informed Ms. Palmer of Ms. O'Neill's unavailability and asked
24
her to re-note her motion. That day, I also discovered that I was previously set to do a property
25
examination near Ashford, Washington (almost an hour and a half away) at 10:00 am on Friday the
MOTION & DECLARATION OF ATTORNEY
SANDRA E. JOHNSTON RE RESPONDENT'S
MOTION TO CONTINUE
Page 2 of3

Phone
253-272-0566; FAX 253-572-4137
2
3
4
5
zr: and will certainly not be available if I must depart at 8:30 am on February zr:
I made Ms.
Palmer aware of the same. See attached email.

On Monday, February 23, 2015, I received the attached email from Ms. Palmer suggesting
that she needed permission from her client to re-calendar a date, for which I was never available to
appear in the first instance.
On Tuesday, February 24, 2015, I did not hear back from Ms. Palmer. Nor have we
7
received word of whether Ms. O'Neill has recovered. Wednesday, February 25, 2015 is our
B
response deadline per the current motion setting, which Respondent will be unable to meet.
9
I am not available to meet with Mr. Dahl prior to his filing deadline. I am also not available
10
11
12
13
for the hearing currently set for Friday, February 27, 2015. I am a solo practitioner. There is no
one available to stand in my place for said hearing or to meet with Mr. Dahl on such short notice.
I ask that the transcript be made available prior to having the matter heard.
I ask that it be
14
re-noted for March 27, 2015, or later, as that is my first available date now in March. Finally, I ask
15
for attorneys' fees for the hour it took me to respond to and ask for this courtesy (of continuance);
16
especialfy in light of the signfficanty additionaltime (almost two months~vast her dead/in~). which Rtspondentqfforded
17
Ms. Dahl to answer inteTTOgatories, for which it appears that we must also bring a motion to compel
18
answers for missing data. Hearing these matters together will best effectuate judicial economy and
19
can be done together on March 27, 2015.
20
21
22
Signed and sworn in Tacoma, Washington on thi
4th day of February, 2015.
23
21~~
24
a E. Johnsto /
SA #27313
ey for Respo de t
25
MOTION & DECLARATION OF ATTORNEY

SANDRA E. JOHNSTON RE RESPONDENT'S
MOTION TO CONTINUE
Page 3 of3

705 s. glh Street, Suite 104
Phone
253-272-0566;
FAX
253-572-4137
Sandra E. Johnston
From:
Sent:
To:
Subject:
Sophia M. Palmer <[email protected]>

Monday, February 23, 2015 10:58 AM
Sandra E. Johnston
RE: In re the Marriage of Dahl and Dahl
"""'"<:"------ ( { z s }15
Sandra,
I have not yet spoken to my client. I will try to do so today.
Regards,
Sophia
Sophia M. Palmer
Attorney at Law
Benjamin & Healy, PLLC
Attorneys at Law
1201 Pacific Avenue, Suite C7
Phone: (253} 512-1196
Fax: (253} 512-1957
This e-mail is covered by the Electronic Communications Privacy Act, 18 U.S.C. secs. 2510-2521, and is legally privileged
and confidential. If the reader of this message is not the intended recipient, the reader is hereby notified that any
unauthorized review, dissemination, distribution, or copying of this message is strictly prohibited. If you are not the
intended recipient, please contact the sender by reply e-mail or call the sender at (253) 512-1196, and destroy all copies
of the original message
From: Sandra E. Johnston [mailto:[email protected]]
Sent: Friday, February 20, 2015 3:46 PM
~----------To: Sophia M. Palmer
Cc: [email protected]
Subject: FW: 1n re the Marriage of Dahl and Dahl
2(ZD/ 15
Sophia:
I still have heard back from you regarding my reasonable request to set over your motion. My client was very patient
with your client's failure to promptly provide interrogatory answers, by over a month (and I still don't have her
answers}. Now I find that I was scheduled weeks ago for a property inspection on the
As I have already told you, I
will not be available on your motion date. I will have my legal assistant show up with my declaration and a for
continuance if I must. There is only one of me and I gave you my objections prior to your filing. With all of the extra
time I gave your client to answer her interrogatories, I do not believe she will have clean hands if you insist on appearing
on the 27th. I will seek fees if I must hire another lawyer to appear to continue this matter. Please re-note your motion
zz".
Kind Regards,
S41141M. E. ~
Attorney At Law
1

Office: 253-2 72-0566
Fax: 253-572-4137
From: Sandra E. Johnston [mailto:[email protected]]

Sent: Friday, February 20, 2015 8:09 AM
To: 'Sophia M. Palmer'
Subject: FW: In re the Marriage of Dahl and Dahl
Sophia:
Apparently there will be a delay in getting the transcript of the Court's ruling of November
you will postpone your current setting.
n".
Please advise whether
Kind Regards,
Sdlltllr4. E. ,.,_,,
Attorney At Law
Office: 253-2 72-0566
Fax: 253-572-4137
From: [email protected] [mailto:[email protected]]

Sent: Thursday, February 19, 2015 8:29 PM
L------
To: [email protected]
"'=
Subject: In re the Marriage of Dahl and Dahl
Z/ttt/r5
Hello, Sandra,
This is Kim O'Neill. You had called and left me a detailed message on this case. I did get your message. I called
remotely for it from home. I am very ill with pneumonia right now and am off work on doctor's orders. I am
hoping to get back on Monday, but we'll see. I'll have to look into this after I get back, and I'm very sorry for the
delay. I know you have a dilemma! LOL. ...
I guess I have a dilemma, too, so we both have dilemmas right now ... oh, gosh, it hurts to laugh .....
Take care,
Kim O'Neill
Court Reporter
The Honorable Katherine M. Stolz
E-FILED
March 03 2015 10:49 AM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
No. 02-3-02768-6
Petitioner(s),
vs.
JAMES R DAHL
Respondent(s)
Phone: (253) 272-0566

Motion
Nature of Hearing: Other MOTION FOR TEMPORARY ORDERS
CALENDAR DATE: Friday, March 13, 2015 9:00 AM

Submitted by:
DATED:
March 3, 2015.
Signed:
/s/ Sophia May Palmer
NAME:
Sophia May Palmer
Phone:
(253) 512-1196
WSBA#:
For:
37799
ADDRESS: 1201 Pacific Ave Ste C7

Tacoma, WA 98402-4393
1 of 1
E-FILED
March 05 2015 2:50 PM
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6

DEBORAH J DAHL
No. 02-3-02768-6
Petitioner(s),
vs.
JAMES R DAHL
Respondent(s)
Name: Sophia May Palmer
Address: 1201 Pacific Ave Ste C7 Tacoma, WA 98402-4393
Phone: (253) 512-1196

Motion
Nature of Hearing: Other COMPEL, FEES, AND CONTINUE MOTION FOR TEMP SUPPORT
CALENDAR DATE: Friday, March 13, 2015 9:00 AM

Submitted by:
DATED:
March 5, 2015.
Signed:
NAME:
SANDRA E. JOHNSTON
Phone:
(253) 272-0566
WSBA#:
For:
27313
ADDRESS: 705 S 9TH

STE 104
TACOMA, WA 98405
1 of 1
E-FILED
March 04 2015 8:30 AM
1
KEVIN STOCK
COUNTY CLERK
2
NO: 02-3-02768-6
3
4
5
6

7
8
DEBORAH J. DAHL,
NO. 02-3-02768-6
Petitioner,
10
and
11
JAMES R. DAHL,
Respondent
12
13
To:
And To:
Clerk of the Court

Thomas Anthony Cena, Attorney for Petitioner
14
15
NOTICE OF ABSENCE &

UNAVAILABILITY
served either upon her or appearances be scheduled, which requires her or the client's attention either
16
in person, by pleading. Because Ms. Johnston is a sole practitioner, she also requests that no action
17
requiring her attention be initially noted or calendared for 2 days immediately following her
18
absence to allow adequate preparation and time to contact her client/ s.

1.
19
March 13J 2015 to March 23J 2015;

20
during her absence. Terms and sanctions will be requested should any matter requiring her attention or
21
attendance be scheduled as noted above in order for the client/ s to obtain the services of substitute
22
23
Dated this 3td day of January, 2015.

24
25
NOTICE OF ABSENCE &

UNAVAILABILITY
Page 1of1
The Law Office
SANDRA E. JOHNSTON

Phone 253-272-0566; FAX 253-572-4137
E-FILED
March 04 2015 8:30 AM
1
KEVIN STOCK
COUNTY CLERK
NO: 02-3-02768-6
3
4
5

7
B
DEBORAHJ. DAHL,
NO. 02-3-02768-6
Petitioner,
10
and
11
JAMES R. DAHL,
Respondent
12
13
SECOND MOTION &

DECLARATION OF ATIORNEY
SANDRA E. JOHNSTON RE
RESPONDENT'S MOTION TO
CONTINUE HEARING TO 3/27 /15
MOTION
14
COMES NOW Respondent, James R. Dahl, by and through his attorney of record, Sandra
15
E. Johnston, and moves this Court for an order continuing the hearing currently set for March 13,
16
17
18
19
2015 due to the unavailability of counsel during the day (2 week criminal trials back-to-back - See
State v Maass cases) and the unavailability of Mr. Dahl at night due to his work schedule.
Respondent further moves the Court for the payment of his actual attorney's fees, which he
20
has incurred and will incur as a result of having to make said motion. An affidavit of fees will be
21
22
Respectfully submitted this 3rd day of March, 2015.

23
24
25
SECOND MOTION & DECLARATION OF

ATTORNEY SANDRA E. JOHNSTON RE
RESPONDENT'S MOTION TO CONTINUE
Page 1 of2

Phone 253-272-0566;
FAX
253-572-4137
DECLARATION
2
3
4

knowledge. Finally, I do hereby adopt by reference those attachments hereto.
As I previously told opposing counsel and the Court, via motion filed on 02/25/15, that I
am not available to meet with Mr. Dahl prior to his filing deadline. I am a solo practitioner. There
7
is no one available to stand in my place for said hearing or to meet with Mr. Dahl on such short
B
notice and I must focus on the current criminal trials, which are 2012 cases (the defendant has two
9
cases that the Court wants to be tried back-to-back) and will be assigned out as soon as a Courtroom
10
is available because they are three years old (and perhaps the oldest on the list).
11
12
13
Again, I ask that the opposing parties' motion be re-noted for March 27, 2015, or later, as
that is my first available date now in March. Finally, I ask for attorneys' fees for the hour it took me
14
to respond to and ask for this courtesy (of continuance); especial/yin light ofthe significantfy additionaltime
15
(almost two monthspast her dead/in~). which RespondentffffordedMs. Dahl to answer interrogatories, for which it
16
appears that we must also bring a motion to compel answers for missing data and for having to file
17
a second motion regarding my unavailability. Hearing these matters together will best effectuate
18
judicial economy and can be done together on March 27, 2015.
19
20
21
Signed and sworn in Tacoma, Washington on
22
23
24
25
SECOND MOTION & DECLARATION OF

ATTORNEY SANDRA E. JOHNSTON RE
RESPONDENT'S MOTION TO CONTINUE
Page2 of2

Phone 253-272-0566; FAX 253-572-4137

Deborah Jean Dahl v. James Richard Dahl 02-3-02768-6

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02-3-027686

1N COUNTY CLERK'S OFFICE

BOB SAN SOUCIE

SUPERIOR COURT OF WASHINGTON

Additional requests, if any, are stated in the petition, a copy of which

You must respond to this summons and petition by serving a copy of

EISENHOWER & CARLSON, PLLC

Your written response to the summons and petition must be on form

If you wish to seek the advice of an attorney in this matter, you

One method of serving a copy of your response on the petitioner is to

This summons is issued pursuant to Superior Court Civi

SERVE A COPY OF YOUR

EISENHOWER & CARLSON, PLLC

IN COUNTY Cl.ERK'S OFFICE

BOB SAN SOUCIE

SUPERIOR COURT OF WASHINGTON

In re the Marriage of:

PETITION FOR DISSOLUTION

CHILDREN OF THE MARRIAGE DEPENDENTUPON EITHER OR BOTH

Name (first/last) AMANDA DAHL

Name (first/last) SARA\bAHL

Name (first/last) ELIZABETH DAHL

PETITION FOR DISSOLUTION OF MARRIAGE

EISENHOWER& CARLSON, PLLC

8/29/2002 623~ 08005

ALLEGATION REGARDING MARRIAGE.

DATE AND PLACE OF MARRIAGE.

over the marriage.

over the respondent because:

The division of the property should be determined by the court at a

DEBTS AND LIABILITIES.

The division of debts and liabilities should be determined by the court

CONTINUING RESTRAINING ORDER.

EISENHOWER & CARLSON, PLLC

8/29/2002 623~ 00606

JURISDICTION OVER THE CHILDREN.

CHILD SUPPORT AND PARENTING PLAN FOR DEPENDENT

The petitioner's proposed parenting plan for the children is attached

Claims to custody or visitation:

EISENHOWER & CARLSON, PLLC

Involvement in any other proceedings concerning the children:

The petitioner has not been involved in any other proceeding

The petitioner does not know of any other legal proceedings

Approve the petitioner's proposed parenting plan for the dependent

Determine support for the dependent children pursuant to the

Divide the property and liabilities.

Award the tax exemptions for the dependent children as follows:

Order payment of attorney's fees, other professional fees and costs.

EISENHOWER & CARLSON, PLLC

)(City and State)

EISENHOWER & CARLSON, PLLC

PIERCE COUNTY, WASHINGTON

BOB SAN SOUCIE

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

Assignment for Trial Date

Friday, January 3, 20039:30 AM

Judge D. Gary Steiner

BOB SAN SOUCIE

PIERCE COUNTY SUPERIOR COURT, STATE OF WASHINGTON

NOTE FOR COMMISSIONER'SCALENDAR

(Please note addillonal attorneyson an attached page)

DATE._S_e~p_te_m_b_e_r 1_6_, _20_0_2

Nature of Case: DISSOLUTIONW/CHILDREN

[a.I] (MO) Show Cause/Family Law, Confinnation Required