Professional Documents
Culture Documents
Thomas L Van Dam vs. Sara L Van Dam Case Number 07-3-02242-1
Thomas L Van Dam vs. Sara L Van Dam Case Number 07-3-02242-1
No. 07-3-02242-1
ORDER ASSIGNING CASE TO DEPARTMENT
In accordance with PCLR 40(b), this case is hereby assigned to Department 22, Judge JOHN R. HICKMAN.
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)
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).
Certificate of Completion of Mandatory Parenting Seminar due from both parties by 09/07/2007. See PCLSPR
94.05(c) & (4)0)
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.
3277
7 -'* '6 /2 0 0 ?
00001
07-3-02242-1
27802807
C lC S
07-08-07
Case Number:
3 0 22 4 T 1
Case Title:
Van Dam
Attorney Name: Clint P. Johnson
Street Address: 5920 100th Street S.W., Suite 25
City: Lakewood
State: WA Zip: 98499
Bar U 14794 Phone # (253) 581-0660________
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.)
I f you cannot determine the appropriate category, please describe the cause o f action below, This will create a "Miscellaneous" cruise which is not
subject to PCLR I. and does not require a Track Assignment Request Form,
APPEAL/REVIEW
____Administrative Law Review (ALR 2) Non PCLR
____Civil, Non-Traffic (LCA 2)Non PCLR
____Civil, Traffic (LCI 2) Non PCLR
CONTRA CT/COM M ERCIAL
____Breach of Contract (COM 2) EXPEDITED
____Commercial Contract (COM 2) EXPEDITED
____Commercial Non-Contract (COL 2) EXPEDITED
____Third Party Collection (COL 2) EXPEDITED
DOMESTIC RELATIONS
____Annulment/fnvalidity (INV 3) DISSOLUTION
____Child Custody (CUS 3) DISSOLUTION
_x_D issolution 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 (MWA 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
____Residential Schedulc/Parenting Plan (PPS 3) Non PCLR
JUDGM ENT
____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 Private 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
____Interpleader (MSC 2) Non PCLR
Malicious Harassment (MHA 2) Non PCLR
Minor ScUlcmcnl/No Guardianship (MST 2) Non PCLR
Petition for Civil Commit/Sexual Predator (PCC 2) Non PCLR
____Seizure of Property from the Comm of Crime (SPC 2) Non PCLR
____Seizure of Property Resulting from Crime (SPR 2) Non PCLR
____Subpoenas (MSC 2) Non PCLR
MISCELLANEOUS
A D O PTIO N ! PATERNITY
____Adoption (ADP 5) Non PCLR
____Confidential Intermediary (MSC 5) Non PCLR
Initial Pre-Placement Report (PPR 5) Non PCLR
____Modification (MOD 5) Non PCLR
____Paternity (PAT 5) Non PCLR
____Patcmity/URESA/UIFSA (PUR 5) Non PCLR
____Relinquishment (REL 5) Non PCLR
____ Termination of Parent-Child Relation (TER 5) Non PCLR
____Rescission of Paternity Affidavit (MSC 5)Non PCLR
PROBATE / 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
____Guard ianship/Estatc (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)
PROPERTY RIGHTS
____ Condemnation (CON 2) STANDARD
____Foreclosure (FOR 2) STANDARD
Property Fairness (PFA 2) STANDARD
____Quite Title (QTI 2) STANDARD
____ Unlawful Detaincr/Eviction (UND 2)Non PCLR
TORT / MEDICAL M ALPRACTICE
____Hospital (MED 2) COMPLEX
____Medical Doctor (MED 2) COMPLEX
Other Health Care Professional (MED 2) COMPLEX
TORT / MOTOR VEHICLE
____Death (TMV 2) STANDARD
____ Non-Death Injuries (TMV 2)STANDARD
Property Damage Only (TMV 2 )STANDARD
TO RT / NON MOTOR V EHICLE
____ Asbestos (PIN 2) STANDARD
____Other Malpractice (MAL 2) COMPLEX
____ Personal Injury (PIN 2) STANDARD
Products Liability (TTO 2) COMPLEX
____ Property Damage (PRP 2) STANDARD
____Wrongful Death (WDE 2 )STANDARD
W RIT
____Habeas Corpus (WHC 2) Non PCLR
____ Mandamus (WRM 2) Non PCLR
____Review (5WRV 2) Non PCLR
3 2 7 ?
7 ^ 6 ^ 2 8
1
IN COUNTY CLERKS OFFlfci
xI
-02242-1
27002810
'JU L
SIM
0 6
2007
4
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07 3 02242 1
NO.
SUMMONS (SM)
vs.
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Respondent.
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1.
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Additional requests, if any are stated in the petition, a copy of which is attached
to this summons.
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2.
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pm
07-08-07
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 (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 enter a default judgment 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 from filing and service. If you serve a
notice of appearance on the undersigned person, you are entitled to notice
FAUBION, JOHNSON & REEDER, P.S.
SUMMONS (SM) -1
WPF DR 01.0200 (6/2006); CR 4.1
S:\CASES9W anDam'.summons.wpd
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakew ood , WA 98499
{253) 581-0660
ft
3277
1
2
3
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Your written answer 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 Administrative Office of the Courts at (360) 705-5328, or from the Internet
at the Washington State Supreme Court Homepage:
5
6
http://www.courts.wa.gov/forms
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 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.
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This summons is issued pursuant to Superior Court Civil Rule 4.1 of the State of
Washington.
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DATED this
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FILE RESPONSE WITH:
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CLINT P. JOHNSON
FAUBION, JOHNSON & REEDER, P.S.
5920 100th Street S.W., Suite 25
Lakewood, Washington 98499
(253) 581-0660
24
25
FAUBION, JOHNSON & REEDER, P.S.
SUMMONS (SM) - 2
WPF DR 01.0200 (6/2006); CR 4.1
S:'CASES9WanDam-summons.wpd
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakew ood , WA 98499
(253)581-0660
3277
UK L
242-1
27002811
PTDSS
07-06-07
I vin
stock , county^ij
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Petitioner,
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vs.
12
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07 3 02242 1
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I. BASIS
1.1
Name (first/last):
Date of Birth:
Last known residence:
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1.2
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1.3
IDENTIFICATION OF RESPONDENT.
Name (first/last):
Date of Birth:
Last known residence:
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IDENTIFICATION OF PETITIONER.
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25
The Husband and Wife are both the parents of the following dependent
children:
PETITION FOR DISSOLUTION OF
MARRIAGE (PTDSS) - 1
WPF DR 0 1.0100 (6/2006); RCW 26.09.020
STCASES9\VanDani)Psit[ion wpd
592010m
" ^ "
suite25
La kew o o d . WA 98499
(253) 581 -0660
Name
Age
Silas R. VanDam
The Husband is and the Wife is not the parent of the following dependent
children:
3
4
Name
Age
5
None
6
The Wife is and the Husband is not the parent of the following dependent
children:
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8
Name
None
10
1.4
1.5
1.6
SEPARATION.
Husband and wife separated in April, 2006.
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12
Age
1.7
JURISDICTION.
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,
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1.8
PROPERTY.
There is community or separate property owned by the parties. The court
should make a fair and equitable division of all the property.
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25
PETITION FOR DISSOLUTION OF
MARRIAGE (PTDSS)-2
WPF DR 01.0100 (6/2006); RCW 26,09.020
S:\CASES5HVfttiDam Petition wpd
The petitioners recommendation for the division of property is set forth below.
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4
1.
2.
3.
4.
5.
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6.
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The respondent should be awarded the parties interest in the following
property:
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1.
2.
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3.
13
4.
14
5.
15
6.
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1.9
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The parties have debts and liabilities. The court should make a fair and
equitable division of all debts and liabilities.
The petitioners recommendation for the division of debts and liabilities
is set forth below.
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j
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FAUBION, JOHNSON
ATTORNEYS AT LAW
5920 iooth street s .w ., suite25
La ke w o o d , WA 98499
(253)591 '0560
32?7
2
1. Any and all expenses associated with the vehicle in her
possession to include insurance, tabs and repairs; and
2. Any and all expenses associated with her residence;
3. Chase for credit card
4. Unicom Financial for loan
3
4
5
SPOUSAL MAINTENANCE.
7
Spousal maintenance should not be ordered.
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1.11
9
Does not apply.
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1.12
PROTECTION ORDER.
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1.13
PREGNANCY.
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The wife is not pregnant.
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1.14
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This court has jurisdiction over the child for the reasons set forth below.
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This state is the home state of the child because
17
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.
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1.15
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Name of
of Child
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The petitioners proposed parenting plan for the children listed above:
PETITION FOR DISSOLUTION OF
, . . ^
A
MARRIAGE (PTDSS) - 4
WPF DR 01.0100 (6/2006); RCW 26.09.020
S:\CAS ES9\VanDana\Pciiiion,wpd
Mothers
Name
Fathers
Name
FAUBION, JOHNSON
t t orneys at Law
32?7
? /& /
2
(The following information is required only for those children who are included
in the petitioners proposed parenting plan.)
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Claims to custody or visitation;
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f
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 child.
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1.16
OTHER:
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II. RELIEF REQUESTED
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The petitioner REQUESTS the Court to enter a decree of dissolution and to grant the
relief below.
Approve the petitioners proposed parenting plan for the dependent children
listed in paragraph 1.15.
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Determine support for the dependent children listed in paragraph 1.15 pursuant
to the Washington State Support Schedule.
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Order payment of day care expenses for the children listed in paragraph 1.15.
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Award the tax exemptions for the dependent children listed in paragraph 1.15 as
follows:
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PETITION FOR DISSOLUTION OF
MARRIAGE (PTDSS)- 5
WPF DR 01.0100 (6/2006); RCW 26.09.020
S:\CASES9\VanDam\ Petition.wpd
1
2
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DATED this
/2007.
day of
REEDER, P.S.
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SffWSBA# 14794
ioner
Of Attorneys for
I declare under penalty of perjury under the laws of the State of Washington that
the foregoing is true and correct.
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Signed at '
, UJ]f\
(City and State)
, on
&
n
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PETITION FOR DISSOLUTION OF
MARRIAGE (PTDSS)-6
WPF DR 01.0100 (6/2006); RCW 26.09.020
S:\CASEiS9WanDam'Petition.wpd
yf 'cxerk'S off
07-3-0; 42-1
27802813
ACSR
07-06-07
2007 i
f k c e c o u n ty
WASHING'
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ACCEPTANCE OF SERVICE
(ACSR)
vs.
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07 3 02242 1
NO.
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Respondent.
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1.
ACCEPTANCE OF SERVICE.
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SARA L. VAN DAM accepts service of:
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the summons and petition in this action
Temporary parenting plan,
a proposed order of child support
proposed Child Support Worksheets
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20
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2.
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24
3.
OTHER:
None.
25
FAUBION, JOHNSON & REEDER, P.S.
A ttorneys at Law
59201 00 th Street S.W., Suite 25
Lakew ood , WA 98499
(253)581-0660
327?
7/& /2B 9
2
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Notice to party: You may list an address
that is not your residential address where
you agree to accept legal documents.
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[Address]
m m
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FAUBION, JOHNSON & REEDER, P.S.
A ttorneys at la w
5920 100 th Street S.W., S uite 25
L akewood , WA 98499
(253)581-0660
5950
07-3-02242-1
28242084
LTR22
09-13-07
S U P E R IO R
9 /1 4 /2 0 0 7
00092
C O U R T
O F T H E
S T A T E
FO R
O F W A S H IN G T O N
P IE R C E
C O U N T Y
(253) 798-3654
Deadline:
09/07/07
Deadline:
09/07/07
Pursuant to Pierce County Local Rule 1 and also pursuant to the Case Scheduling Order given to you
at the time of filing this case, you are out of compliance. Please take the actions necessary to
immediately comply with the Case Schedule. Please file and deliver a courtesy copy of the document
to the Judge.
If the court finds that an attorney or party has failed to comply with the Case Schedule and has no
reasonable excuse, the court may order the attorney or party to pay monetary sanctions to the court,
or terms to any other party who has incurred expense as a result of the failure to comply, or both; in
addition, the court may impose such other sanctions as justice requires. See PCLR 1(k).
Sincerely,
Clint P. Johnson
Van Dam, Sara L
Department 22
Judicial assistant to:
Judge John R. Hickman
\Jxcivil. pbM_noncomp!iance_}etter_rBport
Cause Number: 0 7 -3 -0 2 2 4 2 -1
Petitioner(s)
vs.
Page 1 of 2
CLINT P. JOHNSON
Resolution:
7733
1 8 /3 1 /2 0 0 7
MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner:
DAVID H. JOHNSON
FILED
IN OPEN COURT
EX PARTE DEPARTMENT
OCT
2007
.By___S .
DEPUTY
Year 2007
86854
7??4 1 0 X 3 1 ^
If I III
([/(Iff
07-3.02242-1
20540404
PCOPC
10-31-07
FILED
IN CO UNTY C L E R K S O F F IC E
3
a.m.
OCT 3 0 2007
pm .
5
6
7
9
10
11
Petitioner,
12
13
vs.
NO. 07-3-02242-1
CERTIFICATION OF
COMPLETION OF PARENTING
CLASS RE:
THOMAS L. VAN DAM
14
Respondent.
IS
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FAUBION, JOHNSON & REEDER, P.S.
-1
S:\CASES9WanDarri\Parentmg Class Certification cover sheet re Thomas.wpd
Attorneys at Law
5920 100th Street S.W., S uite 25
LAKEWOOD, WA 98499
(253)581-0660
7774
1 0 X 3 1 /2 8 8 7
88095
7774
07-3-02242-1
28540406
RCOPC
10-31-07
!
FILED
IN C O U N TY C L E R K 'S O FF IC E
2
3
mi.
OCT 3 0 2007
p..
5
6
7
9
10
11
12
13
14
vs.
NO. 07-3-02242-1
CERTIFICATION OF
COMPLETION OF PARENTING
CLASS RE: SARA L. VAN DAM
15
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23
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25
FAUBION, JOHNSON & REEDER, P.S.
- I
S:\CASES9WanPam\Paicnting Class Certification cover sheet re Sara.wpd
A ttorneys at Law
5920 100th Street S.W., Suite 25
L a k e w o o d , WA 98499
( 2 5 3 ) 581 -0 6 6 0
7774
1 0 /3 i/'2 g 3 7
80397
7774
III
07-3-02242-1
20540407
1 8 /3 1 /
10-31-07
RTSR
2
" C0UNTyFC L l& s 0FF1CE
3
4
AM'
BY__
OCT 3 0 2007
p.m.
0pury
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9
10
Petitioner,
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NO. 07-3-02242-1
RESIDENTIAL TIME
SUMMARY REPORT (RTSR)
vs.
14
Respondent.*1
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Submit with final Parenting Plan, only. This form is for statistical reporting purposes only.
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Starting with your oldest child, for each child, list his or her age and check the box that best represents
the time the child spends with each parent:
________
24
Oldest Child - Ag
25
7774
2
3
4
5
6
7
8
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(Continued) Starting with your next child, for each child, list his or her age and check the box that best
represents the time the child spends with each parent:
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A ttorneys at Law
5920 10Oth Street S.W., S uite 25
Lakewood , WA 98499
(253)581-0660
7774
1 0 / '3 1 / 2 8 e 7
39188
7774
3-02242-1
28540417
PP
1Q /31S2-
10-31-07
2
3
FILED
4
A.M. OCT 3 0 2007
P.M.
- W 1'
9
10
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PARENTING PLAN
FINAL ORDER (PP)
Petitioner,
12
13
NO. 07-3-02242-1
vs.
SARA L. VAN DAM,
14
Respondent.
15
I. GENERAL INFORMATION
16
17
1.1
18
19
21
Name
Age
22
23
II. BASIS FOR RESTRICTIONS
24
25
Under certain circumstances, as outlined below, the court may limit or prohibit a
parents contact with the child and the right to make decisions fo r the child.
FAUBION, JOHNSON & REEDER, P.S.
PARENTING PLAN - i
WPF DR 01.0400 (7/2006); RCW 2 6 .0 9 .1 8 1 187; , 194
S:\CASES9Wan Dam\fmaHppfinal.wpd
A ttorneys at Law
5920 100th Street S.W., Suite 25
L akewood , WA 98499
(253)581-0660
7774
2.1
2
3
1 8 /3
2.2
4
5
The residential schedule must set forth where the child shall reside each day o f the
year, including provisions fo r holidays, birthdays offamily members, vacations, and
other special occasions, and what contact the child shall have with each parent.
Parents are encouraged to create a residential schedule that meets the developmental
needs o f the child and individual needs o f their family. Paragraphs 3.1 through 3.9 are
one way to write your residential schedule. I f you do not use these paragraphs, write
in your own schedule in paragraph 3.13.
7
8
9
10
These provisions set forth where the child shall reside each day of the year and what
contact tlie child shall have with each parent.
11
3.1
12
Prior to enrollment in school, the child shall reside with the mother and father,
except for the following days and times when the child will reside with or be
with the other parent:
13
14
15
16
17
18
19
3.2
SCHOOL SCHEDULE.
Upon enrollment in school, the child shall reside with the mother and father,
except for the following days and times when the child will reside with or be
with the other parent:
20
21
22
23
24
25
3.3
PARENTING PLAN-2
WPF DR Oi,0400 (6/2006); RCW 2 6 .0 9 .1 8 1 187;. 194
S:\CASES9WanDam'ippiemp.wpd
ATTORNEYS AT LAW
5920 100th S treet S.W., Suite 25
Lakew ood , WA 98499
(253) 581-0660
7774
3.4
3
4
3.5
SUMMER
SCHEDULE.
{
Upon completion of the school year, the child shall reside with the mother and
father, except for the following days and times when the child will reside with
or be with the other parent:
9
10
3.6
11
12
13
Vacation shall further be defined as when the child goes out of the area
and leaves for a vacation.
14
15
3.7
16
The residential schedule for the child for the holidays listed below is as follows:
17
18
19
20
21
22
23
24
25
With Mother
(Specify whether
Odd/Even/Everv)
EVEN
See 3.1
See 3.1
See 3.1
EVEN
See 3.1
See 3.1
EVEN
With Father
(Specify whether
Odd/Even/Everv)
ODD
See 3.1
See 3.1
See 3.1
ODD
See 3.1
See 3.1
ODD
PARENTING PLAN - 3
WPF DR 01,0400 (6/2006); RCW 26.09.181;. 187; . 194
S:\CASES9\VanDam\pptemp.wpd
attorneys at Law
5920 100th Street S.W., Suite 25
L akewood . WA 98499
(253) 581-0660
7774
3.8
9
10
Mothers Day
Fathers Day
Mothers Birthday
11
12
With Mother
(Specify whether
Odd/Even/Everv)
EVERY
Fathers Birthday
Childs Birthdays
13
14
With Father
(Specify whether
Odd/Even/Everv)
EVERY
EVERY
ODD
EVERY
EVEN
For purposes of this parenting plan, special occasions shall begin and end as
follows:
15
16
3.9
18
3.10
RESTRICTIONS.
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
20
21
EVEN
EVEN
19
ODD
ODD
The residential schedule for the child for the following special occasions (for
example, birthdays) is as follows:
17
With Father
(Specify whether
Odd/Even/Everv)
For purposes of this parenting plan, a holiday shall begin and end as follows:
5
6
With Mother
(Specify whether
Odd/Even/Everv)
Christmas Eve
Christmas Day
1 8 /3 3 V 2
3.11
TRANSPORTATION ARRANGEMENTS.
%
22
23
24
Transportation costs are included in the Child Support Worksheets and/or the
Order of Child Support and should not be included here.
Transportation arrangements for the child between parents shall be as follows:
The receiving parent shall provide transportation except as follows:
25
FAUBION, JOHNSON & REEDER, P.S.
PARENTING PLAN - 4
WPF DR 0 1.0400 (6/2006); RCW 26,09.181187; . 194
SACASES9\VanDam\pptempwpd
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakew ood , WA 98499
(253) 581-0660
During the weekly schedule, the father shall deliver the minor child to
school before it commences or child care no later than l :30 p.m.
Mother shall retrieve the child from child care or school at 5:00 p.m.
and return the child to fathers residence by 7:00 a.m.
2
3
3.12
DESIGNATION OF CUSTODIAN.
4
The child named in this parenting plan are scheduled to reside the majority of
the time with the mother and father. 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 parents rights and responsibilities under this parenting plan.
5
6
7
3.13
OTHER
8
a.
b.
Each parent shall notify the other at least forty-eight (48) hours in
advance if he or she is unable to comply with the regular schedule.
c.
Each parent shall keep the other apprized of his or her current residence
address and residence telephone number.
d.
Both parents shall have unlimited access to the childrens school, day
care, and medical records. Neither parent may revoke this provision by
telling the providers to disobey this court order.
e.
Telephone Access
9
10
11
12
13
14
15
16
The child shall have reasonable telephone privileges with the parent
with whom the child is not then residing, without interference of the
residential parent.
17
18
f.
19
1.
2.
20
21
22
23
24
25
FAUBION, JOHNSON & REEDER, P.S.
PARENTING PLAN - 5
WPF DR 0! .0400 (6/2006); RCW 26.09.18 1 187;. 194
S:\CASES9\VanDam\pptcmp.pd
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lake w o o d , WA 98499
(253) 581-0660
7774
3.14
1 0 /3 1 /
2
3
4
5
6
7
8
9
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 shall give notice to every person entitled to court ordered time with
the child.
If the move is outside the childs 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.)
r.
10
11
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.
12
13
14
15
16
17
18
19
20
21
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 childs relocation whether or not he or she received proper notice.
22
24
An objection may be filed by using the mandatory pattern form WPF DRPSCU
07.0700, (Objection to Relocation/Petition for Modification of Custody
Detree/Parenting Plan/Residential Schedule). The objection must be served on
all persons entitled to time with the child.
25
The relocating person shall not move the child during the time for objection
23
PARENTING PLAN - 6
WPF DR 01.0400 (6/2006); RCW 26.09.181;. 187; . 194
S:\CASES9\VanDam\ppteirp.wpd
Attorneys at Law
5920 100th Street S.W.. Suite 25
L akewood , WA 96499
(253) 581-0660
7774
1 8 /3 1
unless: (a) the delayed notice provisions apply; or (b) a court order allows the
move.
1
2
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.
3
4
5
4.1
10
11
12
4.2
MAJOR DECISIONS.
13
Major decisions regarding each child shall be made as follows:
14
Education decisions
Non-emergency health care
Religious upbringing
15
Joint
Joint
Mother/Father
16
4.3
17
18
19
20
21
Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2
above.
,
V. DISPUTE RESOLUTION
22
PARENTING PLAN - 7
WPF DR 01.0400 (6/2006); RCW 26.09.181; .187; .194
SACASESQWonDarn'ppterr^ wpd
i.
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakew ood , WA 98499
(253) 581-0660
7774
The cost of this process shall be allocated between the parties as follows:
50% mother, 50 % father.
2
3
1 0 /3 1 /'
(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)
(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.
6
7
8
9
10
11
12
13
14
19
20
It is ordered, adjudged and decreed that the parenting plan set forth above is adopted
and approved as an order of this court.
21
22
23
24
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.
25
If a parent fails to comply with a provision of this plan, the other parents obligations
FAUBION, JOHNSON & REEDER, P.S.
PARENTING PLAN - 8
WPF DR 01.0400 (6/2006); RCW 26.09.181;. 187;. 194
S;\CASES9\VunD,i;ivpptcnip.wpd
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakewood . WA 98499
(253) 581-0660
7774
iS /3 1 ^ 2
f) day
0 < X i
, 2007.
4
-JttegS/Commissio
5
6
PRESENTED BY:
8
9
CLINT P. JOHNSON! WSBA# 14794
10
j
Cl I r K'S
OFFlfcl
OCT 3 02007
pj .
IN COUNTY1
11
12
13
Pk e vvnw
I n STOCK,
s r a c TKY'f!!VASHIN<3TCN
County Clert;
----
DEPUTT
14
15
16
By
17
18
19
20
21
22
23
24
25
FAUBION, JOHNSON & REEDER, P.S.
PARENTING PLAN - 9
WPF DR 01.0400 (6/2006); RCW 26.09.181; .187; .194
S:\CASES9\VanDanvpptcmpwpd
ATTORNEYS AT LAW
5920 100th Street S.W., Suite 25
L akewood , WA 98499
(253) 581-0660
7774
10^31
2
3
4
5
6
7
9
10
11
vs.
12
13
NO. 07-3-02242-1
CERTIFICATION OF
COMPLETION OF PARENTING
CLASS RE:
THOMAS L. VAN DAM
14
15
16
17
18
19
20
21
22
23
24
25
FAUBION, JOHNSON & REEDER, P.S.
-1
S 'CASES9\VanDam\Parcnting Class Certification cover sheet rc Thomas wpd
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakew ood , WA 98499
7 774
T h is
Certificate of attendance
is h e re b y a w a rd e d to
~ V v \o trsCfr
L . \l< \n
fo r a tte n d in g an d c o m p le tin g th e
S eminent
C o n d u c te d b y G a te w a y s fo r Y o u th an d F a m ilie s
In P ie rce C o u n ty , W a s h in g to n o n th is d a y
SEPTEMBER 8, 2007
1 0 /3 1 /'2 8 0 ?
60111
7774
1
2
3
4
5
6
7
9
10
11
vs.
12
13
NO. 07-3-02242-1
CERTIFICATION OF
COMPLETION OF PARENTING
CLASS RE: SARA L. VAN DAM
14
Respondent.
15
16
17
18
19
20
21
22
23
24
25
FAUBION, JOHNSON & REEDER, P.S.
-I
S:\CASES9WanDam\Parenting Class Certification cover sheet re Sara wpd
Attorneys at Law
5920 100th S treet S.W., S uite 25
LAKEWOOD. WA 98499
660
7774
1 0 /3 1 ^2 8 8 7
C o u rt C a u se N u m b er:
L esa S w a n so n , L IC S W
38113
7774
1 8 /3 1 /2
2
1N countT
OCT 3
omcE
m *.
0 2007
BY.
6
7
9
10
NO. 07-3-02242-1
ORDER OF CHILD SUPPORT
FINAL (ORS)
Petitioner,
11
vs.
12
14
15
I. JUDGMENT SUMMARY
16
Does not apply because no attorneys fees or back support has been ordered.
17
18
19
II. BASIS
2.1
20
21
22
2.2
23
24
25
TYPE OF PROCEEDING
2.3
OTHER:
FAUBION, JOHNSON & REEDER, P.S.
A ttorneys at Law
5920 100th Street S.W., Suite 25
LAKEWOOD, WA 98499
(253)581-0660
7774
IT IS ORDERED that:
3.1
4
5
Age
1 6 /3 1 ^2
Name (first/last):
Birth date:
09/22/1975
Service Address*:
P O Box 7143
Bonney Lake, WA 98391
9
* You may list an address that is not your residential address where you agree
to accept legal documents.
10
11
12
13
16
17
14
15
18
3.3
$2,310.00
19
Name (first/last):
20
Birth date:
10/21/1969
21
Service Address*:
22
23
24
25
* You may list an address that is not your residential address where you agree
to accept legal documents.
THE OBLIGEE MUST IMMEDIATELY FILE WITH THE COURT AND
THE WASHINGTON STATE CHILD SUPPORT REGISTRY, AND
UPDATE AS NECESSARY, THE CONFIDENTIAL INFORMATION FORM
FAUBION, JOHNSON & REEDER, P.S.
A ttorneys at Law
5920 100th S treet S.W., Suite 25
Lakew ood , WA 98499
(253) 581-0660
7774
1 0 /3 1 ^ 2 8
3
4
5
$3,641.35
6
The Obligor may be able to seek reimbursement for day care or special child
rearing expenses not actually incurred. RCW 26.19.080.
3.4
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
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.
10
11
12
13
3.5
TRANSFER PAYMENT.
14
The obligor parent shall pay the following amounts per month for the following
children:
15
16
Name
Amount
17
$0.00
18
$0.00
19
20
21
22
23
24
3.6
STANDARD CALCULATION.
25
FAUBION, JOHNSON & REEDER, P.S.
S:\CASES9WanDam\final\orsfinal.wpd
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakewood , WA 98499
(253)581-0660
7774
3.6
1 0 /3 1 /2 8 8 7
STANDARD CALCULATION.
$368.75 per month. (See Worksheet A, line 15.)
3.7
3.8
3.9
November 1, 2007
INCREMENTAL PAYMENTS.
Does not apply.
3.11
3.12
3.13
TERMINATION OF SUPPORT.
Support shall be paid:
Until the child reaches the age of 18 or graduates from high school,
FAUBION, JOHNSON & REEDER, P.S.
A t t o r n e y s a t Law
5920 100th Street S.W,, Suite 25
Lakewood , WA 98499
(253) 581-0660
80117
7774
1 0 ^3 1 /
1
2
3.14
3
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.
4
5
3.15
6
The mother shall pay 50% and the father 50% (each parents proportional share
of income from the Child Support Schedule Worksheet, line 6) of the following
expenses incurred on behalf of the children listed in Paragraph 3.1:
7
8
[x]
[x]
10
11
3.16
12
13
PERIODIC ADJUSTMENT.
Does not apply.
3.17
14
Father shall be entitled to claim minor child during odd numbered years;
and Mother shall be entitled to claim minor child during even numbered
years.
15
16
17
18
day care.
educational expenses.
The parents shall sign the federal income tax dependency exemption waiver.
3.18
19
20
21
Unless one or more of the alternatives below are checked, each parent shall
maintain or provide health insurance coverage if:
Alternative 3: The parent below is not obligated to provide health insurance
coverage.
22
Mother
23
24
25
SACASE$9\VanDam\finat\onfinal.wpd
Attorneys at L aw
5920 100th Street S.W., Suite 25
Lakew ood , WA 98499
{253) 581-0660
7774
1 6 /3
1
2
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.
3
4
5
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.
6
7
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.
8
9
10
11
12
13
3.19
14
15
16
17
The OBLIGOR and OBLIGEE shall each pay 50% of extraordinary health care
expenses (the obligors proportional share of income from the Child Support
Schedule Worksheet, line 6).
18
19
3.20
20
No back child support is owed at this time.
21
3.21
BACK INTEREST.
22
No back interest is owed at this time.
23
3.22
OTHER:
24
The parties agree to establish a joint bank account for additional expenses
related to Silas. The account shall be used for such expenses as school clothing
25
__
_ TTTT
A ttorneys at L aw
5920100 street s .w . suite 25
Lakew ood , WA 98499
(253) 581*0660
7774
1
2
3
4
1 0 /3 1 /
and supplies, extracurricular activities, sports fees and equipment, and other
uses the parties might agree upon. It is not to be used as the primary source of
funds for expenses related to Silas.
Initially, Father shall deposit $150.00 per month into the account and Mothers
deposits shall be discretionary. Either party may individually withdraw funds
from this account and shall provide notice and copies of all relevant receipts to
the other party within ten (10) days.
5
DONE IN OPEN COURT this D O day
6
OcY
7
Ju^ge/Commissioner
8
9
PRESENTED BY:
10
FAUBION, JOHNS
EDER, P.S.
11
AM OCT3 02007
12
13
14
15
16
17
18
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20
21
22
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FAUBION, JOHNSON & REEDER, P.S.
S:\CASEjS9VVanDanVifmaKorsfinal.wpd
ATTORNEYS AT LAW
7774
1 6 /3 1 /2 6 8 7
o f f ic e
cr 3 02007
P.M.
T ^ GT*
By______STOC^
Cpunty c
Clerk
z
oepury
07-3-02242-1
WORKSHEETS
Children and Ages Silas Van Dam 5
P art I: B a sic S u p p o rt O b lig a tio n (See Instructions, page 1)
1. Gross Monthly Income
F a th e r
M o th e r
$4,420.00
$2,773.00
$0.00
$0.00
c. Business Income
$0.00
$0.00
$0.00
$0.00
e. Other Income
$0.00
$0.00
$4,420.00
$2,773.00
80121
Father
M o ther
$235.00
$251.00
$325.00
$212.00
$0.00
$0.00
$52.00
$0.00
$167.00
$0.00
$0.00
$0.0Q
$0.00
$Q.OO
$779.00
$463.00
$3,641,00
$2,310.00
^ g51 QQ
(If combined monthly net income is less than $600, skip to line 7.)
5. Basic Child Support Obligation (enter total am ount in box - > )
Silas Van Dam
$862
(advisory)
38.82%
61.18%
$527.37
$334.63
obligation of $25 per child. Number of children: 1. Skip to line 15a and enter this amount)
Part II: Health Care, Day Care, and Special Child Rearing Expenses (See instructions, page 3)
8. Health Care Expenses
a. Monthly Health Insurance Premiums Paid fo r Child(ren)
b. Uninsured Monthly Health Care Expenses Paid for Child(ren)
c, Total Monthy Health Care Expenses (line 8a plus line 8b)
$131.00
$0.00
$0.00
$0.00
$131.00
$0.00
$43,10
$87.90
$0.00
$0.00
b. Education Expenses
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
e. Total Day Care and Special Expenses (add lines 9a through 9d)
10. Combined Monthly Total of Day Care and Special Expenses
(add father's and mother's day care and special expenses from line 9e)
$0.00
7774
(line 8 f
d I us
line 1 0)
1 9 /3 1 /2 0 0 7
$87.90
F a th e r
M o th e r
$53.78
$34.12
$581.15
$368.75
$131.00
$0.00
$0.00
$0.00
$131.00
$0.00
12, Each Parent's Obligation for Extraordinary Health Care. D ay Care, and Special Expenses
(m ultiply each num ber on line 6 by line 11)
$0.00
$450.15
$368.75
$1,638.45
$1,039.50
$2,625.00
$1,294.00
$450.15
$368.75
b. Line 13 minus line 14d, if line 4 is over $600 (see below if applicable).
Limitation standards adjustments
(List the estim ated present value of all m ajor household assets.)
a. Real Estate
b. Stocks and Bonds
c. Vehicles
d. Boats
e. Pension/IRAs/Bank Accounts
f. Cash
g. Insurance Plans
h. Other (describe)
17. Household Debt (List liens against household assets, extaordinary debt)
Father's
Household
M other's
Household
60123
7774
21. Other Children Living In Each Household (First names and ages)
Father's
Household
1 8 /3 1 /2 8 0 7
Mother's
Household
88124
7774
1 6 /3 1 V2887
This worksheet has been certified by the State of W ashinton Office of the A dm instrator fo r the Courts.
68125
7774
07-3-02242-1
28540461
FNFCL
1 8 /3 1
10-31-07
2
3
4
iTr Deputy
5
6
7
9
10
11
vs.
12
13
NO. 07-3-02242-1
14
Respondent.I.
15
16
17
18
19
20
2.1
21
22
23
RESIDENCY OF PETITIONER.
The petitioner is a resident of the State of Washington.
2.2
24
25
FINDINGS OF FACT AND
CONCLUSIONS OF LAW - 1
WPF DR 04.0300 (6/2006); CR 52; RCW 26.09.030; .070(3)
S:\CAS ES9\VanDam\finaI\iTc l.wpd
7774
2.3
4
5
2.4
6
The parties were married on March 20, 1999 at Newport, Oregon.
7
2.5
8
Husband and wife separated in April, 2006.
9
2.6
10
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.
11
12
2.7
13
There is no written separation contract or prenuptial agreement.
14
2.8
COMMUNITY PROPERTY.
15
The parties have the following real or personal community property:
16
1.
2.
3.
17
18
4.
19
5.
20
6.
21
22
23
7.
2.9
SEPARATE PROPERTY.
24
25
7774
2.10
iS l/3
COMMUNITY LIABILITIES.
The parties have incurred the following community liabilities:
2
3
Creditor
Amount
1. Any and all expenses associated with the vehicle in his/her possession to
include insurance, tabs and repairs; and
2. Any and all expenses associated with his/her residence;
3. Obligation owing to Alaska Federal Credit Union for 2005 Ford Focus;
4. Sallie Mae for student loans
5. Wells Fargo, credit card
6. Chase credit card
7. Unicom Financial for loan.
4
5
6
7
8
2.11
SEPARATE LIABILITIES.
9
The husband has no known separate liabilities.
10
The wife has no known separate liabilities.
11
2.12
MAINTENANCE.
12
Maintenance was not requested.
13
2.13
14
Does not apply.
15
2.14
PROTECTION ORDER.
16
Does not apply.
17
2.15
18
There is no award of fees or costs.
19
2.16
PREGNANCY.
20
The wife is not pregnant.
21
2.17
DEPENDENT CHILDREN.
22
The children listed below are dependent upon either or both spouses.
23
24
Name of
of Child
Age
25
Mothers
Name
Fathers
Name
FAUBION, JOHNSON
At t o r n e y s
& REEDER,
at
La w
P.S.
7774
2.18
5
6
1 8 /3 1 ^2
2.19
PARENTING PLAN.
The parenting plan signed by the court on this date is approved and
incorporated as part of these findings.
8
This parenting plan is the result of an agreement of the parties.
9
2.20
CHILD SUPPORT.
10
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 this date and the child support worksheet which has been
approved by the court are incorporated by reference in these findings.
11
12
13
2.21
OTHER:
14
15
16
The court makes the following conclusions of law from the foregoing findings of fact:
17
3.1
18
19
3.2
3.3
22
23
24
25
GRANTING OF A DECREE.
The parties should be granted a decree,
20
21
JURISDICTION.
PREGNANCY.
Does not apply.
3.4
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 child of the marriage entitled to support, consider or
7774
1 8 /3
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 property and liabilities as set forth in the
decree is fair and equitable.
2
3
4
3.5
5
Does not apply.
6
3.6
PROTECTION ORDER.
7
**
C f 3 0 2007
p.m,
8
3.7
----- oepury
OTHER:
11
12
13
14
15
16
PRESENTED BY:
17
F A U ^ N , JO
REEDER, P.S.
18
19
20
By
CONT P. JOHNSON, WSBA# 14794
Of Attorneys for Paiitioner
21
APPROVED AS TO FORM; NOTICE OF
22
23
24
25
FINDINGS OF FACT AND
CONCLUSIONS OF LAW -5
WPF DR 04.0300 (6/2006); CR 52; RCW 26,09.030; .070(3)
S:\CAS ES9W anDom\fina!\ffc [,wpd
7774
1
2
10/31S2
STATE OF WASHINGTON )
) ss:
County of Pierce
)
THOMAS L. VAN DAM, being first duly sworn on oath, deposes and says:
I am the Petitioner in this case; and I have read the foregoing findings of fact and
have also read the conclusions of law, decree, and the support order and related
documents, if included herein; and they are true and accurate to the best of my
knowledge. I am not seeking any relief beyond that specifically requested in the
petition.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
FAUBION, JOHNSON & REEDER, P.S.
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakew ood , WA 98499
(253)581-0660
???4
1
2
1 8 /3
STATE OF WASHINGTON )
) ss:
County of Pierce
)
SARA L. VAN DAM, being first duly sworn on oath, deposes and says:
I am the Respondent in this case; and I have read the foregoing findings of fact
and have also read the conclusions of law, decree, and the support order and related
documents, if included herein; and they are true and accurate to the best of my
Guidelines. Neither of us have any other children except those mentioned herein. J am
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
FAUBION, JOHNSON & REEDER, P.S.
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakew ood , WA 98499
(253)581-0660
7774
07-3-02242-1
28540462
DCD
10^3
10-31-07
IN CUNTyF t|D
OFFICE
3
p*"'
4
CJ 3 02007
p.Mi
s ^ - c^aHwcoToN
"" 1
deputy
6
7
9
10
11
NO. 07-3-02242-1
DECREE OF DISSOLUTION
(DCD)
vs.
12
14
15
I. JUDGMENT/ORDER SUMMARIES
16
17
1.1
18
19
1.2
20
21
1.3
22
23
END OF SUMMARIES
24
25
FAUBION, JOHNSON & REEDER, P.S.
A ttorneys at Law
7774
II. BASIS
1
2
Findings of Fact and Conclusions of Law have been entered in this case.
III. DECREE
3
4
IT IS DECREED that:
3.1
6
7
lS /3
3.2
9
10
1.
2.
11
3.
12
4.
13
5.
14
6.
15
3.3
16
The wife is awarded as her separate property the following property (list real
estate, furniture, vehicles, pensions, insurance, bank accounts, etc.):
17
1.
2.
18
19
3.
20
4.
21
5.
22
6.
23
3.4
24
The husband shall pay the following community or separate liabilities:
25
FAUBION, JOHNSON & REEDER, P.S.
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakew ood , WA 98499
(253) 581-0660
7774
Amount
Creditor
1 0 /3 1 ^
1. Any and all expenses associated with the vehicle in his possession to
include insurance, tabs and repairs; and
2. Any and all expenses associated with his residence;
3. Obligation owing to Alaska Federal Credit Union for 2005 Ford
Focus;
4. Sallie Mae for student loans
5. Wells Fargo, credit card
2
3
4
5
Unless otherwise provided herein, the husband shall pay all liabilities incurred
by him since the date of separation.
6
7
3.5
8
The wife shall pay the following community or separate liabilities:
9
Creditor
Amount
10
1. Any and all expenses associated with the vehicle in her possession to
include insurance, tabs and repairs; and
2. Any and all expenses associated with her residence;
3. Chase for credit card
4. Unicom Financial for loan
11
12
13
Unless otherwise provided herein, the wife shall pay all liabilities incurred by
her since the date of separation.
14
15
3.6
16
17
18
3.7
SPOUSAL MAINTENANCE.
19
Does not apply.
20
3.8
RESTRAINING ORDER.
21
3.9
PROTECTION ORDER
23
Does not apply.
24
3.10
25
FAUBION, JOHNSON & REEDER, P.S.
SACASES9\VanDam\finaI\decrcc.wpd
At to r n e y s
5920 100
street
at
La w
s.w..
suite 25
WA 98499
(253) 581-0660
La k e w o o d .
7774
10^3
The court has jurisdiction over the children as set forth in the findings of Fact
and Conclusions of Law.
1
2
3.11
PARENTING PLAN.
3
The parties shall comply with the Parenting Plan signed by the court on this
date. The Parenting Plan signed by the court is approved and incorporated as
part of this decree.
4
5
3.12
CHILD SUPPORT.
Child support shall be paid in accordance with the order of child support signed
by the court on this date. This order is incorporated as part of this decree.
7
8
3.13
9
10
3.14
NAME CHANGES.
Does not apply.
11
12
0ff\c
PETITIONER OR PETITIONERS
ATTORNEY (A signature below is actual notice
of this order):
18
19
Presented by:
[ ] Approved for entry: ^ \
[] Notice of presentation waived:
20
FAUB
REEDER, P.S.
21
22
By
23
24
25
THOMAS
Petitioner
FAUBION, JOHNSON & REEDER, P.S.
Attorneys
at
Law
7774
1
2
1 8 /3
RESPONDENT OR RESPONDENTS
ATTORNEY (A signature below is actual notice
of this order):
Presented by:
Approved for entry:
Notice of presentation waived:
3
4
5
6
By
7
Respondent
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
FAUBION, JOHNSON & REEDER, P.S.
-5
WPF DR 04.0400 (6/2006); RCW 26.09.030; .040; .070(3)
S:\CAS ES 9\VanDim\fmatVdecrcc.wpd
A ttorneys at L aw
5920 100th S treet S, w ., Suite 25
Lakew ood , WA 98499
(253) 581-0660
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
Petitioner(s)
Type of case:
Vs.
DIC
Track Assignment:
Assignment Department:
Docket Code:
Modification of Custody
HICK
ORSCS
7/3/2009
Adequate Cause Hearing on Commissioner Calendar to be held. (If this hearing is not held by this date,
petition will be dismissed)
8/3/2009 9:30
8/14/2009
8/14/2009
8/26/2009
10/16/2009
Week of 10/16/2009
11/6/2009
11/20/2009
12/4/2009
1/22/2010
2/5/2010
Discovery Cutoff
2/18/2010 9:00
Trial
Unless otherwise instructed, ALL Attorneys/Parties shall report to the trial court at 9:00 AM on
the date of trial.
NOTICE TO PLAINTIFF/PETITION ER
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
All 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.
07-3-02242-1
32246942
SM
06-12-09
IN
cou^
rkJ
office
AH Jl(N 1 2 2009
P.M.
^ T h o m c ts
no.
l& s iy r tfr ?
Petitioner,
and
Respondent.
To .
T H om
ly f-i-o 2 x H Z ' j
Summons(Modification/
Adjustment of Custody
Decree/Parenting Plan/
Residential Schedule)
ISM)__________________
L . l)A O D A t \
1.
An action has been started in the above court requesting that a custody decree/parenting
plan/residential schedule be modified/adjusted. Additional requests, if any, are stated in the
petition, a copy o f which is attached to this notice.
2.
You must respond to this notice and petition by serving a copy o f 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 o f the state o f
Washington) after the date this summons was served on you, exclusive o f the day o f service, the
court may enter an order o f default against you, and the court may, without further notice to you,
enter an order regarding adequate cause and a decree to modify/adjust the custody
decree/parenting plan/residential schedule and providing for other relief requested in the petition
If you serve a notice o f appearance on the undersigned person, you are entitled to notice before
an order o f default or a decree may be entered.
3.
The court shall deny the petition unless it finds that adequate cause for hearing the petition is
established, in which case it shall set a date for hearing on an order to show cause why the
requested order or modification should not be granted.
[]
33>4
S / ,i S / : z * a 9
4.
You may file an opposing declaration to show that there is not adequate cause to hold a full
hearing. If you do not file an opposing declaration or respond and the court finds that adequate
cause exists, the court may enter an adequate cause order and an order modifying/adjusting the
custody decree/parenting plan/residential schedule without notice to you pursuant to RCW
26.09.270,
5.
Your written response to the summons and petition must be on form WPF DRPSCU 07.0200,
Response to Petition for Modification/Adjustment o f Custody Decree/Parenting Plan/Residential
Schedule. This form may be obtained by contacting the clerk o f the court at the address below,
by contacting the Administrative Office o f the Courts at (360) 705-5328, or from the Internet at
the Washington State Courts homepage:
h ttp://www.courts.wa.gov/forms
6.
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 notice. Within 14 days after you serve the demand, the petitioner must file this
action with the court, or the service on you o f this notice and motion will be void.
7.
If you wish to seek the advice o f an attorney in this matter, you should do so promptly so that
your written response, if any, may be served on time.
8.
One method o f serving a copy o f your response on the petitioner is to send it by certified mail
with return receipt requested.
This summons is issued pursuant to Superior Court Civil Rule 4. l o f the state o f Washington.
Dated: yC
Signature o f Movirfg Party or Lawyer/WSBA No.
Print Name
Fite o rig in a l o f y o u r r e s p o n s e w ith
the clerk o f the c o u rt a t
S e r v e a c o p y o f y o u r r e s p o n s e on:
[Name]
Sojf 7 /Y 3
[Address]
<^Sonnp_Lj l tk t . LO fr
Summons Mod/Adj Parenting Plan (SM) - Page 2 of 2
WPF DRPSCU 07.0120 Mandatory (7/2007) - CR 4.1; R C W 26.09.270; 26.10.020
s s s s s
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
June 12 2009 10:14 AM
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
vs.
NOTE FOR COMMISSIONER'S CALENDAR
NAME:
THOMAS L VAN DAM
ADDRESS' 20839 60TH ST EAST #A
BONNEY LAKE, WA 98391
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:
[X] (MO) Show Cause/Family Law, Confirmation Required.................................................. (9:30 Mon.- Thurs.)
PARTY SETTING HEARING MUST CONFIRM BY CALLING (253)798-6697 BY NOON, TWO (2)
COURT/WORKING DAYS PRIOR TO HEARING OR HEARING WILL BE CANCELLED
(YY) Adoption, No Confirmation Required....................................
................................... (9:00 Fri.)
.................... (1:30 Mon.- Fri.)
(OE) Supplemental Proceedings, No Confirmation Required.........
(UD) Unlawful Detainer, No Confirmation Required.....................
...................... (1:30 Mon.- Fri.)
(GD) Probate/Gdnshp/Mnr Settlement, No Confirmation Required
................... (1:30 Mon.- Fri.)
w/Attorneys (3:00Mon.- Fri.)
(DD) Uncontested Dissolutions, No Confirmation Required..........
..... (1:30 Mon., Tues. & Thur.)
(FC) Paternity, No Confirmation Required.....................................
ntcsup-0007.pdf
page 1 o f 2
NAME:
CLINT P. JOHNSON
ADDRESS' 5920 100th St SW Ste 25
' L AKEWOOD, WA 98499-2751
NAME:
ADDRESS:
NAME:
ADDRESS:
NAME:
ADDRESS:
NAME:
ADDRESS:
NAME:
ADDRESS:
NAME:
ADDRESS:
NAME:
ADDRESS:
NAME:
ADDRESS:
NAME:
ADDRESS:
ntcsup-0007.pdf
page 2 o f 2
39&4
O f - 3-02242-1
32246945
3PTIWOC
b S I S '2 0 0 9
06-12-09
No. 07-3-02242-1
(PTMD)
39b4
/i5 /2 0 S
B a s is
Dependent Children
Age _
Name (first/last)____________________________________________Age_
Name (first/last)____________________________________________Age_
Name (first/last)____________________________________________Age_
II. Basis
2.1
2.2
Adequate Cause
There is adequate cause for hearing the petition for modification.
2.3
Child Support
[]
Does not apply.
[x] Child support should be modified or established if the court grants the petition to modify the
parenting plan or residential schedule. A child support worksheet and financial declaration
must be filed with this action. RCW 26.09.170.
2.4
.3 3 & '4
2.5
fc ^ !S /Z BBS
3811
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.
This state is the home state of the children because:
[]
[J
[3
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.
the children are less than six months old and have lived in Washington with a
parent or a person acting as parent since birth.
any absences from Washington have been only temporary.
Washington was the home state of the children within six months before the
commencement of this proceeding and the children are absent from the state but a
parent or person acting as a parent continues to live in this state.
The children and the parents or the children and at least one parent or a 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 childrens care, protection,
training and personal relationships, and:
\Y ^
[]
[]
All courts in the children's home state have declined to exercise jurisdiction on the ground
that a court of this state is the more appropriate forum to determine the custody of the
children under RCW 26.27.261 or .271.
[fY'
[]
This court has temporary emergency jurisdiction over this proceeding because the children
are present in this state and the children have been abandoned or it is necessary in an
emergency to protect the children because the children, or a sibling or parent of the
children is subjected to or threatened with abuse. RCW 26.27.231.
[]
3964
6^15^2B S S
B B S 12
[]
2.6
Other:
Parents Name
Sara L Van Dam
Parents Name
Thomas L Van Dam
[]
in no place other than the state of Washington and with no person other than the requesting
party or the other party.
in the following places with the following persons (list each place the children lived,
including the state of Washington, the dates the children lived there and the names of the
persons with whom the children lived. The present addresses of those persons must be
listed in the required Confidential Information Form.):
[]
The requesting party does not know of any person other than the other party who has
physical custody of, or claims to have custody or visitation rights to, the children.
The following persons have physical custody of, or claim to have custody or visitation
rights to, the children (list their names and the children concerned below and fist their
present addresses in the Confidential Information Form. Do not list the other party.):
3964
[ t/
[]
15^2889
88813
The requesting party has not been involved in any other proceeding regarding the children.
The requesting party has been involved in the following proceedings regarding the children
(list the court, the case number, and the date of the judgment or order):
[]
2.7
The requesting party does not know of, any other legal proceedings concerning the
children.
The requesting party knows of, the following legal proceedings that concern the children
(list the children concerned, the court, the case number, and the kind of proceeding):
2.8
[]
The children have been integrated into my family with the consent of the other
party in substantial deviation from the decree/parenting plan/residential schedule.
[]
39 b 4
[]
2.9
2.10
The other party has been found in contempt of court at least twice within three
years because the party failed to comply with the residential time provisions in the
court-ordered parenting plan, or the parent has been convicted of custodial
interference in the first or second degree under RCW 9A.40.060 or 9A.40.070.
[]
[]
[]
[]
is based on a change of residence of the parent with whom the child does not reside
a majority of the time or an involuntary change in work schedule by a party which
makes the residential schedule in the parenting plan impractical to follow.
3Sfe4
2.11
& S1SS28& 9
00815
[]
[]
[]
[]
3364
ir
[]
The following nonresidential provisions of the parenting plan should be adjusted because
there is a substantial change of circumstances of either party or of the children and the
adjustment is in the best interest of the children:
[]
[]
[]
[]
2.13
6 ^ IS - '2 e i1 9
BB816
Dispute resolution.
Decision making.
Transportation arrangements.
Other:
3S&4
2.14
b S IS s Z S rd S
Protection Order
Does not apply.
There is a protection order between the parties filed in case number______________
court_______________________ , which expires on (date)_________________
The court should grant the [ ] domestic violence [ ] antiharassment petition for order for
protection:
[ ] attached to this petition.
[ ] filed separately under [ ] this case number [ ] case number___________________
If you need immediate protection, contact the clerk/court for RCW 26.50 Domestic Violence
forms or RCW 10.14 Antiharassment forms.
2.15
B0S3 7
33&4
& /1 S /2 8 S S
88818
Other
[]
[]
[]
Enter an order establishing child support in conjunction with the proposed parenting
plan/residential schedule. The child support worksheet and financial declaration are filed
with this petition.
Enter a domestic violence protection order.
Enter an antiharassment protection order.
Other:
(S k tv j A r f b
Pet for Mod/Adj Parenting Pin (P T M D )-faage 10 of 12
WPF DRPSCU 07.0100 Mandatory (&2008) - CR 4.1; RCW 26.09.181;.260; .270
f lq .
39S4
Date
Date
6 / 1 5 / 20B3 8 8 B I9
I declare under penalty of peijury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at foitvW Lnj(o
_______(state) y
Signature of RequestangTarty
on (date) y 1$ ~V O*}
<
) n n t Name
\T a m o
Print
{ / c i n 'l
*
(state)__________on (date)
Signed at (city)
Signature of Requesting Party
Print Name
[]
J o in d e r
[]
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.
Date
[]
Signature
Print Name
I,___________ ____________ , join in the petition. I understand that by joining in the petition,
a decree or judgment and order may be entered in accordance with the relief requested in the
petition unless, prior to the entry of the decree or judgment and order, a response is filed and
served.
[]
[]
3 .9 6 4
9 .-8.0 8 2 S
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.
Signature
Date
[]
Print Name
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.
Date
Signature
Print Name
https://\ar^to(ftnd6.d'sa.5wljS(^Skraj^p?(^:Select
MAY-12-2009 18:15:11
i VAN DAM
; Begin Date
Service/Agency
i THOMAS LEE Based on the information you have furnished, the DMDC does not possess any information indicating that the
Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the
above is the current status of the individual as to all branches of the Military.
Yktopyk. S*A
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. 501 et seq] (SCRA)
(formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating
that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any
family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the
SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the
"defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service
verification, provisions of the SCRA may be invoked against you.
If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at
this Web site and we will provide a new certificate for that query.
This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact.
See: http://www.defenselink.mil/faq/pis/PC09SLDR.html
WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name
or SSN will cause an erroneous certificate to be provided.
Report 1DBTFSYGOSTSZ
1 Of 1
5/12/2009 6:14 PM
394 * / '- l S ^ 2 8 8 9
07-3-02242-1
32247017
FNDCLR
06-12-09
No. F ? ' 3
Financial Declaration
[ VPetitioner
M Respondent
(FNDCLR)
Name:
$ ______
$ ______
S ______
$ ______
Estimate o f the other partys gross monthly income (from 3.If below)
[ ] $ ______
[ ] unknown
2.2
2.3
(1)
Where do you work. Employer's name and address must be listed on the
Confidential Information Form.
BBB29
3364
b. If no:
(2)
(1)
(2)
(3)
6 /1 5 /2 6 8 9
o
O
3.2
v.
Name
VarTfrarr)
a.
$2J25L3
b.
s ^
c.
Business Income
d.
e.
Other Income
f.
g-
/ S O '-
$
$
&x> a g
a.
Income Taxes
b.
FICA/Self-employment Taxes
c.
d.
e.
s
s ^
f.
g-
h.
3.3
Name
a/ o- jL-
______
$
$
$
18 hr / /
800-3-8
$
$
00836
3964
3.4
6 / I S . / .2 8 0 9
Miscellaneous Income
a.
b.
c.
3.5
3.6
If the income of either party is disputed, state monthly income you believe is correct and explain below:
$1
Cash on hand
4.2
On deposit in banks
4.3
$J
4.4
S ___
5.1
Housing
Installment payments for other mortgages or encumbrances
s 9sz>s X)
$ ^
Total Housing
5.2
Utilities
Heat (gas & oil)
Electricity
S>
33031
3964
Telephone
)S>
$ JZS*-
Cable
$ /
Other
Total Utilities
$ 2 5 -0 -
5.3
2 - _____persons
&
%4 n o s (n o * s /6 b ~
______
T> ~sZoo
* u s-n -
Children
Day Care/Babysitting
* t*ro ~
s
s ~g?
s /DP'
%S D Q M >
Clothing
Tuition (if any)
5.5
5.4
6 /1 5 /2 0 3 9
Transportation
s z* rc> %
TS* 1dA
Parking
s _ & _____
$ _ ^ ______
Total Transportation
5.6
s V jQ *
$_5a
5.7
/o p
's
fOD
88832
'-3S&4
5.8
Education
Gifts
Other
$ ^
Miscellaneous Expenses
Life insurance (if not deducted from income)
_____
Other_____________________________________________
_____
Other_____________________________________________
^ _____
V/>
5.9
5.10
5.11
>Si3S2.& & 3 :a B S 3 3
Description
of Debt
Balance
0(^-
Month of
Last Payment
OkcuLi^
ii&btLs
CP)lflJr
Description
of Debt
(L c,.
C..&
0 . . L . _______
Balance
Month of
Last Payment
IM S co
CD m J l
Amount of
Monthly
Payment
(s>5~
.49*
V
s
$
$
$J3Q
39b4
5.12
6 / l
&3,58S~- CO
6.2
6.3
6.4
6.5
Other:
I declare under penalty o f perjury under the laws of the state of Washington that the foregoing is true and correct.
Signed at
i a i Ol ( a
, [City]
[State] on
6?
[Date].
\2 t
Signature of
The follow ing financial records are being provided to the other party and filed separately w ith the court.
Financial records pertaining to myself:
[ ] Individual [ ] Partnership or Corporate Income Tax returns for the years _______________
_____________________________________________________ including all W -2s and schedules;
[ ] Pay stubs for the dates o f _____________________________________________________________
[ ] O ther:________________________________________________________________________________
07-3-02242-1
32247018
06-12-09
PPP
Child(ren)
No 07-3-02242-1
Parenting Plan
[x ] Proposed (PPP)
[ ] Temporary (PPT)
Final Order (PP)
[]
[]
[x ]
the final parenting plan signed by the court pursuant to a judgment and order establishing
Residential Schedule/Parenting Plan/Child Support 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)____ Sara L. Van Dam____________________________ .
It is O rdered, A d ju d g e d a n d D e cre e d :
I. General Information
This parenting plan applies to the following children;
Name
Age
3964
6 /1 5 /2 8 3 9
B3336
2.1
2.2
3 .9 6 4
i>S I S S Z & B B
-B B S :
3.1
3.2
School Schedule
Upon enrollment in school, the child(ren) shall reside with the [ ] mother [ ] father, except for the
following days and times when the child(ren) will reside with or be with the other parent:
from (day and time)___ Wed @ 4:30pm______________ to (day and time)
__ Sat_9pm____________
[ ] every week [ ] every other week [x] the first and third week of the month [ ] the
second and fourth week of the month [ ] other:
[]
The school schedule will start when each child begins [ ] kindergarten [ ] first grade
[x] other: Immediately
39>4
/2 g B S
B883B
following days and times when the child(ren) will reside with or be with the other parent:
Same as in 3.2
3.4
The children) shall reside with the [x ] mother [ ] father during other school breaks, except for the
following days and times when the children) will reside with or be with the other parent:
Same as in 3.2
3.5
Summer Schedule
Upon completion of the school year, the children) shall reside with the [ ] mother [ ] father,
except for the following days and times when the child(ren) will reside with or be with the other
parent:
[x ]
[]
3.6
[]
Does not apply.
[x ]
The schedule for vacation with parents is as follows:
Each Parent is entitled to exercixe up to two weeks of consecutive vacation with the child over the summer,
during which time the other parents residential time will be suspended. A notification of 2
weeks needs to be made
3.7
even_____________________
odd_____________________
even_____________________
With Father
(Specify Year
Odd/Even/Everv)
odd
even
odd_
3 .9 6 4
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
A-
odd
even
odd
even
odd
odd
odd
L
______________
- 6 / '3 . 5 X 2 .8 8 9
even
odd
even
odd
even
even
even
OCifs
[]
For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times):
[x ]
[]
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
Other:
[]
3.9
Other:
Does not apply because one parent has no visitation or restricted visitation.
Paragraphs 3.3 - 3.8 have priority over paragraphs 3.1 and 3.2 in the following order:
Rank the order of priority, with 1 being given the highest priority:
winter vacation (3.3)
___ school breaks (3.4)
summer schedule (3.5)
[]
_1_holidays (3.7)
^ special occasions (3.8)
,3 vacation with parents (3.6)
Other:
8 8 8 3 3
3964
3.10
3.11
B3B4S
Restrictions
[x ]
[]
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
The [ ] mothers [ ] fathers 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:
[]
There are limiting factors in paragraph 2.2, but there are no restrictions on the
[ ] mothers [ ] fathers residential time with the children for the following reasons:
Transportation Arrangements
Transportation costs are included in the Child Support Worksheets and/or the Order for Child
Support and should not be included here.
Transportation arrangements for the child(ren) between parents shall be as follows:
3.12
Designation of Custodian
The children named in this parenting plan are scheduled to reside the majority of the time with the [
x] mother [ ] father. 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 parents rights and responsibilities under this parenting plan.
3.13
Other
3.14
3964
le v a 's B 3
ee@ 4i
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 altering 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 childs
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.
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
4.2
Major Decisions
Major decisions regarding each child shall be made as follows:
Education decisions
Non-emergency health care
Religious upbringing
[]
[]
[]
[]
[]
n
[]
mother
mother
mother
mother
mother
mother
mother
[3
[3
[]
[]
[]
[]
[]
father
father
father
father
father
father
father
[x]
[x]
[x]
[]
[]
[]
[]
joint
joint
joint
joint
joint
joint
joint
[]
[]
4.3
mother
mother
[]
[]
father
father
[]
[]
joint
joint
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 [ ] mother [ ] father for the following reasons:
[]
[]
[]
[]
There are limiting factors in paragraph 2.2, but there are no restrictions on mutual decision
making for the following reasons:
V. Dispute Resolution
The purpose o f 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 o f this plan must, be used before filing a petition to modify the plan or a motion
for contempt for failing to follow the plan.
[tf
Disputes between the parties, other than child support disputes, shall be submitted to (list person or
agency):
counseling by Cfco d f r J y OfLAlft BCACfiC_____ j or
[]
[]
arbitration bv
_______________________________ .
The cost of this process shall be allocated between the parties as follows:
_% mother _
___% father.
39*> 4
[]
[]
k ,'IS /-2 8 8 9
-B B S 4 3
based on each partys proportional share of income from line 6 of the child support
worksheets.
as determined in the dispute resolution process.
The dispute resolution process shall be commenced by notifying the other party by [^written
request [ ] certified mail [ ] other:
In the dispute resolution process:
(a)
(b)
[]
[ .]
There are no other provisions.
[x]
There are the following other provisions:
Communication via e-mail on upcoming events or schedule changes.
Each parent is in charge of finding out about current events in childs schedule on his/her own.
It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and approved as an
order of this court.
Parenting Plan (PPP, PPT, PP) - Page 9 o f 10
WPF PS 15.0600 Mandatory (6/2008) - R C W 26.26.375, 26.09.016,. 181;. 187;. 194
3964
6 ^1 5 ^2 8 0 9
-8 8 8 4 4
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
RCW 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 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 parents obligations under the plan are
not affected.
Dated:______________________________
______________________________
Judge/Commissioner
Presented by:
Print Name
Print Name
39&4
07-3-02242-1
32247021
06-12-09
RTS
Return of Service
(Optional Use)
(RTS)
Respondent.
/ D e c la re
1.
2.
XI
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
'T h o m a s
SSS45
3 9 &4
3.
4.
The date, time and place o f service were (if by mail refer to Paragraph 4 below):
Date:
Address:
_________________________________ __________________
5.
6.
Other:
I declare under penalty o f perjury under the laws o f the state o f Washington that the foregoing is true and
correct.
Signed at (city)__________________________ , (state)___________on (date)________________________ .
Signature
Fees:
Service
Mileage
Total
____________________________
____________________________
____________________________
ORIGINAL
PCOPC
32247022
c oivtyF!A o
Cl^ K S
06-12-09
Am
JUH i 2
2009
INR&
Prtllinng/PUdBdH
Vfc
CvV
L_
V C. IA
0 <W * '"
)
)
)
)
)
) No.
)
)
)
)
)
07
y
M
v. ^
v
3> -
o t \ ^
v V
Q ^ O
.day of.
- /
\~ -T
o
O -P
1 '0 --'|L (. C V }
I'e w L i
Dated dria
20
Signafun
vm
3964
T h is
Certificate ef attendance
is h e re b y a w a rd e d to
o
L. \!(Xin
CKW]
fo r a tte n d in g a n d c o m p le tin g th e
Jnvpact of tDiuorce
On, Children
Seminar
C o n d u cte d b y G a te w a y s fo r Y o u th and F a m ilie s
In P ie rce C o u n ty , W a s h in g to n o n th is d a y
SEPTEMBER 8,2007
6 /1 5 -^ 2 S 8 9
3043
3 3 6 .4
I
06-12-09
-7 *
Petitioner,
and
lA n P a r o
Respondent.
)
)
)
)
)
)
)
)
)
NO.
0 ? '3 ' ) Z 2 / z - /
S 2
3S & 4
- 6 ^ 1 'S > : 2 - 8 e S
[ ] State o f W A [ ] O ther
. (CSW P)
Signed by the Judicial/Reviewing O fficer. (CSW)
Father: THOMAS L. VANDAM
Superior Court/OAH Case No.: 07-3-02242-1
Worksheets
Children and Ages: SIE-AS R. VANDAM, 6
Parti: Basic Child Support Obligation (See Instructions, Page 1)
1. Gross Monthly Income
a.
b.
c.
d.
e.
f.
Father
Mother
$5,304.00
$2,825.30
$5,304.00
$2,825.30
% BBZ
3 S fc 4
6 2 1 5226S3
Father
$889.51
$405.76
Mother
-
$1,295.27
$4,008.73
$2,825.30
$6,834.03
> ;x
r. \
..-i-r
$961.00
' . / - -1* "
.587
.413
$564.11
$396.89
Part II: Health Care, Day Care, and Special Child Rearing Expenses (See Instructions, Page 3)
$150.00
$150.00
$150.00
" \ S
$48.05
1 (V*'^**
$101.95
-
L-. l t Z ,-ic C
. '..
"V* \S -
08624
3S S 4
.SW;
Father
S 2 1 S /2 B B 9
$101 .95 i
Mother
$59.84
$42.11
$623.95 |
$439.00
$150.00
$150.00
Father
Mother
-
$473.95
$439.00
$473.95
$439.00
Fathers
Household
Mother's
Household
-
BBS 2 5
3S *>4
Father's
Household
d.
e.
f.
18! Other Household Income
a. Income Of Current Spouse or Domestic Partner
(if not the other parent of this action)
Name
Name
^1 5 ^2 ^8 9
Mother's
Household
BBBZb
39&4
1 5 /2 0 0 9
Fathers Signature
Mother's
tether's Signatui
Signature
78 0 9
Date
. o iA
Date
Judge/Reviewing Officer
City
Date
n;..\statetemplates\waworksheet.dtf i:\Jegalplus\cindy-dave\vandafnWandam.scp05713/200911:56am
SupportCa/c 2009
86027
3964
fc v 1 S /2 3 S 9
33020
WORKSHEET SYNOPSIS
FATHER
MOTHER
COMBINED
$4,008.73
.587
$2,825.30
.413
$6,834.03
$564.11
$59.84
$396.89
$42.11
$961.00
$101.95
7.
$623.95
$439.00
4.
TOTAL
$961.00
$961.00
TOTAL OBLIGATION
$150.00
11.
TOTAL CREDITS
$150.00
12.
$473.95
CASE ALERT
SupportCa/c 2009
3964
07-3-02242-1
32247070
6 ^1 5 ^2 8 8 3
3084
06-12-09
FILED
JU w
1 2 2009
PIERCE gmHm-yWSHINGTON
KEVIN STOCK. County Clerk
RY
T
DEPUTY
~ T h o M Z
and
)
)
)
Respondent.
p .m .
NO. 0 7 ~ 3 - 6 Z 2 ^ Z ' {
CERTIFICATE OF COMPLETION
MANDATORY PARENTING
SEMINAR
33 84
> / I S ^ 2 S 3 9
C o u rt Cause N um ber:
^ D
a m
r a
.B 3 8 S 3
3 9 t> 4
07-3-02242-1
32247073
NTHG
6 ^ 1 '5 - < 2 S 0 9
06-12-09
P e titio n e rs N otice of
Hearing fo r Adequate Cause
D eterm ination
(O ptional Use)
(NTHG)
[ ] C lerks A ction R equired
Ihonncc Z .
Petitioner,
and
Respondent.
To the C le rk o f C o u rt a n d to:
l.
Please note that the court will be asked to determ ine if adequate cause exists to m odify/adjust the custody
decree/parenting plan/residential schedule as requested in the petition filed in this case.
2.
A hearing has been set for the follow ing date, time and place.
Date:
_______________________________________
Place:
Time:
9 :3 0
__
^ R o o rp/Department:
_^Tm^>.rn.
l O p f i f 7 / Q 7
3.
4.
You may serve and file a response and opposing declarations prior to the hearing date. If the court determ ines
that adequate cause for hearing the petition is established by the declarations, it will set a date for hearing on an
order to show cause why the petition should not be granted.
5.
If you do not file a response to the petition, opposing declarations, or a notice o f appearance, an order may be
entered w ithout further notice to you finding you in default and granting the relief requested in the petition.
Dated: ^
________________________
%jfe v u i
Signature o f Party cfc-tawyer/W SBA No.
v i n t n ** T i m a \ T a m a
Print
or Type Name
iP - d .Z o Y 7 / V 3 _________________
[Address]
0 9 .0 2 0 0 ) w ith the c o u rt c le rk .
/U jlt;
7839/
394
3 5 /2 8 8 9
No. 07-3-02242-
Submit with final Parenting Plan, only. This form is for statistical reporting purposes only.
rxi
3
I 3
[
_______ U _______
% of time the
children spend
with the Mother
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
% o f time the
children spend
with the Father
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
0BSS2
3984
8 ^ 1 5 /2 8 0 3
Mother:
Prepared by:
[ ] Mediation
[ ] Counseling
on (Date)
80053
4286
07-3-02242-1
32328499
AFSR
6 ^2 5 ^2 8 8 3
629223
06-25-09
1
2
IN COUNTYF CLERK'S OFFICE
A-m.
p.b.
6
7
11
Defendant/Respondent
12
13
16
17
18
19
20
14
15
07-3-02242-1
Plaintiff/Petitioner
10
Cause#:
Declaration:
T he undersigned hereby declares: That s(he) is now and at all times herein mentioned, a citizen o f the United
States and a resident o f the State o f Washington, over the age o f eighteen, not an officer o f a plaintiff
corporation, not a party to nor interested in the above endded action, and is com petent to be a witness
therein.
O n the date and time o f Jun 21 2009 8:25PM at the address o f 20839 60TH ST E # A B O N N E Y LAKE,
within the County o f PIER CE, State o f W A SH IN G TO N , the declarant duly served the above described
docum ents upon THOM AS L. VAN DAM by then and there personally delivering 1 true and correct
copy(ies) thereof, by then presenting to and leaving the same with THOM AS L. VAN DAM (20'S, 180, 5'9,
C/M ).
N o inform ation was provided that indicates that the subjects served are members o f the U.S. military.
21
22
I hereby declare under penalty o f perjury under the laws o f the State o f W ashington that the foregoing is true
and correct.
23
24
25
by.
B. Dunayski
PCR 7003
26
27
28
iin fiin ii
ORIGINAL
PROOF OF SERVICE
Page 1 of I
4236
523238
No.
"T hom as / .
Petitioner,
and
Respondent.
To.
L.
i)
O'? 3 - OZZTZ-1
Summons(Modifi cation/
Adjustment of Custody
Decree/Parenting Plan/
Residential Schedule)
1M)___________________
4 C D A *\
1.
An action has been started in the above court requesting that a custody decree/parenting
plan/residential schedule be modified/adjusted. Additional requests, if any, are stated in the
petition, a copy of which is attached to this notice.
2.
You must respond to this notice 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 an order regarding adequate cause and a decree to modify/adjust the custody
decree/parenting plan/residential schedule and providing for other 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 or a decree may be entered.
3.
The court shall deny the petition unless it finds that adequate cause for hearing the petition is
established, in which case it shall set a date for hearing on an order to show cause why the
requested order or modification should not be granted.
[]
4285
Ttim c L &
- 1
h w
p o r tx
c)CUjA S fri) S k r tj fO a r i ,
jocrm *-
un
M f)/n & s
Q cJ '
.fc /.2 -S /2 8 B 3
5282
FILED
32409910
J U L - 8 2009
In re:
No. 07-3-02242-1
Petitioner,
and
Sara L Van Dam
Respondent.
To:
I. Response
Admissions and Denials
The allegations of the petition in this matter are admitted or denied as follows (check only one for
each paragraph):
Paragraph of the Petition
1.1
1.2
1.3
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
1.1
pj
07-09-09
RSP
[x]
[x]
[]
[J
[x]
[x]
[x]
[x]
[x]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
[]
[]
[]
[]
[x]
M
[]
[]
[]
n
[]
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
[]
[]
[]
[]
[]
n
[]
[]
[]
n
[]
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
2.9
2.10
2.11
2.11.1
2.11.2
2.11.3
2.12
2.13
2.14
2.15
2.16
M
[]
[]
[]
[]
[]
[x]
[]
[x]
[x]
[]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
[]
[3
[]
[3
[3
[x]
[3
[x]
[J
[]
[x]
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
[3
[x]
[x]
W
[x3
[]
[]
[]
[]
[]
[]
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Each allegation of the petition that is denied, is denied for the following reasons (list separately):
2.2 Both the petitioner and respondent have since changed and agreed upon a revised schedule that is fair
for both parties.
2.3 Petitioner Thomas L Van Dam gives the respondent $ 150.00/month as well as paying for school
lunches and hair cuts.
2.11.3 Same as in 2.2
2.13 Same as in 2.2. Also, as stated in the respondents petition, we have not and cannot follow a schedule
that is rigid. Both parties have been flexible in meeting each others change in plans and have always
agreed upon a revised schedule that works for both. The current residential schedule is as follows:
The Petitioner has minor child Thursday night from 6:30 p.m. to 7:30 p.m. Monday night. Every
other weekend, the minor child will be with the Petitioner Thursday night form 6:30 p.m. to Friday
afternoon around 4:00 p.m. and then again on Sunday night from 7:30 p.m. to 7:30 p.m. on
Monday. Holidays are still followed per the Original parenting plan set forth.
2.16 Same as in 2.3. Petitioner Thomas L Van Dam not only meets all legal requirements, but also goes
beyond them as agreed upon by both parties.
1.2
Notice of all further proceedings in this matter should be sent to the address below
1.3
Other
II. Requests
2.1
2.2
2.3
Protection Order
[]
[]
d t.c . t ,
~7 /
th
1 1 1 .S 2 T 2
If you need immediate protection, contact the clerk/court for RCW 26.50 Domestic
Violence forms or RCW 10.14 Antiharassment forms.
_
Dated:
07/08/2009_______________
FILED
IN COUNTY CLERK'S OFFICE
07-3-02242-1
32409^11
AFPT
A.H.
07-09-09
JUL - 8 2009
p.m.
PIC
deputy
ft
r
Petitioners),
and
Sara L. Van Dam
Respondent(s).
This declaration is made by:
Name:
_________________
Age:
_________________
"7 /
v o /2 tt3
i'ilS 2 ? 4
The Respondent refused to utilize Dispute Resolution with a professional marriage counselor
Craig Black. The Petitioner has currently offered, in regards to the work schedules, to utilize
Dispute Resolution through Peace Makers Organization which the Responded again has
refused. The Petitioner requests that original order stand since the time of the minor child is
divided equally.
I declare under penalty of perjury under the laws of the state of Washington that the foregoing
is true and correct.
Signed at
Bonnev I.ak
[City]
WA
TStatel on.
07/08/2009
[Date].
'
4 B -3 3
7 yr
.- * * i c
FILED
o71609
07-.3-02242-1
32451053
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"
JUL 1 5 2009
THOMAS L VAN DAM L/"
No. 07-3-02242-1
Petitioner(s),
DEPUTY
vs.
] Show Cause
(ADM02)
Respondent(s)
Pro 5
Pro
For Petitioner
For Respondent
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Show Cause
JAMES M. MARSHALL
Clerk:
Courtroom number: 100
Calendar: C1- SHOW CAUSE/FAMILY LAW
h*.<i lc
07-3-02242-1
32910842
CME
09-28-09
Cause Number: 0 7 -3 -0 2 2 4 2 -1
Petitioner(s)
vs.
Page 1 of 2
C U N T P. JO HNSO N
Attorney fo r Plaintiff/Petitioner
Resolution:
4668
9 2 2 8 /2 0 0 9
270114
MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner:
JOHN R. HICKMAN
September 25, 2009 03:04 PM The Court signs off on Order of Dismissal for failure to
appear at adequate cause hearing.
End Date/Time: 09/25/09 3:05 PM
Year 2009
4&68
9^2822809
1
07-3-02242-1
32910046
ORDSMD
09-28-09
2
3
4
5
6
7
8
THOMAS L VAN DAM,
Case No. 07-3-02242-1
9
Petitioner,
10
11
12
ORDER OF DISMISSAL
vs.
ORDSMD
SARA L VAN DAM,
Respondent.
13
14
THIS MATTER, having come on regularly for Adequate Cause Hearing on August 3, 2009,
15
and the Petitioner failed to appear personally or through counsel, and the Respondent having not
16
appeared personally or through counsel, And Adequate Cause had not previously been granted .Now,
17
18
Therefore, it is hereby
ORDERED that the Petition for Modification filed June 12, 2009, is hereby Dismissed without
Prejudice in accordance with the case schedule generated when Petition was filed.
19
20
DATED this
21
22
23
24
25
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
Septem ber 23 2014 4:10 PM
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
N O . 07-3-02242-1
N O T IC E OF A P P E A R A N C E
SA R A L V A N D A M
__________________ R espondent(s)
TO: C lerk o f the C ourt
A N D TO: C L IN T P. JO H N SO N , attorney for Petitioner, SILA S R V A N D A M , SA R A L O U IS E
VAN DAM
ntaprsup-0001.pdf
E-FILED
IN COUNTY CLERK'S OF
PIERCE COUNTY, WASHIN
O ctober 15 2014 3:41 P
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242' 1
3
4
5
6
7
10
11
No. 07-3-02242-1
In re:
THOMAS L. VAN DAM,
Petitioner,
12
and
13
14
15
16
17
1.1
18
19
20
1.2
21
22
23
1.3
Dependent Child
24
Age 12
25
Pet for Mod/Adj Parenting Pin (PTMD) - Page 1 of 6
WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181;
.260; .270, R C W 26.26.130(7)(b)
II. B asis
2
2.1
3
4
2.2
Adequate Cause
2.3
Child Support
Child support should be modified or established if the court grants the petition to
modify the parenting plan or residential schedule. A child support worksheet and
financial declaration must be filed with this action. RCW 26.09.170.
10
11
12
2.4
13
14
17
This court has jurisdiction over this proceeding for the reasons below:
18
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.
19
20
21
22
2.6
Name of Child
SILAS VAN DAM
Parents Name
THOMAS VAN DAM
Parents Name
SARA VAN DAM
23
in no place other than the state of Washington and with no person other
than the requesting party or the other party.
Pet for Mod/Adj Parenting Pin (PTMD) - Page 2 of 6
WPF DRPSCU 07.0100 Mandatory (07/2011)
.260; .270, RCW 26.26.130(7)(b)
The requesting party does not know of any person other than the other
party who has physical custody of, or claims to have custody or visitation
rights to, the child.
3
4
The requesting party has not been involved in any other proceeding
regarding the child.
6
7
The requesting party does not know of, any other legal proceedings
concerning the child.
9
10
2.7
11
12
13
14
2.8
15
16
17
18
The child has been integrated into my family with the consent of the other
party in substantial deviation from the decree/parenting plan/residential
schedule.
19
20
21
22
23
24
25
2.9
2.10
2.11
7
2.12
9
10
Dispute resolution.
Decision making.
Transportation arrangements.
11
12
13
14
15
16
17
18
19
20
21
22
2.13
Monday
Father
Father
Tuesday
Father
Father
Wednesday
Mother
Mother
Thursday
Mother
Mother
Friday
Mother
Mother
Saturday
Mother
Father
23
24
Sara works Monday through Thursday. Sara has every Friday, Saturday
and Sunday off.
25
Pet for Mod/Adj Parenting Pin (PTMD) - Page 4 of 6
WPF DRPSCU 07.0100 Mandatory (07/2011) - CR 4.1; RCW 26.09.181;
.260; .270, RCW 26.26.130(7)(b)
We developed this schedule to maximize the time Silas spends with each of
us on days we have off while still alternating some weekend time. We split
the weekends and simply alternate exchanging Silas on Saturday night or
Sunday morning.
3
4
2.14
The court should grant the antiharassment petition for order for protection attached to
this petition.
7
8
9
10
11
12
13
14
15
16
Protection Order
2.15
2.15.1 A. Service member status -- SARA VAN DAM is not a service member;
B. Factual basis:
See the attached Defense Man Power Data Center Report obtained from
https://www.dmdc.osd.mil/scra/owa/home.
2.15.2 A. Dependent of a service member status -- SARA VAN DAM is not a
dependent of a resident of Washington who is on active duty and is a
National Guard member or a Reservist;
B. Factual basis:
The other party failed to respond to a notice to him or her as a
dependent of a person in Military Service that was served on with
this petition, therefore he or she should be presumed not a
dependent of a resident of Washington who is on active duty and is
a National Guard member or a Reservist.
17
18
19
20
The moving party requests that the court find that there is adequate cause for hearing
this petition and enter an order modifying the custody decree/parenting plan/residential
schedule in this matter and approving the proposed parenting plan/residential schedule,
which is filed with this petition.
22
The moving party also requests that the court enter an order establishing child support in
conjunction with the proposed parenting plan/residential schedule. The child support
worksheet and financial declaration are filed with this petition.
23
21
24
By: DANIEL N. COOK, WSBA #34866
Of Attorneys for Petitioner
25
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Pet for Mod/Adj Parenting Pin (PTMD) - Page 6 of 6
WPF DRPSCU 07.0100 Mandatory (07/2011) CR 4.1; RCW 26.09.181;
.260; .270, RCW 26.26.130(7)(b)
Van Dam, Thomas and Van Dam, Sara
S:\C A SE S1 W a n Dam\DRAFTS\Pleadings\Petition for Modification of Parenting Pian.doc
SA R A L. VAN DAM
No
Respondent.
5. Describe what the Respondent did or said that you think is harassment or stalking.
The respondent has com m itted acts of harassment or stalking as follow s:
A . Describe the most recent incident of harassment or stalking.
How did the respondent make these statements? 3 in person mail/written notes
e-mail text phone social media (such as facebook and twitter)
other (describe):_______________________________________________________________ .
Date and time (on or around): In Fall 2013
Location: My house in Auburn - 2817 67th Street Court SE, Auburn, WA 98092
What did the respondent do or sav t hat you believe to be harassing or stalking behavior?
Sara Van Dam h a d was angry and violent tow ard me a fte r I disagreed with h e r about
financial issues related to o u r child in common. It was late at night, app ro xim a te ly _____
p.m. and the children in m y hom e were asleep. I term inated the conversation and shut
the front d oor and Sara began kicking and pounding on the do o r in a loud and obnoxious
way. Sara took landscaping rocks and began throwing them at the house in a loud and
dangerous way. The children in the house woke up and were afraid. I was at a loss to
know what to do.
How did the respondent make these statements? ^ in person mail/written notes
e-mail text phone social media (such as facebook and twitter)
other (describe):_______________________________________________________________ .
B. Describe other incidents of harassment or stalking. For each incident, include the date, time
(on or about), location, what was said, how statements were made, and what was done to a
victim.
Sara is very rude, b elligerent and uses frequent p rofanity in h e r conversations with me.
She is dem anding and does not respect boundaries. H e r text m essages are very
harassing.
Pt for an Or for Protection - Harassment/Stalking (PTORAH, PTORSTK*) - Page 2 of 5
WPF UHST-02.0200 (06/2014) - RCW 10.14.040, .800, RCW 7.92.030
6.
How did the incidents you describe above make you, the minor, or the vulnerable adult feel?
7.
Has the respondent used, displayed, or threatened to use a firearm or other dangerous
weapon in a felony? Please describe:
No.
8.
Has the respondent previously committed an offense that makes him or her ineligible to
possess a firearm under the provisions of RCW 9.41.040? Please describe:
N o t to m y kn o w le d g e .
9.
N o t to m y kn o w le d g e .
10. Do you have any evidence of the harassment or stalking conduct other than testimony?
No
M Yes.
11. Has/have the victim /s or the respondent ever requested or obtained protection from the
other person in a restraining order, civil protection order, or criminal no-contact order?
If yes, list the type of order, the name of the court and the approximate date, and whether
the request was granted:
N o t to m y kn o w le d g e .
12. Is there any other litigation between the victim/s and the respondent? This includes all
matters - pending or past - such as parenting plans, landlord-tenant disputes, employment
disputes, or property disputes. If yes, provide case number/s if known, type of case, and
name o f court:
The p a re n tin g p la n m o d ific a tio n a s s o c ia te d w ith th is case.
>
Requests
Pay Fees and Costs: Require the respondent to pay fees and costs of this action, which
may include administrative court costs and service fees and petitioners costs including
attorneys fees._______________________________________________________________________
What irreparable harm would result if an order is not issued immediately without prior notice
to the respondent?
Petitioner
Print or type name
What irreparable harm would result if an order is not issued immediately without prior notice
to the respondent?
iM
________ at
s e cvV M e._______
___ , Washington.
~TlU Wi /Y"'Hf'V i
Petitioner
{V o wi
1
2
3
4
5
6
7
IN THE S U P E R IO R C O U R T OF THE ST A T E OF W A SH IN G T O N
IN A N D F O R T H E C O U N T Y OF P IE R C E
In re:
No. 07-3-02242-1
10
T H O M A S L. V A N DAM,
11
and
12
13
14
15
16
17
18
Petitioner,
D E C L A R A T IO N P U R S U A N T TO G R 17
(FILING OF E -M A IL E D SIG N A T U R E )
S A R A L. V A N DAM,
Respondent.
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
of Washington that the following is true to the best of my knowledge.
I am the person responsible for filing of the e-mailed signature page of the
PETITION FOR MODIFICATION OF PARENTING PLAN AND ATTACHED PETITION
FOR ORDER OF PROTECTION.
19
including this declaration page (but not including attachments), and is a complete and
21
22
23
24
legible image that I have examined personally and that was received by me via e-mail at
[email protected].
Signed at Lakewood, WA on October 15, 2014.
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
IN COUNTY CLERK'S OFFICI
PIERCE COUNTY, WASHINGT
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
3
4
5
6
7
8
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
10
11
12
In re:
No. 07-3-02242-1
Summons(Modification/ Adjustment of
Custody Decree/Parenting Plan/
Residential Schedule)
(SM)
Petitioner,
13
and
14
Respondent.
To:
S a ra Van D a m
1.
An action has been started in the above court requesting that a custody
decree/parenting plan/residential schedule be modified/adjusted. Additional
requests, if any, are stated in the petition, a copy of which is attached to this
notice.
2.
You must respond to this notice 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 an order regarding adequate cause and a decree to modify/adjust the
custody decree/parenting plan/residential schedule and providing for other 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 or a decree may be
entered.
18
19
20
21
22
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
3.
2
3
4
The court shall deny the petition unless it finds that adequate cause for hearing
the petition is established, in which case it shall set a date for hearing on an
order to show cause why the requested order or modification should not be
granted.
4.
You may file an opposing declaration to show that there is not adequate cause to
hold a full hearing. If you do not file an opposing declaration or respond and the
court finds that adequate cause exists, the court may enter an adequate cause
order and an order modifying/adjusting the custody decree/parenting
plan/residential schedule without notice to you pursuant to RCW 26.09.270.
5.
Your written response to the summons and petition must be on form WPF
DRPSCU 07.0200, Response to Petition for Modification/Adjustment of Custody
Decree/Parenting Plan/Residential Schedule. 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:
8
9
10
11
12
13
http://www.courts.wa.gov/forms
14
6.
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 notice. Within 14 days after you
serve the demand, the petitioner must file this action with the court, or the service
on you of this notice and motion will be void.
7.
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.
8.
15
16
17
18
19
20
21
22
23
This summons is issued pursuant to RCW 4.28.100 and Superior Court Civil Rule 4.1 of
the state of Washington.
DATED this ' 0
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
1
2
3
4
5
Serve a c o p y o f y o u r re s p o n s e o n :
Daniel N. Cook
FAUBION, REEDER, FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Telephone: 253-581-0660
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
O ctober 15 2014 3:41 PM
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
Phone:
Respondent
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
M otion - Tem porary O rder
Calendar: Show Cause/Family Law
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
ADDRESS:
1 of
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
No. 07-3-02242-1
NO: 07-3-02242-1
ORDER SETTING CASE SCHEDULE
Type of case:
DIC
Vs.
Track Assignment:
Assignment Department:
Docket Code:
Modification of Custody
TOLL
ORSCS
Notice of Adequate Cause & Note for Comm Cal filed w/Petition or no later than
Confirmation of Service
10/22/2014
Adequate Cause Hearing on Commissioner Calendar to be held. (If this hearing is not held by this date,
petition will be dismissed)
Set Settlement Conference Date with Judge/Commissioner VICKI L. HOGAN
12/17/2014
12/17/2014
12/17/2014
11/5/2014
12/17/2014
2/18/2015
3/11/2015
3/25/2015
4/8/2015
Week of 5/20/2015
5/27/2015
6/10/2015
6/24/2015 9:00
Trial
Unless otherwise instructed, ALL Attorneys/Parties shall report to the trial court at 9:00 AM on
the date of trial.
NOTICE TO PLAINTIFF/PETITION ER
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 3.
NOTICE TO ALL PARTIES
All 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 3 does not apply while the case is in arbitration.
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHINGT
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
3
4
5
6
7
8
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
9
10
11
12
No. 07-3-02242-1
In re:
13
SARA L. VAN DAM,
14
Respondent.
15
State and federal law provide protections to defendants/respondents who are on
16
N o tice.
17
active duty in the military service, and to their dependents. This notice only pertains to a
18
19
reserve component under a call to active service for a period of more than thirty (30)
20
21
22
the service members spouse, a service members minor child, or an individual for whom the
23
service member provided more than one-half of the individuals support for one hundred
24
25
Dependent,docx
FAUBION, REEDER,
FRALEY & COOK, P.S.
One protection provided is the protection against the entry of a default judgment in
2
certain circumstances. If you are the dependent of a member of the National Guard or a
3
4
5
military reserve component under a call to active service for a period of more than thirty (30)
consecutive days, you should notify the plaintiff/petitioner or, if the plaintiff/petitioner is
represented by an attorney, the plaintiff/petitioners attorney in writing of your status as such
within twenty (20) days of the receipt of this notice. If you fail to do so, then a court or an
administrative tribunal may presume that you are not a dependent of an active duty member
of the National Guard or reserves, and proceed with the entry of an order of default and/or a
10
default judgment without further proof of your status. Your response to the plaintiff/petitioner
11
12
or plaintiff/petitioners attorney about your status does not constitute an appearance for
jurisdictional purposes in any pending litigation, a waiver of your rights or a response to the
13
petition, complaint or other application for relief that was filed against you.
14
15
16
17
18
19
20
21
22
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
E-FILED
IN COUNTY CLERK'S OF
PIERCE COUNTY, WASHIN
O ctober 15 2014 3:41 P
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-
3
4
5
6
7
8
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
10
11
In re:
No. 07-3-02242-1
PROPOSED
PARENTING PLAN
(PPP)
12
13
14
Petitioner,
and
SARA L. VAN DAM,
Respondent.
15
16
17
18
19
I. General Information
This parenting plan applies to the following child:
20
Name
SILAS VAN DAM
21
22
23
Age
12
Under certain circumstances, as outlined below, the court may limit or prohibit a
parents contact with the child and the right to make decisions for the child.
24
2.1
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
1
2
2.2
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 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 residential schedule. If you do not use these paragraphs, write in your own
schedule in Paragraph 3.13.
3.1
6
7
10
11
12
School Schedule
Upon enrollment in school, the child shall reside equally with both parents on the
following alternating weekly schedule:
13
14
Sunday
1 Father
2 Father
15
16
Monday Tuesday
Father
Father
Father
Father
Wednesday
Mother
Mother
Thursday
Mother
Mother
Friday Saturday
Mother Mother
Mother Father
17
All exchanges shall take place curbside. Neither parent shall come onto the
other parents property or enter the other parents home to exchange the child.
18
19
20
21
22
23
24
3.3
The child shall reside with each parent during winter vacation as follows:
Winter Vacation shall be defined as commencing the day after school lets out for
the Winter Vacation Break and concluding on the day before school resumes.
In even numbered years, the mother shall have the child for the first
half of the Winter Vacation. Visitation shall begin the day after
school lets out at 9:00 a.m. until December 27th at 8:00 p.m. In odd
numbered years, the mother shall have the child from December
27th 8:00 p.m. through the day before school resumes at 6:00 p.m.
Parenting Plan (PPP, PPT, PP) - Page 2 of 10
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
1
In odd numbered years the father shall have the child for the first
half of the Winter Vacation. Visitation shall begin the day after
school lets out at 9:00 a.m. and conclude on December 27th at
8:00 p.m. In even numbered years the father shall have the child
from December 27th at 8:00 p.m. through the day before school
resumes at 6:00 p.m.
2
3
4
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3.4
The child shall reside with each parent during spring break as follows:
Same as 3.2.
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3.5
Summer Schedule
Upon completion of the school year the child shall reside with each parent as follows:
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3.6
Each parent shall have two weeks uninterrupted with the child for vacation during
the summer months when the child are off from school.
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Each parent shall notify the other parent in writing of his or her two weeks
of vacation no later than May 1 of each year. If there is a conflict in
vacation dates the fathers choice will control in odd years and the
mothers choice will control in even years.
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3.7
The residential schedule for the child for the holidays listed below is as follows:
With Mother
With Father
(Specify Year
(Specify Year
Odd/Even/Everv)
Odd/Even/Everv)
See Par. 3.3
See Par. 3.3
New Years Day
Martin Luther King Day
Presidents Day
Memorial Day
Easter
Even
Odd
July 4th
Even
Odd
*
Labor Day
Even
Veterans Day
Odd
Thanksgiving Day
Even
Odd
See Par. 3.3
Christmas Eve
See Par. 3.3
Parenting Plan (PPP, PPT, PP) - Page 3 of 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,. 181;. 187;. 194
Van Dam, Thomas and Van Dam, Sara
S :\C A S E S 1 W a n D am \D RAFTS\Pleadings\Proposed Parenting Plan.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
Christmas Day
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Holidays marked with an asterisk (*) shall be spent with the parent who is entitled to
the preceding weekend under the alternating week schedule.
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4
Unless otherwise noted, Holidays shall be the night before at 6:00 p.m. until the day of
the Holiday at 8:00 p.m.
July 4th will be from 10:00 a.m. on July 4 until 12:00 p.m. on July 5.
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3.8
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10
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Mothers Day
Fathers Day
Fathers Birthday
Mothers Birthday
Childs Birthday
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With Mother
(Specify Year
Odd/Even/Everv)
Every
With Father
(Specify Year
Odd/Even/Everv)
Every
Every
Every
Odd
Even
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If the Special Occasion is on a non-school day, the Special Occasion shall be the
night before at 6:00 p.m. until the day of the Special Occasion at 8:00 p.m.
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If the Special Occasion is on a a school day, the Special Occasion shall be from after
school on the day of the Special Occasion until the8:00 p.m. on the day of the Special
Occasion.
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3.9
19
Paragraphs 3.31 - 3.8, have priority over paragraphs 3.1 and 3.2, in the following order:
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Rank the order of priority, with 1 being given the highest priority:
4
2
school breaks (3.4)
holidays (3.7)
summer schedule (3.5)
1
6
special occasions (3.8)
vacation with parents (3.6)
winter vacation (3.3)
5
3
Restrictions
Does not apply.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
1
3.11
Transportation Arrangements
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3
Transportation costs are included in the Child Support Worksheets and/or the
Order of Child Support and should not be included here.
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3.12
The child named in this parenting plan are scheduled to reside the majority of the
time with both parents equally. Both parents are 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
parents rights and responsibilities under this parenting plan.
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Designation of Custodian
3.13
Other
A. The parties shall use the My Family Wizard software for calendaring,
communication, storing information and tracking of financial matters. All non
emergency communication between the parents shall be made using the My
Family Wizard software. No phone calls or text messages shall be made to the
other party except in the event of an emergency and in event of an emergency
shall be strictly limited to discussion of the emergency. All communication
between the parents shall be civil, courteous and respectful.
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B. Neither parent shall discuss the residential schedule with the child except for
plans that have already been agreed to by both parties. Neither parent shall
provide information to the child of the status of child support payments or other
legal matters regarding the parents.
C. Each parent acknowledges that the other parent spends substantially equal
residential time with the child. For purposes of any future relocation of the child,
neither parent may claim the presumption under RCW 26.09.520 favoring
relocation of the child and both parents are required to give the notice of
relocation under RCW 26.09.430 and .440 when relocating. Based upon the
child's long-term involvement in school, athletics and other extra-curricular
activities, the existence of family and social relationships and the connections to
health care professionals all in the Pierce County area the parties agree that the
child should remain in the Pierce County area if one parent decides to relocate
out of the Pierce County area.
Parenting Plan (PPP, PPT, PP) - Page 5 of 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
Van Dam, Thomas and Van Dam, Sara
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
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3.14
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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 shall give notice to every person entitled to court ordered time with
the child.
If the move is outside the childs 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).
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.
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A person entitled to time with a child under a court order can file an objection to
the childs relocation whether or not he or she received proper notice.
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.
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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.
Parenting Plan (PPP, PPT, PP) Page 6 of 10
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
1
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.
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3
4
5
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 child.
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9
4.2
Major Decisions
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11
Education decisions
Non-emergency medical and mental health care
Religious upbringing
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joint
joint
joint
Regarding medical decisions, either parent may take the child for regularly
scheduled with their ordinary physicians or medical care providers for
check-ups, vaccinations, routine/recurring doctor or dental appointments
or for treatment of mild or seasonal type illnesses (e.g., cold, flu, allergy,
earaches, anti-biotic, short term prescriptions etc.) without triggering joint
decision-making requirements. The parties shall communicate as much
as possible about even these routine medical and dental decisions to
ensure coordination of care and full advice to the medical professionals
caring for the child.
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Joint decision means that the parent seeking to make a major decision
shall notify the other parent of the proposed major decisions he or she
intends to make and the other parent may object to the decision and/or
propose an alternative within 14 days of notice. If the other parent does
not object or propose an alternative the parents decision shall be final and
he or she may proceed immediately after the expiration of the 14 days.
The parent seeking to make a decision shall not take any irreversible
action in furtherance of a proposed major decision until after 14 days
notice, or, until after an agreement is reached or a court order is issued if
the other parent objects to the decision.
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4.3
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
1
V. Dispute Resolution
2
3
4
5
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
10
The cost of this process shall be allocated between the parties as follows:
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7
11
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13
The dispute resolution process shall be commenced by notifying the other party
by written request via certified mail:
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(a)
(b)
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(c)
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(d)
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(e)
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
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may include, but not be limited to, any records being kept or maintained by a
State or Federal government department or agency. Any third party having or
maintaining any such records is hereby authorized to release any and all
information upon presentation of this order. Any person, including, but not limited
to, any physician, psychologist, counselor, officer or educator, may speak candidly
of or concerning the child named herein to either of the above named parents
without court order or subpoena authorizing same, upon presentation of this
order. It shall be the responsibility of the parent requesting the records to do so
directly with the source of the records.
Both parties shall allow the child to freely communicate with the other party,
including allowing the child to call the other party on the telephone. Both parties
shall have telephone access with the child, excluding the childs calls to that
party, of not less than two calls per week at reasonable times and for reasonable
durations.
Neither parent shall make disparaging remarks about the other parent or any
other remarks that might cause diminishment of the childs respect for the other
parent either to the child or in the presence of the child, nor shall they allow the
child to make disparaging remarks about the other parent.
VII. Declaration for Proposed Parenting Plan
(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.
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l / 1( /
/
Date and Place of Signature
a *4 ;
U]
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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 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 parents obligations
P a re n tin g P la n (P P P , P P T , PP ) - P a g e 9 o f 10
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
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Dated:
Judge/Commissioner
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, WSBA#
Attorney for Respondent
Presented by:
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T h om as V an bm , P e titio n e r"
Date
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
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IN THE S U P E R IO R C O U R T OF THE ST A T E OF W A SH IN G T O N
IN A N D FO R THE C O U N T Y OF P IE R C E
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In re:
No. 07-3-02242-1
T H O M A S L. V A N DAM,
Petitioner,
D E C L A R A T IO N P U R S U A N T TO G R 17
and
(FILING OF E -M A IL E D SIG N A T U R E )
S A R A L. V A N DAM,
Respondent.
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
of Washington that the following is true to the best of my knowledge.
I am the person responsible for filing of the e-mailed signature page of the
PROPOSED PARENTING PLAN.
I have examined the document and determined that it consists of 11 pages,
19
including this declaration page (but not including attachments), and is a complete and
20
21
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legible image that I have examined personally and that was received by me via e-mail at
[email protected] m.
Signed at Lakewood, WA on October 15, 2014
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Declaration Pursuant to GR 17 - Page 1 o f 1
S:\CASES1Wan Dam\DRAFTS\Pleadings\Declaration re Emailed Signature.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING Tt
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF PIERCE
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No. 07-3-02242-1
In re:
THOMAS L. VAN DAM,
Petitioner,
and
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Based on the declaration below, the undersigned moves the court for a temporary order
which:
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DATED this j_
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P.S.
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Mtn/Decl for Temp Ord (MTAF) - Page 1 of 6
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
1
II. Declaration
2
I, TOM VAN DAM, and the Petitioner in this matter. I am over the age of 18 and I
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4
5
SARA VAN DAM and I were formerly married. We had one child together, SILAS,
who is now 12 years old. SARA and I dissolved our marriage in 2007 when SILAS was
only 4 years old. In the seven years since we first established the parenting plan, many
10
things have changed, including work schedules for both parties, residences for both
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following the 2007 parenting plan. We have substantially deviated from the parenting
13
plan for a long time and I am now asking the court to enter a formal parenting plan
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court to enter a restraining order. There have been two incidents when SARA has come
to my house and acted very inappropriately. She has been hostile, belligerent, rude and
18
frankly a little scary. Certainly it has traumatized the children in my home. SARA and I
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generally get along well and are fairly cooperative but certain topics (mostly financial) are
20
very triggering for SARA and if I do not do what she wants financially she will sometimes
21
erupt in an angry and inappropriate manner. To avoid this happening in my home and
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upsetting my wife and children I am asking the court to enter a restraining order.
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Mtn/Decl fo r Temp Ord (MTAF) - Page 2 o f 6
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
The original parenting plan entered in 2005 provided for both parents to have daily
2
contact with SILAS. It was intended to be an equally shared residential schedule. At the
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4
5
time, I was working an aftemoon/evening shift and SARA was working days.
The
parenting plan provides for me to have SILAS every weekday morning and SARA would
have SILAS every weekday evening. He was generally in daycare in the afternoons. We
read as follows:
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I now work three 12 hour day shifts on Thursday, Friday and Saturday. I have
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We have not followed the prior parenting for the last 4-5 years. We have modified
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the residential schedule by mutual agreement and we have intended that change to be
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permanent. We still provide for Silas to reside equally with both parents but we divide it
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up differently because our work schedules and residence locations have changed. For
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the last 4-5 years we have followed an alternating and repeating two week schedule with
SILAS spending overnights as follows:
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Mtn/Decl fo r Temp Ord (MTAF) - Page 3 o f 6
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
1
2
3
4
5
on days we have off while still alternating some weekend time. We split the weekends
and alternate exchanging SILAS on Saturday at noon. SILAS is old enough to be home
alone for short periods at this point, but when SILAS was younger this minimized the time
SILAS had to spend in before or after-school care. Since I was always working on Friday
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and Saturday and SARA always had these days off it made sense for her to have these
days. It made sense for me to have Sundays through Tuesdays since I was always off
12
those days.
13
This also made sense because I have now remarried and have a dynamic blended
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family. In our family attending church on Sunday is a high priority and SILAS enjoys
attending church with my wife and his step-siblings. Linder this schedule SILAS comes
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to my house on Saturday at noon, and he is able to enjoy that dynamic blended family
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SARA and I have been generally cooperative and able to reach agreement on the
major aspects of our parenting plan, for example, the residential schedule. Flowever,
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SARA has also been very unpredictable and explosively angry when discussing other
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issues, primarily financial ones. For example, when she asks for money for a school
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expense if I suggest that I should pay the school the amount she suggested she gets
Mtn/Decl fo r Temp Ord (MTAF) - Page 4 o f 6
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, W A 98499
Phone: (253) 581-0660
angry, rude, belligerent and even hostile. SARA has cursed me and my current wife out
2
many times. SARA has called me and my spouse foul names. SARA has sent me
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5
invaded my home. In the Fall of 2013, SARA was angry and violent toward me after I
disagreed with her about issues related to SILAS. Sara was late picking up Silas, so we
tried contacting her to find out what time she would be there. She didnt answer the
phone call or call back in response to our voicemail. At 9:30 p.m., past Silass bedtime,
10
we had not heard back, so we put Silas to bed. When Sara showed up at 10:00 p.m. to
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pick Silas up, he was already in bed asleep, as were all the children. I terminated the
conversation and shut the front door. SARA began kicking and pounding on the door in a
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loud and obnoxious way. SARA took landscaping rocks and began throwing them at the
14
house in a violent and dangerous way. The children in the house woke up and were
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few weeks prior to the incident. On the day of the incident she came to my house and
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again demanded money. I had checked with the school and found that not as much was
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owed as she had originally said so I told her I had paid or would pay my half to the school
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directly. SARA got extremely angry I would not give her the money. SARA screamed at
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me, shouted obscenities and called me disparaging names (e.g., deadbeat). I told SARA
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I would not allow her to talk to me like that and I closed and locked the front door. SARA
then ran around to the garage and forced herself into my house and continued screaming
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Mtn/Decl fo r Temp Ord (MTAF) - Page 5 o f 6
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone:(253) 581-0660
and yelling at me in front of my family (my current spouse, two children of my current
2
spouse from a prior relationship and SILAS).
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For these reasons I am asking for a restraining order prohibiting SARA from
coming into my house or onto the grounds of my residence. We can exchange SILAS via
a curbside exchange. He is 12 years oid and fuily capable of walking to and from a car at
I also believe our family would be best served by using the Our Family Wizard
10
relationship and have been able to reach agreement on most major issues involving
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SILAS. Sometimes our communications break down, particularly when finances are
involved. SARAs text messages have been so harassing I would like a neutral and
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objective service to record all of our communications. Obviously, exceptions could be
14
made for true emergencies or time sensitive matters (e.g., if child is in hospital or
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unavoidable delay impacts exchange time). But all other routine and non-emergency
communications should be through Our Family Wizard. We can also use the information
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sharing, calendar and financial functions of the website service. This will improve our
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Signed at (city) h p / ) / ) g ^
h jKt
(state)
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M tn/D ecl fo r Tem p Ord (M TAF) - Page 6 o f 6
W P F D R 0 4 .0 1 0 0 M andatory ( 0 6 /2 0 1 4 ) - RCW 2 6 .0 9 .0 6 Q ; . 1 10; .120; . 1 9 4
FAUBIO N, KEEPER,
FRALEY & COOK, P.S.
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IN THE S U P E R IO R C O U R T OF THE ST A T E OF W A SH IN G T O N
IN A N D F O R THE C O U N T Y OF P IE R C E
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In re:
No. 07-3-02242-1
T H O M A S L. V A N DAM,
Petitioner,
D E C L A R A T IO N P U R S U A N T TO G R 17
and
(FILING OF E -M A IL E D SIG N A T U R E )
S A R A L. VAN DAM,
Respondent.
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
of Washington that the following is true to the best of my knowledge.
I am the person responsible for filing of the e-mailed signature page of the
MOTION AND DECLARATION FOR TEMPORARY ORDER.
I have examined the document and determined that it consists of 11 pages,
19
including this declaration page (but not including attachments), and is a complete and
20
legible image that I have examined personally and that was received by me via e-mail at
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[email protected].
Signed at Lakewood, WA on October 15, 2014.
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Declaration Pursuant to GR 17 - Page 1 of 1
S:\CASES1Wan Dam\DRAFTS\Pleadings\Dec!aration re Emailed Signature.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHINGT
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
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S U P E R IO R C O U R T OF W A SH IN G T O N
C O U N T Y OF P IE R C E
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No. 07-3-02242-1
In re:
T H O M A S L. V A N DAM,
Petitioner,
and
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S A R A L. V A N DAM,
Respondent.
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1.
Please note that the court will be asked to determine if adequate cause exists to
modify/adjust the custody decree/parenting plan/residential schedule as requested
in the petition filed in this case.
2.
A hearing has been set for the following date, time and place.
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4.
You may serve and file a response and opposing declarations prior to the hearing
date. If the court determines that adequate cause for hearing the petition is
established by the declarations, it will set a date for hearing on an order to show
cause why the petition should not be granted.
5.
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3.
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Petitioners Notice of
Hearing for Adequate C au se
Determination
(Optional Use)
(NTHG)
[X] Clerks Action Required
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Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.
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E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
O ctober 15 2014 3:55 PM
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
Phone:
Respondent
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
Adequate Cause - C ustody
Nature of Hearing: Parenting Plans
Calendar: Show Cause/Family Law
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
ADDRESS:
1 of
II
07-3-02242-1
43615670
LTR8
11-12-14
-------------------------
SUPERIOR COURT
OF THE
STATE OF WASHINGTON
FOR PIERCE COUNTY
334 County-City Building
(253) 798-3654
Deadline:
11/05/14
Pursuant to Pierce County Local Rules and also pursuant to the Case Scheduling Order or Order Assigning
Case to Department given to you at the time of filing this case, you are out of compliance. Please take the
actions necessary to immediately comply with the Case Schedule or Order Assigning Case to Department.
Please file and deliver a courtesy copy of the document to the Judge.
If the court finds that an attorney or party has failed to comply with the Case Schedule or Order Assigning
Case to Department and has no reasonable excuse, the court may order the attorney or party to pay
monetary sanctions to the court, or terms to any other party who has incurred expense as a result of the
failure to comply, or both; in addition, the court may impose such other sanctions as justice requires. See
PCLR 3(k) or PCLSPR 94.05(g).
Sincerely,
l* f
Brian Matson
Department 08
Phone #: 253-798-7565
Judicial assistant to:
Judge Brian Tollefson
\lxcivil.pbf\d_noncom plianceJetter_report
2014
10:26AM
2533012645
PAGE
ANDERSON INVESTIGATI
E-FILEL
IN COUNTY CL
PIERCE COUNTY W
Novem ber 14 2 ) 1
KEVIN S
COUNTY CL
NO: 07-3-02
2
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF PIERCE
8
9
10
In re:
THOMAS L. VAN DAM,
11
Petitioner,
12
and
13
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
J
The undersigned declares under penalty o f peijury under the laws o f the State of
Washington that the following is true and correct.
The declarant is now and at all tim es herein mentioned was a citizen o f the United
States and a resident of the State o f Washington, over the age o f 18, not a party to nor
interested in the above-entitled action and competent to be a witness therein:
A nderson investigations , l l c
P.CL Box 7770
Tacoma, W A 98417
Telephone: (253) 301-2240
1 0 :26AM
1
2
3
2533012645
ANDERSON INVESTI6ATI
The service address is: 2101 North 34th Street, Suite #160, Seattle, King County, WA
5
98103.
6
Dated this 14thDay Of November, 2014 at Tacoma, Pierce County, WA.
7
Cost: $70.00
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A nderson Investigations , LLC
P.O.Box 7770
Tacoma, WA 98417
Telephone: (253) 301-2240
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
Novem ber 14 2014 10:48 AM
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
N O . 07-3-02242-1
C O N F IR M A T IO N OF SE R V IC E
SA R A L V A N D A M
__________________ R espondent(s)
CS
CSSRV O
D A T E D : N o v em b er 14, 2014
cssup-0002.pdf
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
Case Number:
07-3-02242-1
NO: 07-3-02242-1
Case Name:
Certificate of Attendance
This certifies that
I m p a c t O n C h ild r e n ^
The Changing Family
A four hour seminar at:
HOPESPARKS
On NOV 15,2014
_____ /S/ Signature_______
Pati West
Instructors:
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
November 17 2014 3:12 PM
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
N O . 07-3-02242-1
N O T IC E OF A P P E A R A N C E
SA R A L V A N D A M
__________________ R espondent(s)
TO: C lerk o f the C ourt
A N D TO: C L IN T P. JO H N SO N , attorney for Petitioner, D aniel N C ook, attorney fo r Petitioner,
T H O M A S L E E V A N D A M , SILA S R V A N D A M
D A T E D : N o v em b er 17, 2014
ntaprsup-0001.pdf
/s/ S U E L L E N H O W A R D
SU ELLEN H O W A R D , #20506
A ttorney fo r R espondent(s)
SUELLEN HOWARD
15 S Grady Way Ste 400
WA 98057-3240
(425) 228-8899
t *'
c*
07-3-02242-1
43650528
11-18-14
IN T H E S U P E R IO R C O U R T O F W A S H IN G T O N , C O U N T Y O F P IE R C E
.
,,/
(253)798-3654
' ' :
'
' '
SUPERIOR COURT
OF THE
STATE OF WASHINGTON
FOR PIERCE COUNTY
'
Deadline:
11/05/14
Pursuant to Pierce County Local Rules and also pursuant to the Case Scheduling Order or Order Assigning
Case to Department given to you at the time.of.filing this case, you are out of compliance. Please take the
actions necessary to immediately comply with the Case Schedule or Order Assigning Case to Department.
Please file and deliver a courtesy copy of the document to the Judge.
If the court finds that an attorney or party has failed to comply with the Case Schedule or Order Assigning
Case to Department and has no reasonable excuse, the court may order the attorney or party to pay
monetary sanctions to the court, or terms to any other party who has incurred expense as a result of the
failure to comply, or both; in addition, the court may impose such other sanctions as justice requires. See
PCLR 3(k) or PCLSPR 94.05(g).
Sincerely,
C lint P. J u I i i i s u i i -------- *
Daniel N Cook
Van Dam, Sara Louise
Brian Matson
Department 08
Phone #: 253-798-7565
Judicial assistant to:
Judge Brian Tollefson
To:
'Jxcivil.pbl\d_noncom pliance_letter_report
1 1
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E-FIL ED
IN COUNTY CLE RK'S OFFICE
PIERCE COUNTY W ASHING TO N
Decem ber 02 2 J14 12:58 PM
1
KEVIN S TO C K
COUNTY CLERK
NO: 07-3-0:2242-1
-J>
4
5
6
7
8
9
10
11
12
13
NO. 07-3-02242-1
RESPONSE TO PETITION FOR
MODIFICATION/ADJUSTMENT OF
CUSTODY DECREE/PARENTING
PLAN/RESIDENTIAL SCHEDULE
(RSP)
14
I. RESPONSE
15
16
1.1
17
The allegations of the petition in this matter are ADMITTED or DENIED as follows:
18
Paragraph of the
Petition
19
20
1.1
Admitted
1.2
Admitted
1.3
Admitted
24
2.1
Admitted
25
2.2
21
22
23
26
27
28
RESPTOPETFORMOD/ADJ(RSP) - Page1of3
WPFDR07.0200(9/2000)- RCW26.09.260; .270; 2610.200
SUELLEN HOWARD
ATTORNEY AT LAW
15 SOUTH GRADY WAY. SUITE 400
RENTON, WASHINGTON 08057
(425) 228-8899 Fax: (425) 277-9279
2.3
Lacks knowledge
2.4
Admitted
2.5
Admitted
2.6
Admitted
2.7
Admitted
2.8
2.9
Admitted
2.(0
Admitted
10
2.11
Admitted
11
2.12
Admitted
12
2.13
Admitted
13
2.14
Denied
2.15
Admitted
4
5
6
7
8
14
15
16
17
The allegations of the petition which are denied, are denied for the following reasons:
18
19
There is no detriment to the child and a shared time plan in a different arrangement should be continued.
20
21
1.2
22
23
Notice of all further proceedings in this matter should be sent to the nonmoving party care of the
24
address below.
25
26
27
28
RESPTOPETFORMOD/ADJ(RSP) - Page2of3
WPFDR07.0200(9/2000) - RCW26.09.260; .270; 26.10.200
SUELLEN HOWARD
ATTORNEY AT LAW
15 SOUTH GRADY WAY, SUITE 400
RENTON, WASHINGTON 98057
(425)228-8899 Fax: (425) 277-9279
1.3
OTHER.
2
3
4
II. REQUESTS
5
2.1
6
Does not apply.
7
8
2.2
9
10
11
Find there is adequate cause for hearing this matter.
12
Find that there is adequate cause to enter a parenting plan based on the mothers relocation to
Florida that does not relocate the child but provides for a long distance parenting plan.
13
14
15
16
Dated:
A jsu u -t-^h .. ,
2.0 V
'
17
18
19
Suellen Howard
WSBA 20506
Attorney for Respondent
15 South Grady Way. Suite 400
Renton, WA 98057
20
21
22
23
24
25
26
27
28
RESPTOPETFORMOD/ADJ(RSP) - Page3of3
WPFDR07.0200(9/2000)- RCW26.09.260;.270; 26.10.200
SUELLEN HOWARD
ATTORNEY AT LAW
15 SOUTH GRADY WAY, SUITE 400
RENTON. WASHINGTON 98057
(425) 228-8899 Fax: (425) 277-9279
<7 ^
For Petitioner
r~1
For Respondent
RE:
^J> U~eL_
o^u?
k*j
^ f\
>
i
Clerk:
HARROWSCHIESL
DEPUTVCfERK
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, 1
Decem ber 10 20
1
KEVIN S I
COUNTY C
2
3
4
5
6
7
8
THOM AS L V A N D A M
9
P etitioner(s),
10
Order Granting
Adequate Cause
vs.
11
SA R A L V A N D A M
12
R espondent(s)
13
14
15
16
THIS MATTER having come on regularly for hearing to determine if there is adequate cause to
proceed to trial with regard to a Petition which has been filed.
17
18
19
20
21
22
Dated this 10 day o f D ecem ber, 2014
23
24
25
/S /P T C O M H IL L A R Y A N N H O L M E S
PT COM HILLARY ANN HOLMES
Judge/Commissioner
In re:
1.1
1.2
A hearing was held on: does not apply because this order is an agreed order.
II. Findings
The Court Finds:
2.1
Jurisdiction
This court has jurisdiction over the proceeding and the parties.
2.2
O rd re A d e q u a te C au se (O R R A C D , O R RACG , O RH) - P a g e 1 of 2
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 - 100* St. SW#25
Lakewood, WA 98499
253-581-0660
C)
2.3
The nonmoving party was served within the state of Washington and fewer than
20 days have elapsed since the date of service.
3
4
(Jl
2.4
4
&i
2.5
4
9
Q
(M
y
10
tH
11
The parties stipulate there is adequate cause for hearing the petition with respect
to fathers petition and mothers relocation that does not relocate the child. There
is not adequate cause based upon detrimental home environment.
Response
2.6
H
\
eg
III. Order
12
ft is Ordered.
13
14
Time: 9:00 am
Room/Department: TBD
15
16
Dated:
{ssioniBIILLARY HOLM ES
Commissioner Pro Tern
17
18
Approved by:
Notice of'Qres^htation waived:
19
20
21
Daniel N. CockrWSBA#34866
Attorney for Respondent
22
23
24
25
O rd re A d e q u a te C au se (O R R A C D , O R R A C G , O R H ) - P ag e 2 o f 2
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 0 0 th St. SW#25
Lakewood, WA 98499
253-581-0660
\0 1
j
h 2
O
3
4
5
O'1
'.f
iCi 7
8
4 9
^i j 10
No. 07-3-02242-1
Petitioner,
i\j
0 11
H 12
\
N 13
14
15
16
17
18
DECLARATION PURSUANT TO GR 17
'and
(FILING OF E-MAILED SIGNATURE)
SARA L. VAN DAM,
Respondent.
J, Sally DuCharme, declare under penalty of perjury under the laws of the State
of Washington that the following is true to the best of my knowledge.
I am the person responsible for filing of the e-mailed signature page of the
ORDER RE ADEQUATE CAUSE.
I have examined the document and determined that it consists of 3 pages,
19
including this declaration page (but not including attachments), and is a complete and
20
21
22
23
legible image that I have examined personally and that was received by me via e-mail at
[email protected].
Signed at Lakewood, WA on December 9, 2014.
24
25
Declaration Pursuant to GR 17 - Page 1 o f 1
S : \ C A S E S 1 W a n D am \D R A FTS\Pieadings\D eclaratio n re Em ailed Signature.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
<
ro
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is")
. 4*
si
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10
9:~i
12
Petitioner,
13
No. 07-3-02242-1
In re:
11
and
14
SARA L. VAN DAM,
15
Temporary Order
(TMO)
3.1
Respondent
16
17
18
II. Basis
19
A motion for a temporary order was presented to this court and the court finds
reasonable cause to issue the order.
21
22
III. Order
ft is Ordered.
3.1
Restraining Order
The parties shall comply with the Restraining Orders restraining THOMAS VAN
DAM and SARA VAN DAM signed by the court on this date under this cause
number.
Temp O rder (TMO) - Page 1 of 3
WPF DR 04.0250 Mandatory (06/2014) - RCW 26.09.060;. 110; .120; .194, .300(2)
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
1
2
3.2
Surrender of Weapons
Does not apply: There is no surrender of weapon order in effect under this
cause number and the court is not entering one now,
3
4
5
3.3
Temporary Relief
BOTH PARTIES are restrained and enjoined from removing any of the children
from the state of Washington. This provision does not prohibit day trips (e.g., visits
to Oregon), or overnight vacations so long as the vacation is taken with at least 7
days prior notice to the other parent.
6
7
The mother has indicated an intention to relocate to Florida. If the mother relocates
to Florida the child, SILAS VAN DAM, will reside with the Father.
9
10
Pending the mothers relocation to Florida the residential schedule for the child,
SILAS VAN DAM, shall be as follows until further order:
11
11/28 to 12/10 @ 8:00 pm - Silas will be with the Father Thomas Van Dam.
12
13
12/10 @ 8:00 pm to 12/18 - Silas will be with the Mother Sara Van Dam.
14
12/18 to 12/26 - Silas will be with the Father Thomas Van Dam.
15
12/26 to 1/4 - Silas will be with the Mother Sara Van Dam.
16
After January 4, 2015, the parties the child will reside with each parent on
the following schedule:
17
18
19
20
21
All exchanges shall take place curbside. Neither parent shall come onto
the other parents property or enter the other parent's home to exchange
the child.
22
23
24
25
3.4
Bond or Security
Does not apply.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
3.5
Other
2
Does not apply.
3
HILLARY HOLM ES
Commissioner Pro Tem
nt\i
4
5
6
7
Dated:
Judge/^amm issioner
Presented by:
FAUBIONrREEDER. f
COOK, P.S.
Apprc(ved by)
NoticeOf-presentation waived:
DanieTN. Cook'rwSBfr#32ra6
Attorney for Respondent
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
1
3.5
Other
2
Does not apply.
3
4
5
6
7
D a te d :___________________________ _________
______________________________
J u d g e /C o m m is s io n e r
Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.
Approved by:
Notice of presentation waived:
8
9
10
11
12
of this order.
I Q
Thom as Van D^m. Petitioner
13
14
15
16
17
18
19
20
21
22
23
24
25
T e m p O rd e r (T M O ) -
Page 3 o f 3
'
FAUBIO N, REEDER,
. FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, W A 98499
253-581-0660
"
1
E
H 2
O
3
H
V'i
4
5
(fi
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in
6
7
8
9
4
u
10
In re:
THOMAS L. VAN DAM,
11
and
No. 07-3-02242-1
Petitioner,
\
I
CM
Xs
i;\j
13
14
15
16
17
18
DECLARATION PURSUANT TO GR 17
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
of Washington that the following is true to the best of my knowledge.
I am the person responsible for filing of the e-mailed signature page of the
TEMPORARY ORDER.
I have examined the document and determined that it consists of 4 pages,
19
including this declaration page (but not including attachments), and is a complete and
20
21
22
23
legible image that I have examined personally and that was received by me via e-mail at
sducharme(5)fir-law.com.
Signed at Lakewood, WA on December 9, 2014.
24
/
25
Declaration Pursuant to GR 17 - Page 1 of 1
S :\C A S E S 1 W a n D am \D R A FT S \P leadin gs\D eclaration re E m ailed Signature.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253).581-0660
u1
H
O
07-3-02242-1
43775453
TMRO
12-11-14
3
4
(?'
4
in
4
7
8
4
H
O
(M
H
H
t\i
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10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12/31/2020
FAUBION, REEDER,
FRALEY & COOK, P.S.
RestrainingOrder(TRO/RSTO)Page 2 of 4
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0860
1
2
3
4
6
7
8
9
10
11
12
13
Federal law: effective Immediately and continuing as long as this restraining order is
in effect, the restrained person may not possess a firearm or ammunition. 18. U.S.C.
922(g)(8). A violation of this federal firearms law carries a maximum possible
penalty of 10 years in prison and a $250,000 fine. An exception exists for law
enforcement officers and military personnel when carrying department/governmentissue firearms. 18 U.S.C. 925(a)(1).
State law: If mandatory firearm surrender and restrictions under state law apply: It
is unlawful for the restrained person to own, possess, or have under his/her control a
firearm while this order is in effect. A violation is a class C felony.
You Can Be Arrested Even if the Person or Persons Who Obtained the Order
invite or Allow You to Violate the Order's Profi/b/tions. You have the sole
responsibility to avoid or refrain from violating the orders provisions. Only the court
can change the order upon written application.
Pursuant to 18 U.S.C. 2265, a court in any of the 50 states, the District of
Columbia, Puerto Rico, any United States territory, and any tribal land within the
United States shall accord full faith and credit to the order._____________________
Previous Order
[X ]
[]
14
15
16
17
18
There are no prior Restraining Orders restraining the same person issued under
this cause number.
This order replaces all prior Restraining Orders nesfra/ning the same person
issued under this cause number.
19
20
Service
21
[X ]
22
[]
23
24
The restrained party or attorney appeared in court or signed this order; service of
this order is not required.
The restrained party or attorney did not appear in court; service of this order is
required.
The protected party must arrange for service of this order on the restrained party.
File the original Return of Service with the clerk and provide a copy to the law
enforcement agency listed above.
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
2
3
4
&
Approve'Gy:
Dated:
10
11
12
_X
____________________________
Thomas Van Dam, Petitioner
13
14
15
16
17
18
19
20
21
22
23
24
25
RestrainingOrder(TRO/RSTO)Page 4of 4
WPF DR 04.0500Mandatory (O&2014)- RCW26.09.060
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
D a te d :____________________________________
______________________________
J u d g e /C o m m is s io n e r
Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.
Approved by:
Notice of presentation waived:
R e stra in in g O rder(TR O /R S TO ) P a g e 4 o f 4
W P F D R 0 4 .0 5 0 0 M a n d a t o r y ( 0 6 /2 0 1 4 ) - R C W 2 6 .0 9 ,0 6 0
FAUBIO N, REEDER,
. FRALEY & COOK, P.S. '
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
1
2
3
4
5
6
7
8
9
10
11
In re:
THOMAS L. VAN DAM,
No. 07-3-02242-1
Petitioner,
DECLARATION PURSUANT TO GR 17
and
13
14
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
12
15
16
17
18
19
including this declaration page (but not including attachments), and is a complete and
20
legible image that I have examined personally and that was received by me via e-mail at
21
22
23
[email protected].
Signed at Lakewood, WA on December 9, 2014.
24
25
Declaration Pursuant to GR 17 - Page 1 o f 1
S : \ C A S E S 1 W a n D am \D R AFTS\Pteadings\D eclaration re Em ailed Signature.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
*'
CO
in
o
iTi
to
,4-
6
7
No. 07-3-02242-1
In re:
vt
H
(\j
H
H
l\j
Petitioner,
and
10
11
12
Restraining Order
Temporary (TRO)
Final (RSTO)
El
This is E3 a tem porary restraining order the final restraining order signed by the court
pursuant to a decree or final order, on this date.
13
14
15
16
First
Age
N/A
Middle
F
Height
19
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Eyes
Violation o f this Restraining Order with actual notice of its terms is a criminal
offense under Chapter 26.50 RCW and will subject the violator to arrest RCW
26.09.060.
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W eight
17
18
Last
_________________ _______________________________________________
RestrainingOrder(TRO/RSTO)Page 1 o f 4
WPF DR 04.0500 Mandatory (0&2014) - RCW26.09.060
12/31/2020
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW. Ste 25
Lakewood, WA 98499
253-581-0660
c--"f
1
It is Ordered, Adjudged and Decreed.
2
SARA VAN DAM is restrained and enjoined from:
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UT
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j.
v
0
i\]
H
H
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Other restraints:
The protected party o r the protected partys attorney must complete a law
14
enforcement information sheet and provide it with this order before this order
will be entered into the law enforcement computer system .
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Surrender of Weapons
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RestrainingOrder(TRO/RSTO)Page 2 of 4
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0860
1
Federal taw: effective immediately and continuing as long as this restraining order is
in effect, the restrained person may not possess a firearm or ammunition. 18. U.S.C.
922(g)(8) A violation o f this federal firearms law carries a maximum possible
penalty of 10 years in prison and a $250,000 fine. An exception exists for law
enforcem ent officers and military personnel when carrying department/governmentissue firearms. 18 U.S.C. 925(a)(1).
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4
State law: If mandatory firearm surrender and restrictions under state law apply: It
is unlawful for the restrained person to own, possess, or have under his/her control a
firearm while this order is in effect. A violation is a class C felony.
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7
You Can Be Arrested Even if the Person or Persons Who Obtained the Order
Invite or Allow You to Violate the Order's Prohibitions. You have the sole
responsibility to avoid or refrain from violating the orders provisions. Only the court
can change the order upon written application.
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Previous Order
12
[X ]
There are no prior Restraining Orders re s tra in in g the s a m e person issued under
this cause number.
13
[]
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Service
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[X ]
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[]
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The restrained party or attorney appeared in court or signed this order; service o f
this order is not required.
The restrained party or attorney did not appear in court; service of this order is
required.
The protected party m ust arrange for service o f this order on the restrained party.
File the original Return of Service with the clerk and provide a copy to the law
enforcement agency listed above.
25
RestrainingOrder(TRO/RSTO) Page 3 of 4
WPF OR 04.0500 Mandatory (06/2014) - RCW26.09.060
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
1
This order is in effect until the expiration date on page one.
2
3
4
Dated:
luU M
*;La r y h o l m e s
commissioner Pro Xem
mmissioner
Presented by:
EEDER-ERALEY & COOK, P.S.
roved by:
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Restraining Order (TRO/RS TO) Page 4 of 4
WPF DR 04.0500 Mandatory (064014) - RCW26.09.060
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW. Ste 25
Lakewood, WA 98499
253-581-0660
1
This o rd e r is in effect u n tii the expiration date on page one.
2
3
4
D a te d :____________________________________
Judge/Commissioner
______________________________
Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.
Approved by:
Notice of presentation waived:
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R e s t r a in in g O r d e r ( T R O /R S T O ) P a g e 4 o f 4
W P F D R 0 4 .0 5 0 0 M a n d a t o r y ( 0 6 /2 0 1 4 )
- R C W 2 6 .0 9 .0 6 0
FAUBIO N, REEDER,
FRALEY & COOK, P.S.
5920-1 00 th Street SW, Ste 25
Lakew ood, WA 98499
253-581-0660
1
2
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6
7
8
9
10
In re:
THOMAS L. VAN DAM,
11
and
12
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14
15
16
17
18
No. 07-3-02242-1
Petitioner,
DECLARATION PURSUANT TO GR 17
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
of Washington that the following is true to the best of my knowledge.
I am the person responsible for filing of the e-mailed signature page of the
RESTRAINING ORDER.
I have examined the document and determined that it consists of 5 pages,
19
including this declaration page (but not including attachments), and is a complete and
20
21
22
23
legible image that I have examined personally and that was received by me via e-mail at
[email protected].
Signed at Lakewood, WA on December 9, 2014.
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Declaration Pursuant to GR 17 - Page 1 of 1
S : \ C A S E S 1 W a n Dam \D R AFTS\Pleadings\D ectaration re Em ailed Signature.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
07-3-02242-1
43814596
LTR8
12-16-14
SUPERIOR COURT
OF THE
STATE OF WASHINGTON
FOR PIERCE COUNTY
(253) 798-3654
Docket code:
Deadline:
Deadline:
12/17/14
12/17/14
Pursuant to Pierce County Local Rules and also pursuant to the Case Scheduling Order or Order Assigning
Case to Department given to you at the time of filing this case, you are out of compliance. Please take the
actions necessary to immediately comply with the Case Schedule or Order Assigning Case to Department.
Please file and deliver a courtesy copy of the document to the Judge.
If the court finds that an attorney or party has failed to comply with the Case Schedule or Order Assigning
Case to Department and has no reasonable excuse, the court may order the attorney or party to pay
monetary sanctions to the court, or terms to any other party who has incurred expense as a result of the
failure to comply, or both; in addition, the court may impose such other sanctions as justice requires. See
PCLR 3(k) or PCLSPR 94.05(g).
Sincerely,
Daniel N Cook
Suellen Howard
Department 08
Phone#: 253-798-7565
Judicial assistant to:
Judge Brian Tollefson
To:
Superior Court Clerk for Filing
(Court File Copy)
\lxcivit.pbl\d_noncom pliance_letter_report
07-3-02242-1
43840512
LTRSTC
12 -23-14
e r io r
o urt
O F TH E
S
tate o f
for
a s h in g t o n
ie r c e
o unty
VICKI L. HOGAN, JU D G E
AND REW SHANSTRO M , Judicial A ssistant
Departm ent 5, Courtroom 2-E
(253) 798-7566
n L tiu
^
Daniel N Cook
ATTORNEY AT LAW
5920 100th St SW Ste 25
LAKEWOOD, WA 98499-2751
n o p I m court
SUELLEN HOWARD
,
ATTORNEY AT LAW
15 S Grady Way Ste 400
RENTON, WA 98057-3240
Dear Counsel/Litigant:
This is to confirm the following settlement conference:
Case:
Cause No.:
Before:
2.
3.
Please remember that failure to supply the settlement judge with appropriate forms in a timely
manner may result in the imposition of sanctions. For complete information regarding settlement
conferences, please refer to the Pierce County Local Rules.
Sincerely,
ANDREW J. SHANSTROM
Judicial Assistant
CC: Pierce County Clerk for Filing
2 2
2014
07-3*02242-1
43849065
LTR8
12-24-14
SUPERIOR COURT
OF THE
STATE OF WASHINGTON
FOR PIERCE COUNTY
(253) 798-3654
.
DEPT. 8
IN OPEN COURT
Docket code: CRRSP
DEC 2 3 2014
ti
deputy.
Court records indicate that the attorneys and/or parties listed below have failed to comply with the Case
Schedule or Order Assigning Case to Department in regard to the following item:
Certificate of Parenting Class - Respondent's - Not Filed
Deadline:
12/17/14
Pursuant to Pierce County Local Rules and also pursuant to the Case Scheduling Order or Order Assigning
Case to Department given to you at the time of filing this case, you are out of compliance. Please take the
actions necessary to immediately comply with the Case Schedule or Order Assigning Case to Department.
Please file and deliver a courtesy copy of the document to the Judge.
If the court finds that an attorney or party has failed to comply with the Case Schedule or Order Assigning
Case to Department and has no reasonable excuse, the court may order the attorney or party to pay
monetary sanctions to the court, or terms to any other party who has incurred expense as a result of the
failure to comply, or both; in addition, the court may impose such other sanctions as justice requires. See
PCLR 3(k) or PCLSPR 94.05(g).
Copies mailed to:
Daniel N Cook
Suellen Howard
Phone #: 253-798-7565
Judicial assistant to:
Judge Brian Tollefson
\lxcivit.pbl\d_noncompliancejetter_report
E-FILED
IN COUNTY CLERK'S OF
PIERCE COUNTY, W ASHII
February 03 2015 3:35
KEVIN STO CK
COUNTY CLERF
NO: 07-3-02242-
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14
No. 07-3-02242-1
In re:
THOMAS L. VAN DAM,
Petitioner,
and
(MTAF)
15
16
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20
Based on the declaration below, the undersigned moves the court for a temporary order
which:
Orders child support pursuant to the Washington State Support Schedule.
Requires the parents to use Our Family Wizard for all future communications
regarding the child.
21
Requires all future travel for visitation between Silas with the mother be scheduled
to not cause Silas to miss any school.
22
Except as added to by this motion, confirms and maintains the Temporary Order
23
and mutual Restraining Orders entered on December 10, 2014. This motion is based
24
upon the following declaration and the records pleadings and file herein.
25
Mtn/Decl for Temp Ord (MTAF) - Page 1 of 7
WPF DR 04.0100 M andatory (06/2014) - R CW 26.09.060;. 110;. 120;. 194
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
1
2
DATED this
4
Daniel N. Cook, \A
Attorney for Petitioner
5
6
II. Declaration
7
I, TOM VAN DAM, and the Petitioner in this matter. I am over the age of 18 and I
8
9
10
11
SARA VAN DAM and I were formerly married. We had one child together, SILAS,
12
who is now 12 years old. SARA and I dissolved our marriage in 2007 when SILAS was
13
only 4 years old. In the seven years since we first established the parenting plan, many
14
things have changed, including work schedules for both parties, residences for both
15
16
17
18
For these and other reasons, SARA and I are no longer following the 2007
parenting plan. We have substantially deviated from the parenting plan for a long time
and I am now asking the court to enter a formal parenting plan reflecting the changes we
19
have agreed upon and implemented.
20
21
22
Since asking the court to modify the parenting plan SARA indicated she would be
relocating to Florida but leaving SILAS here with me.
23
entered an Agreed Temporary Order outlining a schedule for the holidays and before her
24
relocation to Florida and confirming SILAS would remain here after her departure.
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Mtn/Decl for Temp Ord (MTAF) - Page 2 of 7
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone:(253) 581-0660
1
I also asked the court to enter a restraining order and mutual restraining orders
2
preventing both parties from entering the home of the other party were entered on
3
4
5
December 10, 2014. There have been two incidents when SARA has come to my house
and acted very inappropriately. She has been hostile, belligerent, rude and frankly a little
scary. Certainly it has traumatized the children in my home. SARA and I generally get
along well and are fairly cooperative but certain topics (mostly financial) are very
triggering for SARA and if I do not do what she wants financially she will sometimes erupt
10
upsetting my wife and children I asked the court to enter a restraining order as well as
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12
13
SARA and I have been generally cooperative and able to reach agreement on the
14
major aspects of our parenting plan, for example, the residential schedule. However,
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SARA has also been very unpredictable and explosively angry when discussing other
issues, primarily financial ones. For example, when she asks for money for a school
18
expense if I suggest that I should pay the school the amount she suggested she gets
19
angry, rude, belligerent and even hostile. SARA has cursed me and my current wife out
20
many times. SARA has called me and my spouse foul names. SARA has sent me
21
harassing texts when she has not gotten her way. I incorporate herein by reference my
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Mtn/Decl for Temp Ord (MTAF) - Page 3 of 7
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
1
mediated prior to her relocation to Florida. We agreed she would go to Florida and leave
2
SILAS with me and generally outlined the visits SILAS would have with her. Drafting the
3
4
paperwork would be left up to the attorneys. But the one issue I was very emphatic about
was that SILAS not miss school for visits to Florida. We talked about a visit during mid
winter break and I wholeheartedly agreed SILAS could come with a strong caveat that he
not miss any school for the visit. In mediation and in subsequent telephone calls SARA
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12
Then after SARA went to Florida and started scheduling the mid-winter vacation
visit she asked me if he could miss a day of school for the visit. I said no because I had
already indicated this was a priority issue for me and she agreed to it.
SILAS already has five absences this year all on times he was scheduled to be
13
with SARA. The simple fact is SARA does not believe school attendance is a priority.
14
SARA takes the position that SILAS can always just make up a day and that missing
15
16
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school is not a big deal. Perhaps in isolation it is not, but when SARA repeatedly does it
many times during the course of the school year it has a negative impact on him.
In addition, SARA does not check schedules or plans with the school in advance,
19
to see what SILAS is doing that day or if there is something important he would miss.
20
She just keeps it out of school when it suits her needs without really considering the
21
impact on SILAS. That is one reason I was so insistent that SILAS not miss school to
22
visit Florida.
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I appreciate that SARA is not trying to uproot SILAS and move him across the
country because she wishes to move to Florida. SARA should also consider the
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Mtn/Decl for Temp Ord (MTAF) - Page 4 of 7
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
1
ramifications of keeping SILAS out of school just because it is better for her (apparently
2
3
4
5
the flight was significantly cheaper if he missed school than if she sent him back as we
originally agreed).
Since SARA did not abide by our agreement to not have SILAS miss school for
visitation in Florida I am asking the court to enter an order to that effect at this time. I
never refused to send SILAS to Florida - I only insisted that SARA ensure he had a ticket
to return prior to school starting. Then SARAs attorney threatened to go to court for an
emergency order because I was not complying with our agreement to send SILAS.
10
Nothing could be further from the truth. I fail to see how SARAs lack of planning and
11
12
then dealing with it at the last minute creates an emergency. Furthermore, it was SARA
who did not comply with our agreement not me. But in any event, what is done is done
13
for now but I do not want to set a precedent that SARA can just unilaterally schedule visits
14
whenever she wants without regard to SILAS school schedule or our agreements and
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then expect SILAS and my family and me to all accommodate what is best for her. The
court needs to make it clear that conduct such a this will not be tolerated in the future.
IN ADDITION TO THE RESTRAINTS PREVENTING EITHER PARTY FROM COMING
TO THE HOME OF THE OTHER THE PARENTS SHOULD BE REQUIRED TO USE
OUR FAMILY WIZARD FOR ALL COMMUNICATIONS REGARDING SILAS
20
21
requested. As noted above, SARA agreed to not have SILAS miss school then failed to
22
follow through. I want future agreements in writing so would like to use Our Family
23
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Wizard to confirm. In addition, during this process SARA claims I am refusing to let
SILAS go. That is not the case, I never refused to let SILAS go - 1always just insisted
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Mtn/Decl for Temp Ord (MTAF) - Page 5 of 7
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone:(253)581-0660
1
her return before school started again like we agreed. At one point we were talking on
2
the phone when I insisted that SILAS come home before school resumed instead of
3
4
5
missing school as she insisted SARA hung up on me. Later she tried to call and I
declined to answer because I did not want to have a pointless conversation. Then she
texted me and asked me to call her and I texted her back and said I would prefer to
communicate in writing and did not want to be hung up on. She refused to communicate
9
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13
19
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information and belief I believe she was making about $60,000 per year. I have imputed
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I am proposing a transfer payment of $489 per month with a 65/35 percent split of
income. I am asking for the effective date to be February 2015 because SARA paid
100% of the round trip airline ticket in January 2014 for SILAS to visit her this winter.
25
Mtn/Decl for Temp Ord (MTAF) - Page 6 of 7
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
CONCLUSION
2
3
4
Based upon ali of the forgoing, I am asking the court to order all future visits be
scheduled so as to avoid SILAS missing any school, for SARA and I to only communicate
through Our Family Wizard unless there is an emergency and for the court to set child
j (state) iA/P
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Mtn/Decl for Temp Ord (MTAF) - Page 7 of 7
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
1
2
3
4
5
6
7
10
11
12
13
14
15
16
17
18
In re:
THOMAS L. VAN DAM,
No. 07-3-02242-1
Petitioner,
DECLARATION PURSUANT TO GR 17
and
(FILING OF E-MAILED SIGNATURE)
SARA L. VAN DAM,
Respondent.
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
of Washington that the following is true to the best of my knowledge.
I am the person responsible for filing of the e-mailed signature page of the
MOTION AND DECLARTION FOR TEMPORARY ORDER.
I have examined the document and determined that it consists of 8 pages,
19
including this declaration page (but not including attachments), and is a complete and
20
21
22
23
legible image that I have examined personally and that was received by me via e-mail at
[email protected].
Signed at Lakewood, WA on February 3, 2015.
24
25
Declaration Pursuant to GR 17 - Page 1 of 1
S :\C A S E S 1 W a n D am \D R A F T S \P lead in g s\D eclaratio n re E m ailed Signature.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
February 03 2015 3:35 PM
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
$488.90
$924.10
I $1,197.00
$924.10
$488.90
Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
Mother
Father
_
_
$924.10 |
$488.90
'
$924.10
$488.90
$3,266.41
$1,728.95
$231.03
$122.23
Father's
Household
Mother's
Household
"
Name/age:
Paid [ ] Yes [ ] No
Name/age:
Paid [ ] Yes [ ] No
Name/aqe:
Paid f l Yes [ l No
25. Other Child(ren) Living In Each Household
(First name(s) and age(s))
26.
Mother's
Household
-
Father's
Household
Judidal/Reviewing Officer
Date
W orksheet certified by the State of W ashington Adm inistrative Office of the Courts.
Photocopying of the worksheet is permitted.
WSCSS-Worksheets - M andatory (CSW/CSWP) 07/2013 Page 5 o f S
SupportCafc 2014
c:\program Hes\lega)plus\state lemp/stesWawcrtaheetdtf m:\scdiaWandam\vandsm.sop 02/02/2015 <M:20 pm
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4
5
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7
8
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12
13
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17
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In re:
THOMAS L. VAN DAM,
No. 07-3-02242-1
Petitioner,
DECLARATION PURSUANT TO GR 17
and
(FILING OF E-MAILED SIGNATURE)
SARA L. VAN DAM,
______________________R e s p o n d e n t . _______________________________________
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
of Washington that the following is true to the best of my knowledge.
I am the person responsible for filing of the e-mailed signature page of the CHILD
SUPPORT WORKSHEETS.
I have examined the document and determined that it consists of 6 pages,
19
including this declaration page (but not including attachments), and is a complete and
20
21
22
23
legible image that I have examined personally and that was received by me via e-mail at
[email protected].
Signed at Lakewood, WA on February 3, 2015.
24
25
Declaration Pursuant to GR 17 - Page 1 o f 1
S :\C A S E S 1 W a n D am \D R A F T S \P lead in g s\D eclaratio n re E m a iled Signature.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
February 03 2015 3:35 PM
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
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
DATED:
February 3, 2015.
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#: 34866
For:
Attorney for Plaintiff/Petitioner
1 of
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHING!
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
3
4
5
6
7
8
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF PIERCE
10
In re:
No. 07-3-02242-1
11
12
13
14
Petitioner,
and
SARA L. VAN DAM,
Respondent.
15
16
17
18
19
20
21
22
23
24
25
Cover Page - Page 1 o f 1
Van Dam, Tom and Van Dam, Sara
S :\C A S E S 1 W a n D a m \D R A F T S \P le a d in g s \C o v e r P ag e.do c
FAUBION, REEDER,
FRALEY & COOK P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
A ttorneys
at
L aw
N icole C. B, H ancock
P eter D, H aroldson
February 2, 2015
Suellen Howard
15 S Grady Way Ste 400
Renton, WA 98057-3240
RE:
T o m Van D am , client
P ierce C o u n ty C a u s e N o .0 7 -3 -0 2 2 4 2 -1 C ourt file
E-FILE
IN COUNTY CLE RK'S OFFICE
PIERCE COUNTY WASHINGTON
February 17 2015 8:30 AM
KEVIN S O C K
COUNTY CLERK
NO: 07-3-102242-1
I agreed to a temporary order that included restraints back in December and I no not understand
why the petitioner is asking the court to order another one.
I agree to use Our Family Wizard for communications. I find that the petitioner either fails to
return calls or is abusive to me when he is on the phone and I welcome some other form of
ATTORNEY AT LAW
15 SOUTH GRADY WAY, SUITE 400
RENTON, WASHINGTON 98057
(425)228-8899 Fax: (425) 277-9279
3
4
Although we already have a temporary restraining order, the petitioner wants to put before the
court the on gong problems that we have had. Since the separation and then divorce from the
petitioner, I have been scared of the petitioner and his controlling ways. He uses intimidation and
passive aggression to get what he wants . I have been a single mon and working hard to support
9
10
Our 2007 parenting plan provided for shared time and the petitioner only paid $150 in support
11
although there is a big disparity between our incomes. The petitioner decided if expenses should
12
come our of the $150. I only asked him to pay for things for Silas when I had no other recourse
13
14
15
Last year there were two incidents that increased my anxiety and fear. I was physically hurt by the
16
petitioner in front of our son. I was once again trying to ask the petitioner for money that was due
17
but which he was refusing to pay. After he slammed the door in my face in front of Silas I went
18
to the side door to check that Silas was all right. The petitioner threw me into a comer and
19
knocked the wind out of me and I was unable to breathe. He then continued to throw me at the
20
door and my sunglasses, rings and earrings all were thrown off during this. I was crawling on the
21
garage floor grasping for air. When I caught my breath I asked to see Silas because I could hear
22
him crying. The petitioner refused and demanded that 1 leave. I went to a friends house shaking
23
24
25
26
SUELLEN HOWARD
27
Declaration
28
ATTORNEY AT LAW
15 SOUTH GRADY WAY, SUITE 400
RENTON. WASHINGTON 98057
(425) 228-8899 Fax: (425) 277-9279
On another occasion the petitioner tried to physically stop my car when I was trying to drop off
My choice to relocate to Florida was a hard one. I would love to have Silas with me full time and
come with me to Florida. 1 have chosen to have him stay in school in Washington. My decision
to move to Florida has a lot to do with the harassment and passive aggressive, controlling
behavior of the petitioner than I have had to deal with for over 8 years now.
8
9
We reached a written agreement on some aspects of my move to Florida. The agreement was not
10
final because our attorneys had to agree also. 1have attached the agreement to show that I agreed
11
not to interfere with Silas school if 1 visit him in Washington, but that provision does not appear
12
with the visitation in Florida. 1 do not intend to have Silas miss school to visit me, but sometimes
13
the travel arrangements are easier as to the times or far less expensive if Silas travels on a school
14
day. The times that this would even be considered are a few times a year. I am asking the court
15
not to impose that restriction on the travel times. Silas is a very good student and I have always
16
worked closely with his teachers. Silas can easily make up any work that he might miss or do it in
17
advance.
18
19
Silas has been through a lot of changes the past three years. Several important family members
20
have died, his father has remarried and he has step sisters, and now I have moved. I want to spend
21
as much time with him as I can and I want him to see me happy and not anxious and fearful. I am
22
asking the court not to put monetary restraints on the visitation that could make it happen less
23
24
25
26
SUELLEN HOWARD
27
Declaration
28
ATTORNEY AT LAW
15 SOUTH GRADY WAY, SUITE 400
RENTON, WASHINGTON 98057
(425) 228-8899 Fax: (425) 277-9279
Child Support
1am a dental assistant. When I worked in Washington I made $30 an hour. Dental office are not
open 40 hours a week and I averaged 32 or 33 hours a week which is standard in the industry.
5
6
At present, I am unemployed and living with my boyfriend. To meet my expenses, I used money
form my tax refund and my mother has helped me. I am looking for work in my field. Here in
Escambia County dental assistants earn between $10 and $15 an hour. I have applied for many
positions and have had two working interviews. The pay for each of those two jobs was $10. The
10
office hours are the same as in Washington, full time is considered $32-36 hours a week.
11
12
I have prepared a worksheet based on 34 hours a week and $12.50 an hour which is the average
13
of the going rate and available hours. Since this is a temporary order, it can be adjusted when I am
14
employed. For the petitioner, I used the one pay check that he provided.
15
16
The petitioner did not pay his child support to me in November and December last year and owes
17
$300. I am asking for an equitable offset of $300 against my child support payment for the first
18
moths.
19
20
21
22
23
24
25
26
SUELLEN HOWARD
27
Declaration
28
ATTORNEY AT LAW
! 5 SOUTH GRADY WAY, SUITE 400
RENTON, WASHINGTON 98057
(425) 228-8899 Fax: (425) 277-9279
I declare under penalty of peij ury under the Jaws c f die State of Washington that the foregoing is
true and correct
Signed at
_on _ Z A / _
SUELLEN HOWARD
ATTORNfcYA.TLAW
15SOUTHCRADYWAY. SUITEAOO
RENTON, WASHINGTON 98057
(42Jj 22 3-S899 Fa*: I42SY277-927S
D eclaration
I'd
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SETTLEMENT AGREEMENT
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mediated
on l l l i e L p f . .
and concluded that the following terms are a fair and reasonable
settlement of our dispute.
1. We agree and intend that the following agreement is a legally binding and
enforceable CR2a settlement contract
initials^_____ /_______
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Settlement
Pagejcf
Initials
Date:
MEDIATOR
Date: J j j g f j ( i f _
j &
<
&
'
MEDIATOR
800/800'd
8000'N
S I M3-]
M0jpuy J |]
6s:oi u m / n o z
Mother:
Sara
Father: Thomas
County:
PIERCE
Case No.:
(CSWP)
07-02242-1
F. If applicable: [ ] All health care, day care and special child rearing expenses are included in the
Worksheets in Part 111.___________________________________________________________________
Worksheets
Child(ren) and Age(s): Silas, 12
P arti: Income (see Instructions, page 6)
1. Gross Monthly Income
a. Wages and Salaries
b. Interest and Dividend Income
c. Business Income
d. Maintenance Received
e. Other Income
f. Imputed Income
g.Total Gross Monthly Income (add lines 1a through 1f)
2. Monthly Deductions from Gross Income
Father
$9,507.00
Mother
$1,841.00
$9,507.00
$1,841.00
$1,098.80
$724.34
$6.30
$136.67
$140.84
$416.67
$277.51
$2,246.11
$1,563.49
$7,260.89
$8,824.38
$1,467.00
.823
.177
$1,207.34
$259.66
I $1,128.00
$1,207.34
$259.66
Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
Mother
Father
$1,207.34 [
$259.66
$1,207.34
$259.66
$3,267.40
$703.57
$301.83
$64.92
21 Household Debt
(List liens against household assets, extraordinary debt.)
a.
b.
c.
d.
e.
f.
22. Other Household Income
a. Income Of Current Spouse or Domestic Partner
(if not the other parent of this action)
Name
Name
b. Income Of Other Adults in Household
Name
Name
c. Gross Income from overtime or from second jobs the party
is asking the court to exclude per Instructions, page 10
Father's
Household
Mother's
Household
Name/age:
_ ........................
Paid [ ] Yes U No
Name/age:
Paid 1j Yes 1] No
Name/aqe:
Paid [JYes n No
25. Other Child(ren) Living In Each Household
(First name(S) and age(s))
Father's
Household
....... __
7
Mothers
Household
- .....
Father's Signature
City
Judicial/reviewing Officer
Date
City
Date
c \slate ter-aa:esW3^ornsrieeti' c ip'09-am flesvegalpuf.an dan, sar,ri flam sara .sco Q2/16/2D151214 pm
Z-d
fr686Z6f 0S8
0jn|osey ||eA\pug
dSZ:0OSl 91 qed
E-FILED
IN COUNTY CLE RK'S OFFICE
PIERCE CO UNTY W ASHING TO N
February 17 20 15 8:30 AM
1
KEVIN S TO C K
COUNTY LERK
NO: 07-3-102242-1
3
4
5
6
7 SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
8
In re:
9
NO. 07-3-02242-1
Petitioner,
10
and
FINANCIAL DECLARATION
PETITTONER/RESPONDENT
(FNDCLR)
11
Sara L. Van Dam
12
Respondent.
13
14 Name: Sara Van Dam
15
16
17
18
$-0-
S 1227
21
S9500.
Estimate of the other partys gross monthly income (from 3.1 f below)
22
23
24
25
26
27
28
FINANCIAL DECLARATION
WPF DR 01.0550 (2/97)
RCW 26.18.220(1)
Page 1
Suellen Howard
Attorney at Law
15 South Grady Way, Suite 400
Renton, WA 98057
425-228-8899 phone *425-277-9279 fax
2 2.1
3 2.2
4
2.3
5
a. If yes:
(l)
(2)
7
8
If child support is at issue, complete the Washington State Child Support Worksheet(s), skip Paragraphs
10 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 partys income information is optional.)
11
3.1
GROSS MONTHLY INCOME.
12
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.
13
If you are paid twice monthly, multiply your gross pay by 2. If you are paid once a month, list
14
that amount below.
Petitioner
15
a.
Wages and Salaries
$
16
b.
c.
Business Income
d.
19
e.
Other Income
20
f.
21
g.
17
18
(L&I)
$
$
22
23
24
25
26
27
FINANCIAL DECLARATION
WPF DR 01.0550 (2/97)
28
RCW 26.18.220(1)
Page 2
Suellen Howard
Attorney at Law
15 South Grady Way, Suite 400
Renton, WA 98057
425-228-8899 phone *425-277-9279 fax
I 3.2
a.
Income Taxes
b.
FICA/Self-employment Taxes
c.
d.
e.
f.
g.
h.
5
6
7
8
9
10 3.3
II
12
3.4
13
14
MISCELLANEOUS INCOME.
a.
b.
c.
15
16 3.5
17 3.6
If the income of either party is disputed, state monthly income you believe is correct and explain
below:
18
Sunknown
19
4.1
Cash on hand
4.2
On deposit in banks
4.3
4.4
20
21
22
23
24
25
26
27
28
FINANCIAL DECLARATION
WPF DR 01.0550 (2/97)
RCW 26.18.220(1)
Page 3
Suellen Howard
Attorney at Law
15 South Grady Way, Suite 400
Renton, WA 98057
425-228-8899 phone *425-277-9279 fax
2 Monthly expenses for myself and__ dependents are: (Expenses should be calculated for the future,
after separation, based on the anticipated residential schedule for the children.)
3
4 '5.1
i;
5
:!
6I
$
$
Total Housing
8 5.2
UTILITIES.
10
Electricity
11
Telephone
Cable
$150
$140
Total Utilities
$290
12
13
HOUSING.
14
15
i
i,5.3
16
'I
17
18
19
20
21 5.4
22
23
24
25
$300
$
$
Other
Total Food Supplies
$
$
CHILDREN.
Day Care/Babysitting
Clothing
Tuition (if any)
Other child related expenses will be contribution to activities and
and air travel
26
27
28
FINANCIAL DECLARATION
WPF DR 01.0550 (2/97)
RCW 26.18.220(1)
Page 4
$
$
$
$
Suellen Howard
Attorney at Law
15 South Grady Way, Suite 400
Renton, WA 98057
425-228-8899 phone *425-277-9279 fax
TRANSPORTATION.
$397
$240
Parking
Other transportation expenses: AAA
Total Transportation
$
$
$637
4
5
6
10
Insurance: Premium
Other uninsured health expenses
Total Health Care
11
12
13 5.7
$
$
$
$
S
S
$
$
19
$
$
$
$
20 5.8
MISCELLANEOUS EXPENSES.
21
$
$
$
$
14
15
16
17
18
22
23
24
5.9
25
26
27
FINANCIAL DECLARATION
WPF DR 01.0550(2/97)
28
Page 5
RCW 26.18.220(1)
Suellen Howard
Attorney at Law
15 South Grady Way, Suite 400
Renton, WA 98057
425-228-8899 phone *425-277-9279 fax
1
2 5.10
3
4
Creditor
Description
of Debt
Balance
Month of
Last Payment
5
6
5.11
THROUGH 5.8.
7
8
9
Creditor
Description
of Debt
Balance
LastPayment
medical bills
3,800
$200.
10
11
12
13
14
5.12
15
16
17
18
19
20
6.1
6.2
6.3
6.4
6.5
$1000.00
$2000.00
21
22
23
24
25
26
27
28
FINANCIAL DECLARATION
WPF DR 01.0550(2/97)
RCW 26.18.220(1)
Page 6
Suellen Howard
Attorney at Law
15 South Grady Way, Suite 400
Renton, WA 98057
425-228-8899 phone *425-277-9279 fax
I declare under penalty of perjury under the laws of the State of Washington that the foregoing is
true and correct
Signed at
SUELLEN HOWARD
Y i n U<asaX
Declaration
fd
fr68516P OS8
ATTORNEY AT LAW
15 SOUTH GRADY WAY. SUfTEAOO
RENTON. WASHINGTON' 9S057
(425) EW S59 F : 1425) 277-W27y
e}n|osey ||0w\puQ
d22:eOS19iqed
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
February 18 2015 9:59 AM
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
$597.47
$1,149.53
I $1,226.00
.
.
$1,149.53
$597.47
Part III: Health Care, Day Care, and Special C hild Rearing Expenses (see Instructions, page 8)
M other
Father
.
_
$1,149.53 I
$597.47
$1,149.53
$597.47
$3,274.81
$1,699.23
$287.38
$149.37
Mother's
Household
Father's
Household
a. Real Estate
b. Investments
c. Vehicles and Boats
d.Bank Accounts and Cash
e. Retirement Accounts
f. Other: (describe)
$3,500.00
$280.00
26.
Father's
Household
Mother's
Household
Judiciat/Reviewing Officer
Date
S u p p o rt Ca/c 2015
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
In re:
THOMAS L. VAN DAM,
No. 07-3-02242-1
Petitioner,
DECLARATION PURSUANT TO GR 17
and
(FILING OF E-MAILED SIGNATURE)
SARA L. VAN DAM,
Respondent.
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
of Washington that the following is true to the best of my knowledge.
I am the person responsible for filing of the e-mailed signature page of the CHILD
SUPPORT WORKSHEETS.
I have examined the document and determined that it consists of 6 pages,
19
including this declaration page (but not including attachments), and is a complete and
20
21
22
23
legible image that I have examined personally and that was received by me via e-mail at
[email protected].
Signed at Lakewood, WA on February 18, 2015.
yJ_____
""Sally DuCnarme, Legal Assistant
24
25
Declaration Pursuant to GR 17 - Page 1 o f 1
FAUBION, REEDER,
FRALEY & COOK, P.S.
E-FILED
IN COUNTY CLERK'S OF
PIERCE COUNTY, WASHIN
February 18 2015 9:59 A
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242' 1
2
3
4
5
6
7
8
9
Petitioner,
Financial Declaration
[X] Petitioner
[ Respondent
(FNDCLR)
And
10
SARA VAN DAM VAN DAM
Respondent.
11
12
Date of Birth:
13
14
15
10/21/1969
[X]
[ ]
16
$7,277.36
$8,950.00
$820.00
$9,770.00
$4,399.20
Unknown
17
2.1
Occupation: Engineer
18
2.2
2.3
19
3 years of college
20
21
b.
If no:
22
23
24
25
FAUBION, REEDER,
FRALEY & COOK, PS
5920 100th Street SW, #25
Lakewood, WA 98499
(253) 581-0660
SupportCa/c/FD 2015
1
III.
2
3
4
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.)
5
3.1
6
7
8
9
10
11
12
13
14
15
16
17
18
19
a.
b.
c.
d.
e.
f.
9h.
Income Taxes
FICA/Self-employment Taxes
State Industrial Insurance Deductions
Mandatory Union/Professional Dues
Pension Plan Payments
Spousal Maintenance Paid
Normal Business Expenses
$1,080.13
$727.34
$6.30
$2,230.44
$623.14
$7,277.36
$3,776.06
$416.67
20
21
22
23
24
25
Financial Declaration (FNDCLR) - Page 2 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)
FAUBION, REEDER,
FRALEY & COOK, PS
5920 100th Street SW, #25
Lakewood, WA 98499
(253) 581-0660
SupportCa/c/FD 201S
1
2
3
4
3.4
Thomas Dam
Miscellaneous Income
a.
Child support received
relationships
Name: Stephanie VanDam
Name:
b.
Other miscellaneous income
from
other
$280.00
6
7
8
9
10
11
$3,500.00
12
c.
13
14
$3,780.00
3.5
15
16
3.6
If the income of either party is disputed, state monthly income you believe is correct and
explain below:
4.1
4.2
4.3
Cash on hand
On deposit in banks
Stocks and bonds
Cash value of life insurance
Other liquid assets:
17
IV. Available Assets
18
19
20
21
22
4.4
23
24
25
Housing
Rent, 1st mortgage or contract payments
Installment payments for other mortgages or
encumbrances
Taxes & insurance (if not in monthly payment)
Total Housing
SupportCa/c/FD 2015
$1,250.00
$1,250.00
FAUBION, REEDER,
FRALEY & COOK, PS
5920 100th Street SW, #25
Lakewood, WA 98499
(253) 581-0660
1
5.2
2
3
4
Utilities
Heat (gas & oil)
Electricity
Water, sewer, garbage
Telephone (includes several lines plus insurance)
Cable (includes cable and high-speed internet)
Other: ADT (home security system)
$125.00
$125.00
$200.00
$300.00
$ 112.00
$49.00
Total Utilities
$911.00
5
6
5.3
7
8
9
5.4
5.5
14
15
Transportation
Vehicle payments or leases (two vehicles)
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
Parking
Other transportation expenses
Total Transportation
5.6
17
18
20
21
22
23
$1,675.00
Children
Day Care/Babysitting
Clothing
Tuition (if any) (post-secondary assistance for older child of Stephanie VanDam)
Other child-related expenses (sports and extra-curricular for Silas and younger child
13
19
$75.00
$400.00
$250.00
$400.00
$135.00
of Stephanie VanDam)
12
16
$1,200.00
10
11
5.7
$785.00
$830.00
$246.00
$500.00
$30.00
$1,606.00
$30.00
$40.00
$70.00
$300.00
$150.00
$280.00
$300.00
$9.00
$300.00
$417.00
$1,756.00
24
25
Financial Declaration (FNDCLR) - Page 4 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)
FAUBION, REEDER,
FRALEY & COOK, PS
5920 100th Street SW, #25
Lakewood, WA 98499
(253) 581-0660
SupportCa/c/FD 2015
1
2
5.8
3
4
5
6
7
5.9
Miscellaneous Expenses
Life insurance (if not deducted from income)
Other: World Vision (support 3 children in 3rd world countries)
Other: Redemption Bible Church (tithe)
Total Miscellaneous Expenses
$72.00
$105.00
$720.00
$897.00
$8,950.00
5.10
Installment Debts Included in Paragraphs 5.1 Through 5.8
Creditor/Description of Debt
Balance
Wells Fargo (home
$195,000.00
mortgage)
Toyota Finance
$12,000.00
Honda Financial
$7,000.00
10
11
12
13
14
15
5.11
Other Debts and Monthly Expenses not Included in Paragraphs 5.1 - 5.8
Amount of
Month of
Last Pavment
Monthlv Pavm
Creditor/Description of Debt
Balance
$50.00
January
$1,200.00
Wells Fargo (credit card)
$300.00
January
$5,800.00
USAA (credit card)
$35.00
January
$200.00
JCPenny (credit card)
$75.00
February
$2,000.00
Chase (credit card)
$360.00
February
$12,000.00
Key Bank (consolidation
loan)
16
17
18
19
20
21
22
23
24
25
Financial Declaration (FNDCLR) - Page 5 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)
SupportCa/c/FD 2015
FAUBION, REEDER,
FRALEY & COOK, PS
5920 100th Street SW, #25
Lakewood, WA 98499
(253) 581-0660
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5.12
$820.00
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6.1
6.2
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Other:
$9,770.00
$2 ,9 5 0,00
$5,515.00
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I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
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Signed at
K u -V rg y
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/>
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[City] ( / - / f t '
[State]
[Date].
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The following financial records are being provided to the other party and filed separately with the court.
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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 all parties In the
case, their attorneys, court personnel and certain state agencies and boards.) See GR 22 (c)(2).
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Financial Declaration (FNDCLR) - Page 6 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220 (1)
FAUBION, REEDER,
FRALEY & COOK, PS
5920 100th Street SW, #25
Lakewood, WA 98499
(253) 581-0660
SupportCatoTO2015
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In re:
THOMAS L. VAN DAM,
No. 07-3-02242-1
Petitioner,
DECLARATION PURSUANT TO GR 17
and
(FILING OF E-MAILED SIGNATURE)
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I, Sally DuCharme, declare under penalty of perjury under the laws of the State
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including this declaration page (but not including attachments), and is a complete and
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legible image that I have examined personally and that was received by me via e-mail at
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[email protected].
Signed at Lakewood, WAon February 18, 2015.
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D e c la r a t io n P u r s u a n t t o G R 1 7 - P a g e 1 o f 1
S : \ C A S E S 1 W a n D a m \D R A F T S\Plea d ings\D ecla ra tion re Em ailed Signature.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
February 19 2015 10:45 AM
KEVIN STO CK
COUNTY CLERK
NO: 07-3-02242-1
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
DATED:
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#: 34866
For:
Attorney for Plaintiff/Petitioner
1 of