Professional Documents
Culture Documents
Jennifer Kay Shipman vs. Jason William Shipman
Jennifer Kay Shipman vs. Jason William Shipman
NO: 10-3-00961-1
Atty/Litigant_____________________________
Bar # 28960
State WA
Zip 98 373
Please check one category that best describes this case for indexing purposes.
I f you cannot determine the appropriate category, please describe the cause o f action below. This will create a
Miscellaneous cause which is not subject to PCLR1, and does not require a Track Assignment Request Form.
DOMESTIC RELATIONS
ADOPTION / PATERNITY
DISSOLUTION
_f__ Of Marriage with Child (DIC 3) FAM LAW
___ Of Marriage without Child (DIN 3) FAM LAW
___ Of Domestic Partnrshp w Child (DPC 3)FAM LAW
___ Of Domestic Prtnrshp w/o Child (DPN3)FAM LAW
LEGAL SEPARATION
___ Of Marriage with Children (LSC 3) FAM LAW
___ Of Marriage without Children (LsN 3)FAM LAW
___ Of Domestic Partnership w Child (SPDC 3)FAM LAW
___ Of Domestic Prtnrshp w/o Child (SPD 3)FAM LAW
DOMESTIC RELATIONS
___
___
___
___
___
___
MISCELLANEOUS
PROBATE / GUARDIANSHIP
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
March 15 2010 3:08 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
No. 10-3-00961-1
Petitioner(s)
ORDER ASSIGNING CASE TO DEPARTMENT
vs.
Notice to Petitioner:
Once the case has been filed, the petitioner shall serve a copy of this Order Assigning Case to Department on the
respondent with the summons and petition. Provided, however, that in those cases where service is by
publication the petitioner shall serve a copy of this Order Assigning Case to Department within five (5) court days
of service of the respondent's first response/appearance. If the case has not been filed, but an initial pleading is
served, a copy of this Order Assigning Case to Department shall be served within five (5) court days of filing.
PCLR 1(b).
Trial Date:
A trial date may be obtained pursuant to PCLR 40(d) by filing a 'Note of Issue' for assignment of a trial date by
noon at least six (6) court days prior to the date fixed for assignment of the trial date. PCLR 40(d)
If a trial date is not obtained pursuant to PCLR 40(d), failure to appear on this date will result in dismissal of
the case by the Court. PCLR 40(d)
Assignment to Set Trial Date
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 05/17/2010. See
PCLSPR 94.05(c) & (4)(i). http:\\wwwxo.pierce.wa.us\pc\services\lawjust\parentingseminars.htm
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.
E-FILE
IN COUNTY CLEI
PIERCE COUNTY
March 15 201(
KEVIN ST
COUNTY C
NO: 10-3-C
2
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6
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8
In re the Marriage of:
9
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No.
JENNIFER KAY SHIPMAN
Petitioner,
and
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I. Basis
1.1
Identification of Petitioner
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.2
Identification of Respondent
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.3
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The husband and wife are both the parents of the following dependent children:
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Name: TS
Age 15
and
Name: HS
Age 8
1.4
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3
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5
1.6
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Separation
Husband and wife separated on February 27, 2010.
1.7
Jurisdiction
This court has jurisdiction over the marriage.
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10
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The petitioner and respondent may have conceived a child while within
Washington.
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1.8
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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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The division of property should be determined by the court at a later date.
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1.9
18
The parties have debts and liabilities. The court should make a fair and equitable
division of all debts and liabilities.
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/
//
PETITION FOR DISSOLUTION
OF MARRIAGE
2 of 6
1.10
2
3
4
5
1.12
6
7
Spousal Maintenance
Protection Order
Does not apply
1.13
Pregnancy
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1.14
12
This court has jurisdiction over the children for the reasons set forth below.
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This state is the home state of the children because:
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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.
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1.15
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/
//
PETITION FOR DISSOLUTION
OF MARRIAGE
3 of 6
Name of
Child
Mother's
Name
Father's
Name
Jennifer Shipman
Jennifer Shipman
Jason Shipman
Jason Shipman
2
TS
HS
3
4
The petitioner's proposed parenting plan for the children listed above:
(The following information is required only for the children who are included in the
petitioner's proposed parenting plan.)
7
During the last five years, the children have lived:
8
in no place other than the State of Washington and with no person other than the
petitioner or the respondent.
10
The petitioner does not know of any person other than the respondent who has
physical custody of, or claims to have custody or visitation rights to, the children.
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14
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The petitioner does not know of any other legal proceedings concerning the
children.
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1.16
Other
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There are no other provisions
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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.
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Approve the petitioner's proposed parenting plan for the dependent children listed
in paragraph 1.14.
PETITION FOR DISSOLUTION
OF MARRIAGE
4 of 6
Determine support for the dependent children listed in paragraph 1.14 pursuant to
the Washington State Child Support Schedule.
2
Change name of wife to: Jennifer Kay Lund.
3
Order payment of day care expenses for the children listed in paragraph 1.14.
4
Order payment of Vi of attorney fees, other professional fees and costs
5
J j v i s i o n o f p r o p i f v f j } d t i f f e tb v j. iicJb'i ( ik lS
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Dated this 10th Day of March 2010
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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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PETITION FOR DISSOLUTION
OF MARRIAGE
5 of 6
Joinder
I, Jason William Shipman, 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.
6
[ ] I waive notice of entry of the decree.
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[ ] I demand notice of all further proceedings in this matter. Further notice should be
sent to the following address [You may list an address that is not your residential address
where you agree to accept legal documents]:
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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.
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Dated:______________________
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______________________
Jason Shipman, Respondent
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PETITION FOR DISSOLUTION
OF MARRIAGE
6 of 6
E-FILE
IN COUNTY CLEI
PIERCE COUNTY,
March 15 201(
KEVIN S'
COUNTY C
NO: 10-3-C
2
3
4
5
6
7
8
In re the Marriage of:
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10
No.
Summons
(SM)
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1.
The petitioner has started an action in the above court requesting that your marriage be
dissolved.
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Additional requests, if any, are stated in the petition, a copy of which is attached to this
summons.
2.
You must respond to this summons and petition by serving a copy of your written
response on the person signing this summons and by filing the original with the clerk of the
court. If you do not serve your written response within 20 days (or 60 days if you are served
outside of the State of Washington) after the date this summons was served on you, exclusive of
the day of service, the court may enter an order of default against you, and the court may, without
further notice to you, enter a decree and approve or provide for the relief requested in the
petition. In the case of a dissolution of marriage, the court will not enter the final decree until at
least 90 days after filing and service. If you serve a notice of appearance on the undersigned
person, you are entitled to notice before an order of default or a decree may be entered.
3.
Your written response to the summons and petition must be on form WPF DR 01.0300,
Response to Petition (Domestic Relations). This form may be obtained by contacting the clerk of
Summons
1 of 2
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:
2
http ://www.courts.wa.gov/forms
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4.
If this action has not been filed with the court, you may demand that the petitioner file
this action with the court. If you do so, the demand must be in writing and must be served upon
the person signing this summons. Within 14 days after you serve the demand, the petitioner must
file this action with the court, or the service on you of this summons and petition will be void.
5.
If you wish to seek the advice of an attorney in this matter, you should do so promptly so
that your written response, if any, may be served on time.
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6.
One method of serving a copy of 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 4.1 of the state of Washington.
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Summons
2 of 2
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
March 15 2010
KEVIN STO
COUNTY CL
NO: 10-3-0)
2
3
4
5
6
Superior Court of Washington
County of Pierce
7
8
10
No.
Petitioner,
Financial Declaration
[X] Petitioner
(FNDCLR)
And
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2.2
2.3
1 of 5
1
2
3
4
5
6
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10
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3.2
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13
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h.
a. Income Taxes
b. FICA/Self-employment Taxes
c. State Industrial Insurance Deductions
d. Mandatory Union/Professional Dues
e. Pension Plan Payments
f.
Spousal Maintenance Paid
g. Normal Business Expenses
Total Deductions from Gross Income
(add lines 3.2a through 3.2g)
Jennifer Shipman
$1,185.50
$446.80
Jason Shipman
$812.55
$371.41
$40.06
$62.06
$1,672.36
$1,246.02
$4,285.14
$3,608.98
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2
3.5
3
4
3.6 If the income of either party is disputed, state monthly income you believe is
correct and explain below:
Husband income of 4,855.00 based on 2009 Joint income tax return
5
IV. Available Assets
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4.1
4.2
4.3
4.4
Cash on hand
On deposit in banks
Stocks and bonds
Cash value of life insurance
Other liauid assets:
$20.00
$1,530.00
-
$1,670.69
$1,670.69
5.2 Utilities
Heat (gas & oil)
Electricity
Water, sewer, garbage
Telephone
Cable
Other: internet
Total Utilities
$100.00
$100.00
$90.00
$230.00
$85.00
$48.00
$653.00
$700.00
5.4 Children
Day Care/Babysitting
150.00
$400.00
$50.00
$250.00
3 of 5
la
1
2
Clothing
Tuition (if any)
Other child-related expenses
Total Expenses Children
3
4
5
6
5.5 Transportation
Vehicle payments or leases
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
Parking
Other transportation expenses
Total Transportation
$356.55
$75.67
$225.00
$657.22
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8
9
10
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$40.00
$100.00
$65.00
$10.00
$150.00
$365.00
$175.55
$7.50
$183.05
$4,228.96
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4 of 5
la
1
2
3
4
5
5.11 Other Debts and Monthly Expenses not Included in Paragraphs 5.1 - 5.8
Creditor/Descrintion of
Balance
Month of Last
Amount of
Debt
Payment
Monthly Pa
Alaska Credit Union /
$20,000.00
$356.00
April, 2010
auto loan
Red Canoe Bank
$3,000.00
April, 2010
$90.00
Sallie Mae / student loans
$8,000.00
January, 2010
$76.00
Total Monthly Payments for Other Debts and Monthly
Expenses
$522.00
6
5.12
$4,750.96
7
VI. Attorney Fees
8
6.1
6.2
The source of this money was: Loan from Red Canoe Bank
6.3
6.4
$1,780.00
9
10
$1,780.00
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6.5
Other:
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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 Puyallup, Washington on March 9, 2010
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(
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jk m
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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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law
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, '
March 15 201C
mam
KEVIN ST
COUNTY C
NO: 10-3-0
3
4
5
6
7
8
In re the Marriage of:
9
JENNIFER KAY SHIPMAN
Petitioner,
and
10
No.
Parenting Plan
[XX] Proposed (PPP)
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I. General Information
This parenting plan applies to the following children:
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Name Age
18
TS
HS
15
8
19
II. Basis for Restrictions
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Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contact with the children and the right to make decisions for the children.
i
il
PARENTING PLAN
PROPOSED (PPP)
1 OF 8
2.1
2
3
2.2
5
6
7
8
The residential schedule must set forth where the children shall reside each day o f the year,
including provisions for holidays, birthdays o f family members, vacations, and other special
occasions, and what contact the children shall have with each parent. Parents are encouraged
to create a residential schedule that meets the developmental needs o f the children 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.
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3.1
10
There are no children under school age.
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3.2
School Schedule
Upon enrollment in school, the children shall reside with the mother, except for the
following days and times when the children will reside with or be with the other parent:
From:
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3.3
Friday 7 pm
to
Sunday 7 pm
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The children shall reside with the mother during winter vacation, except for the
following days and times when the children will reside with or be with the other parent:
the winter vacation shall be split equally between the parents.
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3.4
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3.5
Summer Schedule
Upon completion of the school year, the children shall reside with the mother, except for
the following days and times when the children will reside with or be with the other parent:
Same as school year schedule.
PARENTING PLAN
PROPOSED (PPP)
3.6
2
3
3.7
4
The residential schedule for the children for the holidays listed below is as follows:
5
With Mother
(Specify Year
Odd/Even/Every)
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7
8
9
10
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12
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
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[ ]
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EVEN
EVEN
EVEN
ODD
EVEN
ODD
EVEN
EVEN
ODD
ODD
For purposes of this parenting plan, a holiday shall begin at 8 a.m. and end at 10 p.m.
13
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ODD
ODD
ODD
EVEN
ODD
EVEN
ODD
ODD
EVEN
EVEN
With Father
(Specify Year
Odd/Even/Every)
3.8
Other:
The residential schedule for the children for the following special occasions (for example,
birthdays) is as follows:
With Mother
With Father
(Specify Year
(Specify Year
Odd/Even/Every)
Odd/Even/Every)
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Mother's Day
Mother Birthday
Father's Day
Fathers Birthday
TSs Birthday
HSs Birthday
PARENTING PLAN
PROPOSED (PPP)
EVERY
EVERY
NEVER
NEVER
EVEN
EVEN
NEVER
NEVER
EVERY
EVERY
ODD
ODD
3.9
If the residential schedule, paragraphs 3.1 - 3.8, results in a conflict where the children are
scheduled to be with both parents at the same time, the conflict shall be resolved by priority
being given as follows:
Rank the order of priority, with 1 being given the highest priority:
1
2
3
4
5
6
7
6
7
8
9
3.10
Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2
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3.11
Transportation Arrangements
12
Transportation costs are included in the Child Support Worksheets and/or the Order of
Child Support and should not be included here.
13
Transportation arrangements for the children between parents shall be as follows:
the receiving parent shall provide the transportation to the exchange point
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3.12
Designation of Custodian
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The children named in this parenting plan are scheduled to reside the majority of the time
with the mother. This parent is designated the custodian of the children solely for purposes of
all other state and federal statutes which require a designation or determination of custody. This
designation shall not affect either parents rights and responsibilities under this parenting plan.
19
3.13
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Other
there are no other provision
3.14
PARENTING PLAN
PROPOSED (PPP)
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.
2
3
4
5
6
7
8
If the move is outside the child's school district, the relocating person must give notice by
personal service or by mail requiring a return receipt. This notice must be at least 60 days before
the intended move. If the relocating person could not have known about the move 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.
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Failure to give the required notice may be grounds for sanctions, including contempt.
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A person entitled to time with a child under a court order can file an objection to the
child's relocation whether or not he or she received proper notice.
An objection may be filed by using the mandatory pattern form WPF DRPSCU 07.0700,
(Objection to Relocation/Petition for Modification of Custody Decree/Parenting Plan/Residential
Schedule). The objection must be served on all persons entitled to time with the child.
The relocating person shall not move the child during the time for objection unless: (a)
the delayed notice provisions apply; or (b) a court order allows the move.
20
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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.
22
PARENTING PLAN
PROPOSED (PPP)
4.1
Each parent shall make decisions regarding tire day-to-day care and control of each child
while the children are residing with that parent. Regardless of the allocation of decision making
in this parenting plan, either parent may make emergency decisions affecting the health or safety
of the children.
Day-to-Day Decisions
5
4.2
Major Decisions
6
Major decisions regarding each child shall be made as follows:
7
[ ] mother
[ ] father
[XX] joint
[ ] father
[XX] joint
Religious upbringing:
[ ] father
[XX] joint
Education decisions:
8
9
[ ] mother
10
4.3
11
Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2 above
12
V. Dispute Resolution
13
The purpose o f this dispute resolution process is to resolve disagreements about carrying out this
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15
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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.
Disputes between the parties, other than child support disputes, shall be submitted to
mediation by Pierce County Center for Dispute Resolution
18
The cost of this process shall be allocated between the parties as follows:
19
As determined in the dispute resolution process.
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The dispute resolution process shall be commenced by notifying the other party by
written request via certified mail, return receipt.
In the dispute resolution process:
PARENTING PLAN
PROPOSED (PPP)
(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.
4
5
(c)
mediation and of each arbitration award and shall be provided to each party.
6
7
(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.
8
9
(e)
The parties have the right of review from the dispute resolution process to the
superior court.
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14
declare under penalty of peijury 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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7 OF 8
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3
4
5
6
7
8
9
10
11
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Jason Shipman
Signature of Party
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PARENTING PLAN
PROPOSED (PPP)
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
March 15 2010 3:08 PM
COUNTY CLERK
NO: 10-3-00961-1
, (CSWP) Or, [
W orksheets
Children and Ages: TSage15
and
HS age 8
Father
Mother
$5,957
$4,855
$4,855
$
$5,957
$813
$371
$1,186
$447
> \
($40 ) bO
"T
$
$
$
$62
$
$
$
$
$1,246
$3,609
$1673
$4,284
$7,893
$946
HS $767
$1,713
.457
.543
$782.84
$930.16
$783
$930
Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
10. Health Care Exoenses
a. Monthly Health Insurance Premiums Paid for Child(ren)
b. Uninsured Monthly Health Care Expenses Paid for Child(ren)
c. Total Monthly Health Care Expenses (line 10a plus line 10b)
Father
$
$
$
Mother
$
$
$85.65
$
$150
b. Education Expenses
$
$
$
$
$150
12. Combined Monthly Total Day Care and Special Expenses (add
fathers and mother's day care and special expenses from line 11e)
13. Total Health Care, Day Care, and Special Expenses (line 10d plus
line 12)
$150
$236
14. Each Parents Obligation for Health Care, Day Care, and Special
Expenses (multiply each number on line 6 by line 13)
$108
$128
$891
$1,058
$
$150
$
d. Total Support Credits (add lines 16a through 16c)
$
$150
$908
$891
19. 25% of each parents basic support obligation from line 9 (.25 x
amount from line 9 for each parent)
Mothers
Household
$
$
e. Retirement Accounts
f. Other (describe)
$
$
$
$
$
$
Judicial/Reviewing Officer
Date
This worksheet has been certified by the State of Washington Administrative Office of the Courts.
Photocopying of the worksheet is permitted.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 10/2009 Page 5 o f 5
e - f il e :
IN COUNTY C L E :
PIERCE COUNTY, \
March 16 2010
KEVIN ST
COUNTY C
NO: 10-3-0
3
4
5
6
10
NO. 10-3-00961-1
RETURN OF SERVICE
(OPTIONAL USE)
(RTS)
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I am over the age of 18 years, I am not a party to this action, and I am competent to testify
at trial.
15
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2.
[XX]
[XX]
[XX]
[XX]
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3.
20
Date:
March 15,2010
21
Address:
22
McKenna, WA 98558
RETURN OF SERVICE
1 OF 2
4.
5.
Other:
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 Puyallup, WA, on March 16, 2010
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Shad Chajlman, Declarant
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RETURN OF SERVICE
2 OF 2
law
E-FILE
IN COUNTY CLEI
PIERCE COUNTY
March 23 2010
KEVIN S'
COUNTY C
NO: 10-3-C
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And,
COVER SHEET:
PROOF OF PARENTING CLASS
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JASON SHIPMAN,
____________Respondent.
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To the above named Court
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Attached please find the Certificate of Completion for the parenting seminar attended by
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COVER SHEET:
PROOF OF PARENTING CLASS
1 of 1
/ ^ - 3 -
/ -
q q
Cause Number
3 ra \n X c -r
Case names:
S hvonw v
Petitioner
S h ip m a rt
Respondent
Certificate of Completion
Dated this 16th day of March, 2010
In the City of Tacoma, State of Washington
S o h n M k n Stines, 9 A.S.
-4 /1 /2 8 -te m ? %
FILED
IN COUNTY CLERK'S OFFICE
A.M.
10-3-00961-1
34043916
3 1 2010
P.M.
04-01-10
RSP
MAR
*-1
No. 10-3-00961-1
Response to Petition
(Marriage)
Petitioner,
(RSP)
Check box if petition is attached for:
[ ] O rder for protection DV (PTORPRT)
[ ] O rder for protection UH (PTORAH)
and
Jason W. Shipman
________________________ Respondent.
To the Above-Named Petitioner:
I. Response
1.1
[x]
[X)
[X]
[X]
[X]
[X]
[Xj
[]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
u
[]
[]
[]
[]
[]
[]
[x]
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
u
[]
f]
[]
[]
[]
[]
[]
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
8372
1.9
1.10
[x]
[x]
1.11
M2
[X]
1.13
1.14
1.15
1.16
[X]
[X]
[X]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
[]
[]
[]
[}
[]
[]
[x]
Denied
Denied
Denied
Denied
Denied
Denied
[]
[]
[]
[}
[]
[]
1128338
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Denied
[]
Lacks Information
[3 Denied
[]
[*] Admitted
Each allegation of the petition that is denied, is denied for the following reasons (List separately):
1.8 Is denied for the following reasons,
Respondent would prefer mediation for the property division instead of a court proceeding.
1.15 is denied for the following reasons,
The summer schedule in the parenting plan should be modified, The parenting plan should be modified to
allow travel for work.
1.2
1.3
3^1^2818
*
9 3 72
JS1Z3337
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
Protection Order:
[]
[]
If you need immediate protection, contact the clerk/court for RCW 26.50 Domestic
Violence forms or RCW 10.14 Antiharassment forms.
D a te d :
[]
[)
[]
[]
[]
3- 30-
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Print or Type Name
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Jason Shipman
Has Successfully Completed the 4 Hour Training
Certificate of Completion
In the City of Olympia, State of Washington, 4/21/2010
Family Education
& Support Services
Marji Mitchell
1-'
Walt Barfield
E-FILEb
IN COUNTY CLEF
PIERCE COUNTY, W
June 04 2010 8
KEVIN STO
COUNTY CL
NO: 10-3-03
2
3
4
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8
Petitioner(s),
and
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No. 10-3-00961-1
Declaration of
JENNIFER KAY SHIPMAN
(PCLR Modified)_______
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I Declare:
That I am Jennifer Kay Shipman, I am competent, and I am a party to this action.
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P arenting Plan:
We have separated since February 27, 2010. To date, we have worked out parenting
informally (I have been the primary residential parent and Jason has had visitation with
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the children every other weekend). However, Jason has issues with the summer visitation
18
that I propose: In his Response, which was filed on March 31, he is requesting that the
court Modify petitioner s parenting plan, providing six weeks of summer vacation with
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respondent. Suspend visitation as needed to allow respondent to travel for work (emphasis
added).
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Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 7310G3
Puyallup, Washington 98373
(253) 770-0808, Fox (253) 770-0259
1
2
My parenting plan allows each parent to have two weeks of vacation with the children.
With our situation, it would be impractical to give Jason six weeks with the children.
Primarily, although the children would be on vacation the whole time, Jason would not.
Jason would be working during the day, thereby leaving a nine year old child at home with
a fifteen year old. Second, Jason often has to travel on his job, as he has conceded in his
response.
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6
7
8
9
Child Support:
Since we have been separated, Jason has been paying a form of child support informally.
However, again, we need an order, both for the protection of the children, and because we
have disagreement on some issues. I also have to modify the drafted child support
worksheets which I had submitted on March 15, 2010, to cover some issues, such as
daycare and health insurance, which were not covered in the initial proposed worksheets.
10
Regarding daycare, I am paying $ 150 a month for daycare for our child HS. I am proposing
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that Jason pay 50% of that. The boys are active in sports, I am proposing that Jason pay
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50% of the expenditures for the boys participation, which would be $ 130 plus the cost of
uniform, equipment, and pictures annually for baseball, and $ 160 plus the cost of uniform,
equipment, and pictures annually for football. Health insurance is provided for the boys by
Jasons employer at no charge (no formal premiums are paid). I would propose, however,
that each parent be formally obligated by a proportionate share of our incomes for any
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extraordinary health care or dental expenses not covered by insurance. In particular, our
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To date, Jason has been paying me directly for the support. However, I believe it is both of
our best interests, to avoid any problems in the future, that the Division of Child Support
be enlisted to provide enforcement and collection services.
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Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
1
2
Ford F-150 and 86 or 87 Toyota 4 Runner, and kept the $ 6,100 he earned from those
deals. I am especially upset about this sale because, two years prior, Jason had badgered
me to cash out what retirement I had at that time so that we could buy the 4 Runner.
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6
7
8
9
Jason had also received the refund from our 2009 joint tax return, which was
$ 12,281.oo , and only gave me $ 790.45 from the proceeds.
Jason should be enjoined from selling any further property. Further, in case any of the
proceeds of the sale of the vehicles referenced above, or from the 2009 income tax are left,
he should be enjoined from spending or disposing of those funds.
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I dont want a restraining order, but I want a court order indicating that Jason may not
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enter the family home without my permission, and that Jason must give me the master
code for the homes security system.
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Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
1
2
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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Jennifer Shipman
Print or Type Name
Do not attach financial records, personal health care records or confidential
reports to this declaration. Such records should be served on the other party and
filed with the court using one of these cover sheets:
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
If filed separately using a 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(
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Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
June 04 2010 3
1
KEVIN STO
COUNTY C .
NO: 10-3-0)
4
5
6
7
10
11
No. 10-3-00961-1
Petitioner,
and
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Respondent.
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I.
Motion
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Based on the declaration below, the undersigned moves the court for a temporaiy order which:
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[]
[x]
[X]
[]
[X]
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[]
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[]
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25
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[]
1 of 3
1
2
[]
3
4
5
[]
[X ]
[]
8
9
10
11
[X]
12
[X ]
[X ]
[X ]
[X ]
[X]
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14
15
16
[1
17
Ij
other:
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Dated:
? 2 - 0 ] O ___________
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^
______ _____
S^gnatufaof Requesting Party or Lawyer/WSBA No.
Timothy M'/Greene. WSBA # 17499
Print or Type Name
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M otion a n d D e c la ra tio n
fo r T em p o ra ry O rd ers
1
2
3
4
II. Declaration
Tem porary relief is required because:
Declaration filed separately
I declare under penalty o f perjury under the laws o f the state o f W ashington that the foregoing is true and
correct.
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Signature o f Requesting Party
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12
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Jennifer Shipman
Print or Type N am e
Do not attach financial records, personal health care records or confidential reports to
this declaration. Such records should be served on the other party and filed with the
court using one of these cover sheets:
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
If filed separately using a 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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M otion an d D e c la ra tio n
fo r T em p o ra ry O rd ers
3 of 3
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
June 04 2010 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
Phone:
Respondent
Please take notice that an issue of law in this case will be heard on the date and time shown below:
P ierce C o u n ty S u p e rio r C o u rt, C o u n ty -C ity B uilding - 930 T a c o m a A v e S - T aco m a , W A 9840 2
DA TED :
June 3, 2010.
S ign ed :
NA M E:
TIMOTHY M. GREENE
Phone:
(253) 770-0808
W SBA#:
17499
A D D R E S S : 4115 S MERIDIAN
PO BOX 731063
PUYALLUP, WA 98373
For:
1 of 1
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
June 04 2010 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
NO. 10-3-00961-1
NOTICE OF APPEARANCE
ntaprsup-0001.pdf
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
July 12 2010 1:30 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
Please take notice that an issue of law in this case will be heard on the date and time shown below:
P ierce C o u n ty S u p e rio r C o u rt, C o u n ty -C ity B uilding - 930 T a c o m a A v e S - T aco m a , W A 9840 2
DA TED :
S ign ed :
NA M E:
TIMOTHY M. GREENE
Phone:
(253) 770-0808
W SBA#:
17499
A D D R E S S : 4115 S MERIDIAN
PO BOX 731063
PUYALLUP, WA 98373
For:
1 of 1
3349
vs.
Page 1 of 2
ROBERT D. LLOYD
CLINT P. JOHNSON
SHIPMAN, TYLER
SHIPMAN, HUNTER
Resolution:
Ixcalcivii.pbl,d_cMIJoumal_rvport_cover
QS43
T382SZ
vs.
JASON WILLIAM SHIPMAN
Page: 2 of 2
Judge/Commissioner:
STEPHANIE A. AREND
July 16, 2010 09:45 AM This matter comes before the Court on an assignment to set a trial
date. Attorney Johnson appears on behalf of the Respondent.
Court/counsel colloquy.
Court generates a case schedule setting a trial date of July 25, 2011 at 9:00 am and
provides 2 copies to Atty. Johnson. Court is at recess on this matter.
Confirmation of Service
12/06/10
Set Settlement Conference Date with Judge/Com m issioner ELIZABETH M AR TIN (S ee PCLR 3(c) 2(b ) &
94 .04 (f
02/21/11
03/07/11
04/04/11
04/25/11
05/09/11
Discovery Cutoff
06/13/11
06/27/11
06/27/11
Week Of 07/11/11
07/25/11 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/PETITIONER
If the case has been filed, the plaintiff shall serve a copy of the Case Schedule on the defendant(s) with the summons and
complaint/petition: Provided that in those cases where service is by publication the plaintiff shall serve the Case Schedule
within five (5) court days of service of the defendants first response/appearanee. 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.
S349
7 ^ 2 0 ^ 2 3 1 3 '& S 8 2 8 4
ORDER AMENDING
CASE SCHEDULE
Petitioner(s)
vs.
JASON WILLIAM SHIPMAN
Respondent(s)
CC:
Type of Case:
Estimated Trial (days):
Track Assignment:
Assigned Department:
Docket Code:
Page 2 of 2
DIC
Dissolution
12
ORACS
o84cv
7 /2 8 /2 0 3 /0 .-S30Z7S
vs.
Page 1 of 2
ROBERT D. LLOYD
CLINT P. JOHNSON
SHIPMAN, TYLER
SHIPMAN, HUNTER
Resolution:
vs.
JASON WILLIAM SHIPMAN
Page: 2 of 2
Judge/Commissioner:
Mark L Gelman
Attorney Tim Greene comes before the court to present an agreed temporary order. Court
declines to sign order. Order to list full names of children and to be on mandatory pattern
form.
3Z7
10-3-00961-1
34756054
PPT
iS /2 ^ 2 8 i
1278383
00-02-10
FILED
IN COUNTY CLERKS OFFICE
JUL 3 0
2010
p.m.
3
BY ---------------------- .DEPUTY
4
5
6
7
8
JENNIFER KAY SHIPMAN
No. 10-3-00961-1
9
Petitioner,
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and
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Parenting Plan
[x ] Temporary (PPT)
Respondent.
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This parenting plan is:
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pC ]
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A temporary parenting plan signed by the court, and agreed to by the parties to
be an interim order until the hearing on temporary orders in this matter,
presently scheduled for August 24, 2010.
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17
Age
Tyler Shipman
15
Hunter Shipman
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9127
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1271
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8 /2 7 2 8 1 8
Under certain circumstances, as outlined below, the court may limit or prohibit a parent's contact with
the children and the right to make decisions fo r the children.
I
2.1
5
2.2
6
Does not apply
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3.1
12
There are no children under school age.
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3.2
School Schedule
Upon enrollment in school, the children shall reside with the mother, except for the following
days and times when the children will reside with or be with the other parent:
From: Friday 7:00 pm to Sunday 7:00 pm every other week; starting the weekend of July 9,
2010 (Friday).
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The children shall reside with the mother during winter vacation, except for the following days
and times when the children will reside with or be with the other parent:
No schedule until further temporary orders are entered at the hearing presently scheduled
for August 24, 2010 or a permanent parenting plan is entered.
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3.4
9127
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1
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3
/
3.5
Upon completion of the school year, the children shall reside with the mother, except for the
following days and times when the children will reside with or be with the other parent:
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5
This interim order is entered without prejudice to fathers request for more vacation time as
entered in his response.
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Summer Schedule
3.7
10
The residential schedule for the children for the holidays listed below is as follows:
11
No holidays until further temporary orders are entered at the hearing presently scheduled
for August 24, 2010.
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3.8
13
The residential schedule for the children for the following special occasions (for example,
birthdays) is as follows:
No special occasions until further temporary orders are entered at the hearing presently
scheduled for August 24,2010.
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3.9
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3.10
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Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2
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9 1 2 ? S /2 /2 8 1 B
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3.11
2
3
Transportation Arrangements
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 children between parents shall be as follows:
The parents shall exchange the children at the Fred Meyer parking lot at 176thand
Meridian between the Baskin-Robbins store and the Umpqua Bank at the beginning and
end of each visitation period. Each parent must be present for exchange, and neither
parent may substitute another person.
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3.12
The children named in this parenting plan are scheduled to reside the majority of the time with
the mother. This parent is designated the custodian of the children solely for purposes of all other state
and federal statutes which require a designation or determination of custody. This designation shall not
affect either parent's rights and responsibilities under this parenting plan.
9
10
3.13
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12
Designation of Custodian
Other
there are no other provision
3.14
13
This is a sum m ary only. For the full text, please see RCW 26,09.430 through 26.09.480.
14
If the person with whom the child resides a majority of the time plans to move, that person shall
give notice to every person entitled to court ordered time with the child.
15
If the move is outside the child's school district, the relocating person must give notice by
personal service or by mail requiring a return receipt. This notice must be at least 60 days before the
intended move. If the relocating person could not have known about the move 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).
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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.
Parenting Plan (PPP, PPT, PP) * Page 4 of 7
WPF DR 01,0400 Mandatory (6/2008) R C W 26.09.016, .181; .187; .194
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian, Ste. B
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
912?
1271
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3
4
5
6
7
A relocating person may ask the court to waive any notice requirements that may put the health
and safety of a person or a child at risk.
Failure to give the required notice may be grounds for sanctions, including contempt.
If no objection is filed within 30 days after service of the notice of intended relocation, the
relocation will be permitted and the proposed revised residential schedule may be confirmed.
A person entitled to time with a child under a court order can file an objection to the child's
relocation whether or not he or she received proper notice.
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.
10
11
Day-to-Day Decisions
Each parent shall make decisions regarding the day-to-day care and control of each child while
the children are residing with that parent. Regardless of the allocation of decision making in this
parenting plan, either parent may make emergency decisions affecting the health or safety of the children.
4.2
Major Decisions
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Education decisions:
[ ] mother
[ ] father
[XX] joint
18
[ ] mother
[ ] father
[XX] joint
19
Religious upbringing:
[ ] mother
[ ] father
[XX] joint
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912?
8^2>201B
1 2 .7 0
1
V. Dispute Resolution
2
3
4
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.
5
6
Disputes between the parties, other than child support disputes, shall be submitted to mediation
by Pierce County Center for Dispute Resolution
The cost of this process shall be allocated between the parties as follows:
8
9
The dispute resolution process shall be commenced by notifying the other party by written
request via certified mail, return receipt.
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11
(a)
12
(b)
Unless an emergency exists, the parents shall use the designated process to resolve
13
disputes relating to implementation of the plan, except those related to financial support.
(c)
14
(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.
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(e)
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20
The parties have the right of review from the dispute resolution process to the superior
court.
VI. Other Provisions
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912 7
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1*
1
VIII. Order by the Court
IT IS ORDERED, ADJUDGED AND DECREED that the parenting plan set forth above is adopted and
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.
6
7
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.
8
If a parent fails to comply with a provision of this plan, the other parent's obligations under the plan are
9
not affected.
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14
15
Presented by:
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9127
S V 2 /2 616
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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 9A40.060(2) or
9A.40.G70(2). Violation of this order may subject a violator to arrest
When mutual decision making is designated but cannot be achieved, the parties shall make a good faith
effort to resolve the issue through the dispute resolution process.
If a parent fails to comply with a provision of this plan, the other parent's obligations under the plan are
not affected.
Date this
day
2010
ft | tr-EO
m m is s io n e r
P.M.
P 'E COUNTY, WASHINGiTON
^KEVIN STOCK, County (IIfork
tr
Approved for entry. Notice of
Presentation Waived ^
Cunt P, Johnson,
Attorney for Respond
#14794
0 iPUTY
9356
8 / 16,'20 18
888B9
08-16-10
10-3-00961-1
2
L0UNTY CLERKS OFFICE
am.
AUG is 2010 PM
4
-----t y deputv
5
6
7
No. 10-3-00961-1
Petitioner(s),
and
10
n
12
Supplemental Declaration of
JENNIFER KAY SHIPMAN
Re: Motion for
Temporary Orders
(DCLR Modified)
13
14
/ Declare:
20
now $ 35,000. The original loan was for a 2002 Mercedes, which had recently had
21
electrical problems and transmission problems that would cost $ 8,000 to $ 9,000
to repair, at the time that my Mercedes was only worth $ 16,000.1 accordingly
22
23
purchased a used 2004 Cadillac Escalade, with the $ 35,000 Alaska Credit Union
loan.
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
9356
8 ^ 1 6 /2 6 1 8
The monthly payments on the Escalade are $ 200 more a month, or $ 556.00.
1
2
(b) I had to take out a Home Depot credit card and borrow $ 800 on that
3
4
Division o f Debts:
5
6
7
I am requesting that Jason either agree to, or be ordered to, pay half of the unpaid
community related bills that accrued before he left the community home. These are bills
related to the Verizon cell phone, cable, water, garbage, house phone, and auto insurance.
I will have the bills itemized immediately for my attorney to present to Jasons attorney.
8
9
I declare under penalty of perjury under the laws of the state of Washington that the
foregoing is true and correct.
10
13
14
15
16
17
18
iu iik
fer Shipman
Lture of Declarant
k L ,_________
19
20
21
22
23
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
4
5
6
7
8
10
11
12
NO. 10-3-00961-1
REPLY DECLARATION OF
JASON SHIPMAN
vs.
JASON WILLIAM SHIPMAN,
Respondent.
13
14
15
16
17
This declaration is made under penalty of perjury of the laws of the State of
Washington.
18
Parenting plan.
19
20
21
I generally agree with the proposed plan, but I objected in my Response to the
summer schedule and I requested flexibility in the schedule due to my travel for work.
22
There is no reason I should not have the boys for half the summer. Jennifer states
23
I would be leaving a nine year old child alone with a fifteen year old. Yet the boys have
24
25
been home alone at her house all summer. On one occasion she left Hunter (the nine year
old) home alone while she was getting her car repaired. Tyler is now sixteen and capable
REPLY DECLARATION
OF JASON SHIPMAN - 1
FAUBION, JOHNSON, REEDER & FRALEY, P.S.
Attorneys at Law
5920 100th Street S.W., S uite 25
Lakewood, WA 98499
(253)581-0660
of watching his brother. If this is acceptable at her home, why not at mine? I am with the
children every weekend they are at my home. She has them at friends homes most of the
weekends they are with her. In fact, when I was still living in the family home, Tyler had
gone to a friends home. When Jennifer and I picked him up we had a conversation
regarding the residence and location. We decided he should not go there anymore
because it just was not a good place. There was no parental supervision. However, after I
moved out Jennifer herself began to let Tyler do whatever he wanted without
supervision, including returning to that home.
About three weeks ago my brother saw Tyler walking on Portland Avenue in
Tacoma after 10:00 p.m. My brother called Jennifer to let her know about this. Jennifer
said it was all right because Tyler was staying with a friend. It turned out to be the
place we said he should not be. I got a call from the police at about 1:30 a.m. They had
arrested Tyler for shoplifting. The police could not reach his mother; she was not home
and would not answer her cell phone. Tylers friends mother, who was supposed to be
supervising the boys, was so drunk she could not hold a conversation with police. The
police asked me if it was all right to release Tyler to my parents.
When our sons stayed with me for a week, I made sure they had proper parental
supervision while I was at work, they were either with me or with friends whose parents
were capable of watching them. I am currently not traveling for my job because, among
other antics, Jennifer called my workplace making false accusations that I stole my
employers property and it was in the garage. This ended up involving the owner of the
REPLY DECLARATION
OF JASON SHIPMAN - 2
FAUBION, JOHNSON, REEDER & FRALEY, P.S.
A ttorneys
at
Law
S.W., Suite 25
Lakewood , WA 98499
(253) 581-0660
company, human resources, my boss, and the company attorney. Then when they
planned to come and get the allegedly stolen property, Jennifer said, Oh, never mind, I
changed my mind. There was no stolen property, but now my employer will always
question whether I am a thief.
In addition, Jennifer has keyed my work van, called 911 and fabricated a story
saying I hurt her, attempted to get an unnecessary restraining order, and caused a lot of
problems for me at work. I have a security clearance and am in the P.R.P. program. I
have to explain to my employer all these things that Jennifer is doing. I am on very thin
ice and have been demoted to the testing department. I am no longer traveling (see
attached letter from my employer). There should be no more concern as to me watching
our children in the summer.
Now that my travel for work has been eliminated, I have filed a Proposed
Parenting Plan providing me with more time with my two sons. In addition to sharing
the summer, I am proposing alternating weekends from Friday at 7:00 p.m. to Monday
morning (return to school) and a regular weeknight visit. I do have concerns with
Jennifers ability to care for the boys full time. She seems to be taking out her anger on
Tyler. See the police report filed under seal.
Child support.
Jennifer and I agreed informally I would pay her $175.00 a week to help support
the boys. That is what I have been paying. I have given her forms to have the money
directly deposited to her account, but she refuses to do so.
REPLY DECLARATION
OF JASON SHIPMAN - 3
FAUBION, JOHNSON, REEDER & FRALEY, P.S.
Attorneys at Law
5920 100th Street S.W., Suite 25
Lakewood, WA 98499
(253) 581-0660
Hunter has not been going to daycare. Tyler watches him. Again, she states in her
document that I cannot see the boys because I will leave them alone, yet that is exactly
what she does and now she wants additional money for daycare.
The sports she refers to are activities she signs them up for without consulting
me. I do not ask her to pay for extracurricular activates they participate in when they are
with me. If I am expected to participate in paying for activities, I should consent to them
first and not pay for Jennifers unilateral decisions.
Jennifer is upset I bought a motorcycle, yet we discussed the purchase and she
agreed to it. She even took me to Renton to buy it and sat there while I did the
paperwork. Now she says I spent the money frivolously.
My earnings statements are filed under seal. My child support worksheets are
based on my regular year-to-date earnings. I no longer receive per diem since I do not
travel. According to this worksheet, my monthly support obligation should be $780.02.
Restraining order re Community Property,
I sold the Ford truck a week or two before I left for $200. It was not drivable and
would have cost a lot of money to fix. I also sold the 4Runner before I left because it was
not practical. I got $2,000 for it and I put the money down on a 2002 Toyota truck that
was better for the family, so for both vehicles I received $2,200, not $6,100.1bought the
truck before I left. Jennifer traded in our very nice 2007 Chevy 2500 diesel truck for a
Mercedes Benz. I had begged her not to do this. I told her if it broke she could never
REPLY DECLARATION
OF JASON SHIPMAN - 4
FAUBiON, JOHNSON, REEDER & FRALEY, P.S.
Attorneys at Law
5920 100th Street S.W., Suite 25
Lakewood, WA 98499
(253) 581-0660
afford to fix it. That is exactly what happened. Now she has a newer Cadillac Escalade!
These are very expensive vehicles. I bought a simple older Toyota truck. I fail to see why
she can buy and sell all these costly high-end vehicles but I am called to task when I sell
a 1985 4Runner to get 2002 Toyota truck.
As far as badgering her to cash out her retirement, I do take offense at that.
Jennifer got fired from her job and did not go back to work for a long time. She lived off
her retirement money. We traded my truck and her car to get her a brand new truck when
she went back to work. This left me with no vehicle so we got the 4Runner. Again she
got a $35,000 truck; I got a 1985 truck that barely functioned.
As far as the tax return, 1 paid off several of bills with the money, giving Jennifer
half of what was left. I paid two months5power bills; a house payment; a personal loan
from a friend; and the Home Depot, Chase, and Frontier credit cards (see spreadsheet
attached). The credit cards were run up in part because Jennifer was not paying bills. (I
would get calls from bill collectors while working out of town and have to pay them. She
had the power shut off on her once. After that 1 had all bill collectors just call me and I
paid them.) We also remodeled the bathroom, which was very expensive. Jennifer knows
how I spent that money, just as she knows I used the money from the 4Runner to make a
down payment on the truck. I gave her a copy of the spreadsheet. She is just angry and
being vindictive. We only have one debt now and that is her student loan, ft was the debt
with the lowest interest rate so it was the last thing to pay off.
REPLY DECLARATION
OF JASON SHIPMAN - 5
FAUBION, JOHNSON, REEDER & FRALEY, P.S.
A ttorneys at Law
1
2
3
I have no problem not going to the home, but it is my house, too. I offered to put
5
6
the home in my name. I went to the bank and got approval. Jennifer told me to do that so
she could move out. Then when I got approval she got mad and told me she was keeping
7
8
9
the house and I needed to move out. I have always done what she has asked. I think she
should put the home in her name or sell it. She said she was going to stop making the
10
house payment to ruin my credit. I have a text on my work phone that says, im not
11
making the house payment this is war. All of Jennifers statements are false or
12
exaggerated. Jennifer kicked me out of the home and is still punishing me for it. She uses
13
the children as a tool to hurt me. She does not pay bills, which she knows causes me
14
damage. She even tried to get me fired. She has made me go without seeing the children
15
16
17
18
for over six weeks more than once. Even after setting up a time and place with my
attorney, she has not shown up.
Jennifer has not made a house payment since May, even though she earns over
19
$70,000 per year, and receives child support from me. Yet she just bought a very nice
20
car and added $15,000 to her total debt. She should be ordered to resume the mortgage
21
payments and promptly cure the arrears, or immediately refinance the home in her name.
22
Signed at Lakewood, Washington, on August 17, 2010.
23
24
25
REPLY DECLARATION
OF JASON SHIPMAN - 6
FAUBION, JOHNSON, REEDER & FRALEY, P.S.
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakewood, WA 98499
(253)581-0660
beginning $
funds spent on
Frontier credid card
Chase credit card
Home depot card
Frenchie personal loan from a friend
House Payment
Power bills for 2 months
Divided in 2 giving Jen half ($790.45)
$ spent
$3,320.27
$2,075.11
$1,147.82
$2,000.00
$1,603.14
$553.77
$1,580.89
$12,281,00
Balance
$8,960.73
$6,885.62
$5,737.80
$3,737.80
$2,134.66
$1,580.89
$0
As of July 26,2010, Jason Shipman has been re-assigned to a permanent position with our Federal
Fire Alarm Program in Washington State. Jason is a Senior Low Voltage Journeyman and will work
on or around Ft. Lewis Washington. Please contact me if you need additional information.
Thank you,
Page 1 of 1
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https://www4.usbank.com/iiitemetBankixig/en us/image/viewer/ImaaeWriter
N E G O T IA B L E
Progressive insirance
I transferred service it was a final bill after the $553.77 tax return
$159.28 payment
She took me off the policy but it was still in my name so I had to pay
$95.97 final bill
She lives there but I paid this with tax return money; half should be
$801.57 reimbursed to me for fair split of return funds
Qwest phone
She paid her phone bill with my checking info from child support
checks. Along with several other of her bills I had charges reversed at
$146.02 my bank on all the others.
Qwest Phone
Overdraft fees $35.00 x 2
TOTAL
C u s to m e r
JASON W SHIPMAN
Page 1 o f 3
Account No.
994-232-498-0
Account Balance
$338.90
$553.77C R
$135,00C R
____________$.13CR
$350.00C R
Current Charges
Deposit Charges
$159,28
$350.00
$159.28
Meter
Number
Prev
Read
Pres
Date
Prev
Date
KWH
(Usage)
Mult
1
297
297
297
297
297
297
297
KWHS
KWHS
KWHS
KWHS
@
@
@
@
kw hs @
KWHS @
Bill
Demand
KVAR
Hours
Code
Amou nt
ACTL
$.084786 Per KWH
$.002833Per KWH
$.00 Per KWH
$.007269CR Per KWH
$.001684CR Per KWH
$.000374CR Per KWH
$7.00
$25.18
$.84
$.00
$2.16CR
$.50CR
$.11CR
For information, emergencies, to report an outage or for changes to your account, please call 1-888-225-5773.
When paying in person, please present both portions. When matting remittance, please maif'to Puget Sound Energy, BOT-01H, P.O. Box 91269, Bellevue, WA 98009-9269
Customer
JASON W SHIPM AN
Page 1 o f 2
Account No.
Account Balance
$47.09
$47.09CR
$.00
$39.73
$39.73
17E
$147.00
$39.73
$39.73
Current Charges
Balance, as of JUN 11, 2010
$147.00
Amount
$.00
$.00
$.00
$147.00
$147.00
Budget Amount
Budget Payment Due
Meter
Number
H096185718
05/12/10 06/10/10
05/12/10 06/10/10
05/12/10 06/10/10
05/ 12/ 1006 / 10/10
05/12/10 06/10/10
05/12/10 06/10/10
05/12/10 06/ 10/10
05/12/10 06/10/10
$.00
Actual Balance
Balance as of last billing
Payments Applied
Balance Forward
Rate/
Dates
$.00
$147.00
Electric Detail:
994*232-498-0
Amount to Pay
$47.09
$47.09CR
Pres
Read
42822
Prev
Read
42433
Pres
Date
06/10
Prev
Date
05/11
Basic Charge
Energy Charge
Electric Conservation Program Charge
Power Cost Adjustment
Energy Exchange Credit
Wind Power Production Credit
Merger Credit
Regulatory Asset Tracker
KWH
(Usage)
Mult
1
Bill
Demand
KVAR
Hours
Code
ACTL
389
389 KWHS
389KWHS
389 KWHS
389 KWHS
389 KWHS
389 KWHS
389 KWHS
@
@
@
@
@
@
@
Amount
$7.25
$33.28
$1.80
$.00
S2.83CR
$.66CR
S.15CR
$1.04
For information, emergencies, to report an outage or for changes to your account, please call 1-880-225-5773.
When paying in person, please present both portions. When mailing remittance, please mail to Puget Sound Energy, BOT-01H, P.O. Box 91269, Bellevue, WA 98009-9263
PROGRESSIVE
P.O, BOX 31260
TAMPA, FL 33631
PRO G RESSIVE'
DIRECT
015717
JASON W SHIPMAN
JASON W SHIPMAN
9306 116TH STE
PUYALLUP, WA 98373
Page 1 of 1
Online Service
progressive.com
Customer Service
1-800-776-4737
Final Bill
Please note that you no longer have insurance with us, effective February 28, 2010.
Your policy canceled because we did not receive your payment by its due date. However, there is still a balance due on
your canceled term. Please see your payment summary below for more information. Please know that your payment will
satisfy the amount that is past due, but it will not reinstate your policy. Failure to pay the amount owed by the due date
may result in your referral to a collections agency.
Total
Total amount paid
Total amount due
Due date :
If you have any questions, please call Customer Service.
$324.00
-228.03
$95.97 f a (
Y: ^ U p o n receipt
E-
ijl,
.
/ ^
Q w e s t.- ^ S p i r i t o1 S e r v i c e *
Confirmation Number:
Qwest
P.0, BOX 2619
Omaha NE 68103-2560
Confirm Notice
10031512573
253-845-2268-373
AB 01 007522 62892 H 28 B
JENNIFER SHIPMAN
PO BOX 167
MCKENNA WA 98558-0167
0075221/1
CONFIRMATION NOTICE
Thank you for using the Qwest Electronic Funds Transfer Payment option.
On March 15, 2010 you authorized Qwest to automatically withdraw funds in the amount of $150.02
from your financial institution's checking account. This authorization includes a $146.02
payment that w ill be credited to your Qwest telephone account number 253-845-2268-373,
and a $4,00 convenience fee.
If you have any questions regarding this information, please call our Customer Service Center at
1-800-244-1111.
Revised Closing
Statement
Qwesc
S p irit o f Service
i'i:!<::
Phone
Service
Why settle for simple Internet 'Mien you can get more?
Qwest High-Speed Internet offers a lot more than just
fast connection speeds. Like 99.9% network reliability.
And, extras, like automatic online back up, support
services, and security including Norton Anti-Virus.
Cal! today: 1 8 6 6 .9 6 0 .6 6 6 9 .
Internet Wireless
TV
Service
Service Service
Cali or visit qwest.com to learn more!
Important Message
This statement reflects additional charges or credits not previously billed to your account A summary of these charges and
credits is provided in this statement.
= Total Amount
Due
$5.13
Due Upon Receipt
Please fold, tear here and return the portion below with your payment.
0363141/2
JASON SHIPMAN
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 18 2010 10:59 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
MOTHER
COUNTY
FATHER
CASE NO.
F. If applicable: [ ] All health care, day care and special child rearing expenses are included in the worksheets in
Part III.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2010 page 1 of
Original
9i10AM
WORKSHEETS
Children and Ages: Hunter 9, Tyler 16
{child ages calculated using August 18, 2010)
Part I: in co m e (See Instructions, page 6)
1. Gross Monthly Income
a. Wages and Salaries
Father
Mother
$4,299.00
$6,192.00
$0.00
$0.00
c. Business Income
$0,00
$0.00
d. Maintenance Received
$0.00
$0.00
e. Other Income
$0,00
$0.00
f. Imputed Income
$0.00
$0.00
$4,299.00
$6,192,00
$670.65
$1,002.09
$328.87
$473.69
$5.00
$0.00
$54.00
$80.00
$0.00
$0.00
$0,00
$0.00
g. Maintenance Paid
$0.00
$0.00
$0.00
$0.00
$1,058,52
$1,555.78
$3,240.48
$4,636.22
(presumptive)
41.14%
58.86%
$780.02
$1,115.98
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$780.02
$1,115.98
b. Is Monthly Net Income Less Than Self-suDDort Reserve? If ves, for that
parent enter the presumptive $50 per child.
c. Is Monthly Net Income Greater Than Self-support Reserve? If ves, for each
parent subtract the self-support reserve from line 3. If that amount is less than
line 7, enter that amount or the presumptive $50 per child, whichever is greater
9. Each parent's basic support obligation after calculating applicable limitations.
For each parent enter the lowest amount from line 7, 8a - 8c. but not less than
the presumptive $50 per child.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2010 page 2 of
Part III: Health Care, Day Care, and Special Child Rearing Expenses
Mother
$0,00
$0.00
$0,00
$0.00
c. Total Monthy Health Care Expenses (line 10a plus line 10b)
$0.00
$0.00
$0.00
$0.00
b. Education Expenses
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$780.02
$1,115,98
$0.00
$0.00
$0.00
$0.00
e. Total Day Care and Special Expenses (add lines 11a through 11 d)
12. Combined Monthly Total of Day Care and Special Expenses
(add parent's day care and special expenses from line 11 e)
1
13. Total Health Care, Day Care, and Special Expenses
(line 10d plus line 12)
14, Each Parent's Obligation for Health Care, Day Care, and Special Expenses
(multiply each number on line 6 by line 13)
$0.00
$0.00
Part VI: Standard C alculation/P resum ptive Transfer Payment (See instructions, page 9)
17. Standard Calculation (line 15 minus 16d or $50 per child whichever is greater)
$780.02
$1,115,98
$1,458.22
$2,086,30
$195.01
$279.00
Fathers
Household
Mothers
Household
Father's
Household
Mothers
Household
25. Other Children Living In Each Household (First names and ages)
Father's signature
Mother's signature
Date
Date
City
Judge/Reviewing Officer
City
Date
This worksheet has been certified by the State of Washington Administrative Office of the Courts.
Photocopying of the worksheet is permitted.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2010 page 5 of
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
August 18 2010 10:59 AM
KEVIN STOCK
COUNTY CLERK
NO. 10-3-00961-1
Petitioner,
vs.
JASON WILLIAM SHIPMAN,
Respondent.
GENERAL INFORMATION
1.1
Age
TYLER
16
HUNTER
9
II. BASIS FOR RESTRICTIONS
2.1
'
Attorneys at Law
59201 00th Street S.W., Suite 25
Lakewood, WA 98499
(253)581-0660
2.2
3.2
SCHOOL SCHEDULE.
Upon enrollment in school, the children shall reside with the mother, except for
the following days and times when the children will reside with or be with the
other parent:
From 5:00 p.m. Friday to 7:00 p.m. Sunday every other weekend, beginning the
weekend of August 27, 2010.
3.3
3.4
3.5
SUMMER SCHEDULE.
Upon completion of the school year, the children shall reside with the mother,
except for the following days and times when the children will reside with or be
with the other parent:
Father shall have, in addition to the residential time described in paragraph 3.2,
five weeks residential time during the summer break. Father shall notify mother
by March 1 of each year which five weeks, which may or may not be
consecutive, he selects.
3.6
Each parent shall be entitled to two consecutive weeks vacation time with the
children each year, scheduled by notifying the other parent of the selected vacation time
in writing by March 1.
3.7
The residential schedule for the children for the holidays listed below is as follows:
With Mother
(Specify whether
Odd/Even/Every)
New Years Day
Martin Luther King Day
Presidents Day
Easter
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
New Years Eve
With Father
(Specify whether
Odd/Even/Every)
ODD
EVEN
ODD
ODD
EVEN
ODD
EVEN
ODD
ODD
ODD
EVEN
EVEN
EVEN
ODD
EVEN
EVEN
ODD
EVEN
ODD
EVEN
EVEN
EVEN
ODD
ODD
For purposes of this parenting plan, a holiday shall begin at 8:00 a.m. and end at
10:00 p.m.
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
3.8
The residential schedule for the children for the following special occasions is as
follows:
With Mother
(Specify whether
Odd/Even/Every)
2
3
4
5
cO
7
Mothers Day
EVERY
Fathers Day
Mothers Birthday
EVERY
Fathers Birthday
Childrens Birthdays
EVEN
*Fathers work schedule permitting.
9
3.9
11
13
14
16
17
18
3.10
20
22
23
1.
2.
3.
4.
5.
6.
7.
15
21
EVERY*
ODD*
If the residential schedule, paragraphs 3.1 - 3.8, results in a conflict where the
children are scheduled to be with both parents at the same time, the conflict shall
be resolved by priority begin given as follows, with 1 being given the highest
priority:
12
19
EVERY
For purposes of this parenting plan, a holiday shall begin at 8:00 a.m. and end at
10:00 p.m.
10
With Father
(Specify whether
Odd/Even/Every)
RESTRICTIONS.
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
3.11
TRANSPORTATION ARRANGEMENTS.
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 children between parents shall be as
follows:
Receiving parent shall provide transportation to the exchange point.
nI
PARENTING PLAN - PROPOSED
WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194
FAUBION, JOHNSON, REEDER & FRALEY, P.S.
A ttorneys at Law
5920 100th Street S.W., Suite 25
Lakewood, WA 98499
(253)581-0660
3.12
DESIGNATION OF CUSTODIAN.
The children named in this parenting plan are scheduled to reside the majority of
the time with the mother. This parent is designated the custodian of the children
solely for purposes of all other state and federal statutes which require a
designation or determination of custody. This designation shall not affect either
parents rights and responsibilities under this parenting plan.
3.13
OTHER
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 apprised 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
The children shall have reasonable telephone privileges with the parent
with whom the children are not then residing, without interference of the
residential parent.
f.
Plan/Residential Schedule). The objection must be served on all persons entitled to time
4.2
MAJOR DECISIONS.
Major decisions regarding each child shall be made as follows:
Education decisions
Non-emergency health care
Religious upbringing
4.3
joint
joint
joint
(c)
(d)
(e)
OTHER PROVISIONS
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.
<5
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________________________________
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vnai^6 r &r~sj
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For Respondent
For Petitioner
RE:
4 a B .W b
rc ^ ja v
\T T \ g / 0 | VA <L_________
|0 w
*ovcf*\
^Sfju vc)
n
Clerk:
Courtroom number: 117
Calendar:C2 - SHOW CAUSE/FAMILY LAW
txcrtrpt.pbt dJoumai_entry_showcause_report
>
9524
8 /2 5 /2 3 1 8
-00961-1
34896172
OB-25-10
PPT
5
IN THE SUPERIOR COURT OF THE STATE OF WASHING"
7
8
9
10
13
14
15
PARENTING PLAN
-TEMPORARY (PPT)
vs.
11
12
NO. 10-3-00961-1
GENERAL INFORMATION
1.1
16
proposed by Respondent Father
17
18
19
20
Name
Age
21
TYLER
16
22
HUNTER
23
24
25
2.1
9524
I
2
3
2.2
5
III.
3.1
8
9
RESIDENTIAL SCHEDULE
3.2
10
SCHOOL SCHEDULE.
Upon enrollment in school, the children shall reside with the mother, except for
the following days and times when the children will reside with or be with the
other parent:
11
12
From 5:00 p.m. Friday to 7:00 p.m. Sunday every other weekend, beginning the
weekend of Awgust-27, 2010. ^
mu
V b cxd loJU
13
14
3.3
^
*
h> ( K <
SCHEDULE FOR WINTER VACATION1
r^
15
The winter vacation shall be split equally between the parents, with the father
having the first half in even-numbered years and the mother having the first half
in odd-numbered years.
16
17
18
3.4
19
20
21
22
3.5
SUMMER SCHEDULE.
Upon completion of the school year, the children shall reside with the mother,
except for the following days and times when the children will reside
with the other parent:
23
24
25
U
scu x A
s ivJX vJ)
0uiJ(
..
I V t C
, -Ft*.
Uj U ^
A ttorneys at Law
HaMjs'
7/
v i> |
9524
I
2
3
Tfcr^^UATATlON WITH PA1
f t
(V I
3.7
The residential schedule for the children for the holidays listed below is as follows:
10
With Mother
(Specify whether
Odd/Even/Every)
11
With Father
(Specify whether
Odd/Even/Every)
12
13
14
15
16
17
18
19
20
ODD
EVEN
ODD
ODD
EVEN
ODD
EVEN
ODD
ODD
ODD
EVEN
EVEN
EVEN
ODD
EVEN
EVEN
ODD
EVEN
ODD
EVEN
EVEN
EVEN
ODD
ODD
For purposes of this parenting plan, a holiday shall begin at 8:00 a.m. and end at
10:00 p.m.
21
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
22
23
3.8
24
The residential schedule for the children for the following special occasions is as
follows:
25
1
With Mother
(Specify whether
Odd/Even/Every)
3
4
5
6
With Father
(Specify whether
Odd/Even/Every)
EVERY
Mothers Day
Fathers Day
EVERY
Mothers Birthday
Fathers Birthday
EVEN
Childrens Birthdays
^Fathers work schedule permitting.
EVERY
EVERY*
ODD*
For purposes of this parenting plan, a holiday shall begin at 8:00 a.m. and end at
10:00 p.m.
9
10
3.9
11
If the residential schedule, paragraphs 3.1 - 3.8, results in a conflict where the
children are scheduled to be with both parents at the same time, the conflict shall
be resolved by priority begin given as follows, with 1 being given the highest
priority:
12
13
14
1.
2.
3.
4.
5.
6.
7.
15
16
17
18
19
3.10
20
21
22
23
24
25
RESTRICTIONS.
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
3.11
TRANSPORTATION ARRANGEMENTS.
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 children between parents shall be as
follows:
Receiving parent shall provide transportation to the exchange point.
9524
8 ^ 2 5 2 :2 0 1 :3
1
2
3
3.12
DESIGNATION OF CUSTODIAN.
The children named in this parenting plan are scheduled to reside the majority of
the time with the mother. This parent is designated the custodian of the children
solely for purposes of all other state and federal statutes which require a
designation or determination of custody. This designation shall not affect either
parent's rights and responsibilities under this parenting plan.
5
6
7
3.13
OTHER
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 apprised 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
10
11
12
13
14
15
16
17
The children shall have reasonable telephone privileges with the parent
with whom the children are not then residing, without interference of the
residential parent.
18
19
20
21
22
23
24
25
f.
9bZ4
t t ^ b z . 2 g ; l 'i
1
2
3
4
This is a summary only. For the full text, please see RCW 26.09.430 through 26.09.480.
6
7
8
9
10
11
12
13
14
15
16
17
18
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 2 1 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.
19
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.
20
Failure to give the required notice may be grounds for sanctions, including contempt.
21
22
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.
23
24
25
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
PARENTING PLAN TEMPORARY - 6
WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194
3 L- Z 4
H /Z b /Z B lfl
I
2
3
4
5
6
7
8
9
10
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.
WARNING: VIOLATION OF THE 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.40.070(2). VIOLATION OF THIS ORDER MAY SUBJECT VIOLATOR TO
ARREST.
11
IV. DECISIONMAKING
12
13
4.1
Each parent shall make decisions regarding the day-to-day care and control of
each child while the child is residing with that parent. Regardless of the
allocation of decision making in this parenting plan, either parent may make
emergency decisions affecting the health or safety of the children.
14
15
16
17
4.2
MAJOR DECISIONS.
18
19
Education decisions
Non-emergency health care
Religious upbringing
20
21
4.3
joint
joint
joint
22
23
24
25
Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2
above.
V. DISPUTE RESOLUTION
Disputes between the parties, other than child support disputes, shall be
submitted to:
PARENTING PLAN TEMPORARY - 7
WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194
1
2
3
The cost of this process shall be allocated between the parties as follows:
4
5
6
7
based on each partys proportional share of income from line 6 of the child
support worksheets.
The counseling, mediation, or arbitration dispute resolution process shall be
commenced by notifying the other party by written request, certified mail/return
receipt.
8
9
10
11
12
(c)
13
14
(d)
15
16
(e)
17
18
VII.
22
VIII.
23
24
25
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 RCW 9A.40.070(2). Violation of this
9524
8 /25/2:918
1
2
3
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.
5
6
7
8
9
10
If a parent fails to comply with a provision of this plan, the other parent=s
obligations under the plan are not affected. Before signing the final parenting
plan, the court consulted the judicial information system and databases, if
available, to determine the existence of any information and proceedings that are
relevant to the placement of the children.
DONE IN OPEN COURT this
2010.
11
12
13
14
COMMISSIONER
PRESENTED BY:
FAUBION, JOHNSON
15
16
17
18
19
CLim^PfJOHNSQ
Of Attorneys for R
D IA N A LY N N K IE S E L
C O U R T C O M M IS S IO N E R
14794
TRY WAIVED
GREENE & LLOYD, PLLC
20
21
22
23
24
25
9524
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1
2
10-3-00961-1
34 896178
TMORSW
08-25-10
3
4
5
6
1
In re the Marriage of:
8
No. 10-3-00961-1
JENNIFER KAY SHIPMAN,
Petitioner,
and
10
Respondent.
Clerks Action Required
12
I. Judgment Summary
1.1
14
[]
15
A.
B.
C.
16
17
18
19
20
11
13
D.
E.
F.
G.
H.
I.
J.
K.
L.
21
22
23
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
5524
1.2
3
4
D.
E.
F.
G.
H.
I.
J.
K.
5
6
7
8
48
[]
[]
A.
B,
C.
8^ 25 /2 8 1 8
%per annum
II. Basis
9
2.1
Type of Proceeding
10
This order is entered under a petition for dissolution of marriage or domestic partnership, legal
separation, or declaration concerning validity:
11
[]
[]
[X ]
[]
t]
[]
12
13
14
15
2.2
16
17
2.3
Other
18
19
20
21
22
23
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
3S24
8 /2 5 /2 3 1 8
1
III. Findings and Order
2
3
It Is Ordered:
3.1
Name (first/last)
Age
TS
15
HS
6
7
8
9
10
II
12
13
14
3.2
15
For purposes of this Order of Child Support, the support obligation is based upon the following
income:
16
A.
17
18
19
B.
[]
9524
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1
OR
2
C.
[]
4
5
6
[]
[]
[]
7
8
[]
9
10
11
12
[]
13
[]
Other:
14
15
3.3
16
17
18
19
20
The Obligee Must Immediately File With the Court and the Washington
State Child Support Registry and Update as Necessary the Confidential
Information Form Required by RCW 26.23.050.
21
22
23
SSZ4
8 /2 5 /2 8 1 3
1
2
For purposes of this Order of Child Support, the support obligation is based upon the following
income;
^
A.
[x ]
4
5
B.
[]
6
7
8
9
10
OR
11
C.
[]
12
[]
[]
[]
13
14
15
17
[]
[]
[]
18
[]
16
19
[]
t]
Other:
9524
8**25^2818
1
The obligor may be able to seek reimbursement for day care or special child rearing expenses not
actually incurred. RCW 26.19.080.
2
3
4
5
6
3.4
Service of Process
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 7310G3
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
9524
3.5
8 /2 5 ^ 2 0 1 3
The obligor parent shall pay the following amounts per month for the following child(ren):
Name
TS
HS
Amount
$_____
$_____
5
6
[]
The parents combined monthly net income exceeds $12,000 and the court sets child
support in excess of the presumptive amount for $12,000 because:
[]
The court finds that the obligors child support obligations owed for all his or her
biological or legal children exceeds 45% of his or her net income and it is [ ] just
[ ] unjust to apply the 45% limitation based upon the best interests of the children) and
the circumstances of each parent as follows:
[]
If one of the children changes age brackets, the child support shall be as follows:
[]
[]
[]
Other:
8
9
10
11
12
13
14
15
16
17
18
19
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49;
1
2
3
3.6
1&D.WL
$~7z.&4 per month. (See Worksheet line 17.)
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Standard C a lc u la tio i/
3.7
[x ] The child support amount ordered in paragraph 3.5 does not deviate from the standard
calculation.
[ ] The child support amount ordered in paragraph 3.5 deviates from the standard calculation for
the following reasons:
[} Income of a new spouse or new domestic partner of the parent requesting a deviation for
other reasons;
[ ] Income of other adults in the household of the parent requesting a deviation for other
reasons;
[ ] Child support actually paid or received for other child(ren) from other relationships;
[ ] Gifts;
[ ] Prizes;
[ ] Possession of wealth;
[ ] Extraordinary income of children);
[ ] Tax planning which results in greater benefit to the child(ren);
[ ] Income from overtime or second jobs that was excluded from income of the parent
requesting a deviation for other reasons;
[ ] A nonrecurring source of income;
[ ] Extraordinary debt not voluntarily incurred;
[ ] A significant disparity in the living costs of the parents due to conditions beyond their
control;
[ ] Special needs of disabled child(ren);
[ ] Special medical, educational, or psychological needs of the children);
[ ] The child(ren) spend(s) a significant amount of time with the parent who is obligated to
make a support transfer payment. The deviation does not result in insufficient funds in
the receiving parents household to meet the basic needs of the child(ren). The
children) do(es) not receive public assistance;
[ ] Children) from other relationships;
[ ] Costs incurred or anticipated to be incurred by the parents in compliance with courtordered reunification efforts or under a voluntary placement agreement with an agency
supervising the children);
[ ] The obligor has established that it is unjust to apply the presumptive minimum payment
of $50.00 per child;
[ ] The obligee has established that it is unjust to apply the self-support reserve.
22
[ ] Other reason(s) for deviation:
23
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S, Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
9524
S /2S ^ 2B 18
496214
3.8
[]
[x ]
[]
3.9
Starting Date:
Day(s) of the month support is due:
3.10
[]
[]
3.11
Enforcement and collection: The Division of Child Support (DCS) provides support
enforcement services for this case because: [ ] this is a public assistance case, [] this is
a case in which a parent has requested services from DCS, [ ] a parent has signed the
application for services from DCS on the last page of this support order. (Check all
that apply.) Support payments shall be made to:
Washington State Support Registry
P. O. Box 45868
Olympia, WA 98504
Phone: l-800-922-4306 or
I-800-442-5437
[]
Payment services only: The Division of Child Support will process and keep a record of
all payments but will not take any collection action. Support payments shall be made to:
Washington State Support Registry
P. O. Box 45868
Olympia, WA 98504
Phone: 1-800-922-4306 or
1-800-442-5437
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
9524
[]
8^ 2 5 /2 8 1 8
3
A party required to make payments to the Washington State Support Registry will not receive
credit for a payment made to any other party or entity. The obligor parent shall keep the registry
informed whether he or she has access to health insurance coverage at reasonable cost and, if so,
to provide the health insurance policy information.
4
5
Any time the Division of Child Support is providing support enforcement services under
RCW 26.23.045, or if a party is applying for support enforcement services by signing the
application form on the bottom of the support order, the receiving parent might be required to
submit an accounting of how the support, including any cash medical support, is being spent to
benefit the children).
6
7
8
9
10
11
12
13
3.12
Withholding action may be taken against wages, earnings, assets, or benefits, and liens enforced
against real and personal property under the child support statutes of this or any other state,
without further notice to the obligor parent at any time after entry of this order unless an
alternative provision is made below:
[If the court orders immediate wage withholding in a case where Division of Child Support does
not provide support enforcement services, a mandatory wage assignment under Chapter 26.18
RCW must be entered and support payments must be made to the Support Registry.]
[]
14
15
the parties have reached a written agreement that the court approves that
provides for an alternate arrangement.
[]
the Division of Child Support provides support enforcement services for this
case [see 3.11] and there is good cause [as stated below under "Good Cause"]
not to require immediate income withholding which is in the best interests of the
child(ren) and, in modification cases, previously ordered child support has been
timely paid.
[]
the Division of Child Support does not provide support enforcement services for
this case [see 3.11] and there is good cause [as stated below under "Good
Cause] not to require immediate income withholding.
16
17
18
19
20
21
Good Cause:
22
23
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
9524
8 ^ 2 5 /2 0 1 8
1
3.13
[x ]
[]
5
[]
6
[]
7
[]
8
9
[]
3.14
10
provided that this is a temporary order, until a subsequent child support order is entered
by this court.
until the children) reach(es) the age of 18 or as long as the child(ren) remain(s) enrolled
in high school, whichever occurs last, except as otherwise provided below in Paragraph
3.14.
until the child(ren) reach(es) the age of 18, except as otherwise provided below in
Paragraph 3.14.
after the age of 18 for (name)___________________________ who is a dependent
adult child, until the child is capable of self-support and the necessity for support ceases.
until the obligation for post secondary support set forth in Paragraph 3.14 begins for the
child(ren).
Other:
12
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.
The parents shall pay for the post secondary educational support of the child(ren). Post
secondary support provisions will be decided by agreement or by the court.
No post secondary educational support shall be required.
13
[]
11
14
15
16
17
18
3.15
[]
Does not apply because all payments, except medical, are included in the transfer
The petitioner shall pay
% and the respondent M J f
%(each parents
proportional share of income from the Child Support Schedule Worksheet, line 6) of the
Vn
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23
iff/J
.)
A/i
thCT: U r '
$(LfnCO
Payments shall be made to [ ] the provider of the service [ ] the parent receiving the
transfer payment.
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21
fa itx v A
[]
The obligor shall pay the following amounts each month the expense is incurred on
behalf of the child(ren) listed in Paragraph 3.1:
[]
day care: $
parent;
^524
[]
[]
[x ]
8 /2 5 /2 0 1 0
5
3.16
6
7
[x ]
[]
[]
Other:
8
9
10
3.17
11
12
The parents shall sign the federal income tax dependency exemption waiver.
Other:
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3.18
Each parent shall provide health insurance coverage for the child(ren) listed in paragraph 3.1, as
follows:
16
3.18.1 Health Insurance (either check box A, or complete sections B and C. Section D
17
18
19
A. [ ] There is insufficient evidence for the court to determine which parent must provide
coverage and which parent must contribute a sum certain. Therefore, the court is not
specifying how insurance coverage shall be provided. The petitioners and respondents
medical support obligations may be enforced by the Division of Child Support or the
other parent under RCW 26.18.170 as described in paragraph 3.18.2, below.
OR
B.
9524
[]
[]
Insurance coverage for the child(ren) is available but not accessible to:
[ ] the petitioner at $________ cost (child(ren)s portion of the premium, only) and/or
[ ] the respondent at $___________cost (child(ren)s portion of the premium, only).
[]
Neither parent has available or accessible insurance through an employer or union; but:
[ ] the petitioner is able to provide private coverage at a cost not to exceed 25% of the
petitioners basic support obligation; and/or
[ ] the respondent is able to provide private coverage at a cost not to exceed 25% of the
respondents basic support obligation.
f]
Both parties have available and accessible coverage for the child(ren). The court finds
that:
[ ] the petitioner, or
[ ] the respondent
has better coverage considering the needs of the child(ren), the cost and extent of each
parents coverage, and the accessibility of the coverage.
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3
4
5
6
7
8
9
10
AND
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C.
Parties obligations (check the option(s) that apply for each parent):
(i)
Petitioner shall:
a.
[]
b.
[]
c.
[ ]
d.
[]
Pay $_______ towards the health insurance premium being paid by the
other parent (petitioners proportionate share of the premium, not to
exceed 25% of the petitioners basic support obligation). This payment
is only required if the petitioner is not providing insurance as described
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S /2 5 ^ 2 B lg
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9524
8 ^ 2 5 /2 8 1 8
<
above.
1
e.
[x ]
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4
5
6
7
8
(ii)
Respondent shall:
a.
[x ]
b.
[ ]
c.
[ ]
d.
[ ]
e.
[ ]
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18
19
20
21
D.
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If the child(ren) are receiving state financed medical coverage, the Division of Child
Support may enforce the responsible parents monthly premium.
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
'9524
8^25 ^zase
I
The parent(s) shall maintain health insurance coverage, if available for the child(ren)
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.
2
3
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.
4
5
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 20 days of the entry
of this order to the other parent or the Washington State Support Registry if the parent
has been notified or ordered to make payments to the Washington State Support
Registry.
6
7
8
If proof that health insurance coverage is available or not available is not provided within
20 days, the parent seeking enforcement or the Department of Social and Health Services
may seek direct enforcement of the coverage through the other parents employer or
union without further notice to the other parent as provided under Chapter 26.18 RCW.
9
10
11
A parent required to provide health insurance coverage must notify both the Division of Child
Support and the other parent when coverage terminates.
12
If the parents circumstances change, or if the court has not specified how medical support shall
be provided, the parents medical support obligations will be enforced as provided in
RCW 26.18.170. If a parent does not provide proof of accessible coverage for the children)
through private insurance, a parent may be required to satisfy his or her medical support
obligation by doing one of the following, listed in order of priority:
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17
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A parent seeking to enforce the obligation to provide health insurance coverage may apply for
support enforcement services from the Division of Child Support; file a motion for contempt (use
form WPF DRPSCU 05.0100, Motion/Declaration for an Order to Show Cause re Contempt); or
file a petition.
20
21
22
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3.19
Both parents have an obligation to pay their share of uninsured medical expenses.
Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Pax (253) 770-0259
9524
The petitioner shall pay 54.3% of uninsured medical expenses (unless stated otherwise,
the petitioners proportional share of income from the Worksheet, line 6) and the
respondent shall pay 45.7% of uninsured medical expenses (unless stated otherwise, the
respondents proportional share of income from the Worksheet,
line 6).
1
2
3
4
8/2 S /-2 0 f*
3.20
[]
n
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7
n
[]
n
8
9
10
^ C ^ A p th e r: ^
for back
0/Y ^
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3.21
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[]
[]
[]
[]
[]
[]
[]
Other:
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3.22
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[]
[]
[]
.9524
0225/Z ei*.
1
2
[]
[]
[]
[]
Other:
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7
3.23
O ther
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-\o i &
Dated:
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Jttfkje/C m m issioner
Presented by:
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Si
16
Print Name
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[]
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I apply for full support enforcement services from the DSHS Division of Child Support (DCS).
(Note: If you never received TANF, tribal TANF, or AFDC, an annual $25 fee applies if over
$500 is disbursed on a case, unless the fee is waived by DCS.)
Signature of Party
[]
Approval required in Public Assistance cases. The DSHS Division of Child Support received
notice required by RCW 26,23A30. This order has been reviewed and approved as to:
[]
[]
[]
[]
9S24
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Law Offices of Greene & Lloyd, PLLC
Street: 4115 S. Meridian
Mailing: P.O. Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
498
9524
8 /2 5 /2 8 .1 8
498224
MOTHER
COUNTY
FATHER
CASE NO.
E.
F. If applicable: [ ] All health care, day care and special child rearing expenses are included in the worksheets in
P artlllWSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2010 page 1 of
Original
9:10AM
WORKSHEETS
Children and Ages: Hunter 9, Tyler 16
(child ages calculated using August 18, 2010)
Father
Mother
$4,299.00 j
$6,192.00
$0.00
$0.00
c. Business Income
SO. 00 j
$0.00
$0.00
$0.00
e. Other Income
$0.00
$0.00
f. Imputed Income
$0.00
$0.00
$4,299.00
$6,192.00
$670.65
$1,002.09
$328.87
$473.69
d. Maintenance Received
'
$5.00
$0.00
$54.00
$80.00
$0.00
$0.00
$0.00
$0.00
g. Maintenance Paid
$0.00
$0.00
$0.00
$0.00
$1,058.52
$1,555.78
$3,240.48
$4,636.22
$7,876.70
$848
Tyler
$1,048
$1,896.00
(presumptive)
58.86%
41.14%
$780.02
$1,115.98
b. Is Monthly Net Income Less Than Self-support Reserve? If yes, for that
parent enter the presumptive $50 per child.
c. Is Monthly Net Income Greater Than Self-support Reserve? If yes, for each
parent subtract the self-support reserve from line 3. If that amount is less than
line 7, enter that amount or the presumptive $50 per child, whichever is greater
9. Each parent's basic support obligation after calculating applicable limitations.
For each parent enter the lowest amount from line 7, 8a - 8c. but not less than
the presumptive $50 per child.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2010 page 2 of
$1,128.00
$ 0.00
$ 0.00
$0.00 j
$0.00
$0.00
$0.00
$780.02
$1,115.98
D'' 3 / O IO
Part 111: Health Care, Day Care, and Special Child Rearing Expenses
Mother
$0.00 ;
$0.00
$0.00
$0.00
c. Total Monthy Health Care Expenses (line 10a plus line 10b)
$0.00
$0.00
$0.00 S
$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 11a through 11 d)
12. Combined Monthly Total of Day Care and Special Expenses
(add parent's day care and special expenses from line 11e)
13. Total Health Care, Day Care, and Special Expenses
(line 10d plus line 12)
1
1
$0.00
$0.00
'
$0.00
$0.00
$780.02
$1,115.98
$0.00
$0.00
$0.00
$0.00
14. Each Parent's Obligation for Health Care, Day Care, and Special Expenses
(multiply each number on line 6 by line 13)
Part IV: Gross Child Support O bligation
15. Gross Child Support Obligation (line 9 plus line 14)
Part V: Child Support Credits
$0.00
$0.00
Part VI: Standard C alculation/Presum ptive Transfer Payment (See instructions, page 9)
17. Standard Calculation (line 15 minus 16d or $50 per child whichever is greater)
$780.02
$1,115.98
$1,458.22 j
$2,086.30
i
$195.01 j1
$279.00
,0 1*1 q y s z x ,'
a. Real Estate
b. Investments
F ather's
H ousehold
i
i
e. Retirement Accounts
f. Other (describe)
21. Household Debt (List liens against household assets, extaordfnary debt)
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 second jobs the party is
asking the court to exclude per instructions, page 10
d. Income of Children (If considered extraordinary)
Name
Name
e. Income From Child Support
i
j
Name
Name
Program
Program
g. Other Income (describe)
Mother's
Household
This worksheet has been certified by the State of Washington Administrative Office of the Courts.
Photocopying of the worksheet is permitted.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2010 page 5 of
9524
8 /25/28:18
498223
II. Basis
A motion for a temporary order was presented to this court and the court finds reasonable cause to issue
the order.
III. Order
It is Ordered:
3.1
Restraining Order
Previous Order
9524
B -S Z S S 2 9 1&
498238
[X ]
Temporary Relief
Child support shall be paid in accordance with the order of child support, signed by the
court.
The parties shall comply with the Temporary' Parenting Plan signed by the court.
Each party' shall be immediately responsible for their own future debts whether incurred by
credit card or loan, security interest or mortgage.
Date /
Vl
I
Print or TypeNdme
Date
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
October 15 2010 11:55 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
Please take notice that an issue of law in this case will be heard on the date and time shown below:
P ierce C o u n ty S u p e rio r C o u rt, C o u n ty -C ity B uilding - 930 T a c o m a A v e S - T aco m a , W A 9840 2
Show Cause
N a tu re o f H earin g:
Contempt
DA TED :
S ign ed :
NA M E:
CLINT P. JOHNSON
Phone:
(253) 581-0660
W SBA#:
14794
LAKEWOOD, WA 98499-2751
For:
1 of
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
KEVIN S TOCK
COUNTY LERK
NO: 10-3-D0961-1
5
6
7
8
10
11
12
13
NO. 10-3-00961-1
Respondents Attachment to
Motion
vs.
JASON WILLIAM SHIPMAN,
Respondent.
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Clint Johnson
From:
Sent:
To:
Subject:
3-00961-1
35213191
MTSC
C O U N T ^ c l e r K' S
10-18-10
o p p ,c e
J
A' -
0 C r l 5 2010
p .m.
4
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NO. 10-3-00961-1
MOTION AND DECLARATION
TO SHOW CAUSE RE
CONTEMPT/JUDGMENT
AND FOR OTHER RELIEF
(MTSC)
vs.
JASON WILLIAM SHIPMAN,
Respondent.
13
14
I. MOTION
15
16
KAY SHIPMAN to appear personally before the court and show cause why an
17
18
19
1.1
20
21
22
23
1.2
FINDING CONTEMPT.
ESTABLISHING A JUDGMENT.
24
Does not apply.
25
MOTION AND DECLARATION TO
SHOW CAUSE RE CONTEMPT/
JUDGMENT (MTSC)- 1
WPF DRPSCU 05.0100 (6/2008)
RCW 26.09.160
ORIGINAL
1
2
3
4
1.3
5
6
GRANTING SANCTIONS.
Does not apply.
1.4
OTHER:
7
That paragraph 3.2 of the Temporary Parenting Plan entered August 24, 2010, be
8
9
10
11
12
13
14
15
FAUBION, JOHN SOI
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II. DECLARATION
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1
2
3
payments and make best efforts to protect the community's equity in the family home
5
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7
family home, and despite requests to comply she has chosen to ignore the court order.
8
9
Petitioner is a registered nurse, has ample income to pay the mortgage, and states,
10
within her own financial declaration filed March 15. 2010, she has the ability to pay; she
11
has chosen not to do so. Her financial declaration states she has living expenses of
12
$4,750.96. These living expenses are to include making the mortgage payment.
33
14
According to the temporary support order, her net earnings are $4,636.22. With the
$780.02 child support I pay her, she has a monthly income of $5,416.24. She has the
15
16
17
means to meet the mortgage obligation easily and there is absolutely no reason for her to
miss the $ 1,670 mortgage payments.
18
On the weekend of October 2-3 Petitioner moved out of the house and relocated
19
into an apartment across town, without notice to me. Quite frankly, she never intended
20
to make the mortgage payment. Texts that she has sent in the past confirm her attitude
21
and her intention not to comply with the court order. Attached is a text she sent me on
22
May 20, 2010. She consistently tells me the same thing when she does communicate
23
24
25
with me. She will say that 1 have not cooperated in assisting in some sort of loan
modification. That is not true. She has not communicated with me to even inform me
of what she is doing and what attempts she may have made in dealing with mortgage
MOTION AND DECLARATION TO
SHOW CAUSE RE CONTEMPT/
JUDGMENT (MTSC)- 3
WPF DRPSCU 05.0100 (6/2008)
RCW 26.09.160
10 294
itt
1
2
3
4
5
6
7
spend time with their cousins, who happened to be visiting their parents on a different
8
9
schedule, and the rest of my family. The court was willing to make that change, except
10
that Petitioner asserted she was unable to change her alternating-weekend work
11
schedule. The court order in Parenting Plan paragraph 3.2 required her to provide proof
12
that she could not change her work schedule. A copy of the notice she provided is
13
14
attached. However, as it turns out, she was able to take the weekend of October 2 and 3
off to move, so clearly she can change her schedule, contrary to the letter she obtained
15
16
17
18
from her employer. I would therefore ask the court to invoke the provisions of
paragraph 3.2 and allow the reversal of the weekends, as I previously requested.
I am asking for attorney fees and costs in the amount of $1,500, for the necessity
19
of bringing this motion, and an order to bring the mortgage current. I ask that she be
20
ordered to make the September through November mortgage installments within ten (10)
21
days, and that she make arrangements to bring the mortgage completely current within
22
ninety (90) days of entry of this order.
23
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I declare under penalty of perjury under the laws of the State of Washington that
25
MOTION AND DECLARATION TO
SHOW CAUSE RE CONTEMPT/
JUDGMENT (MTSC)- 4
WPF DRPSCU 05.0100 (6/2008)
RCW 26.09.160
1
2
3
, 2010.
5
JAgON' SHIPMAN
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5920 100t h
(253)581-0660
25
ORTSC
10-3-00961-1
10- 18-10
1
2
3
FILED
OCT 1 5 2010
a.m.
p.m,
7
8
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
9
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and
Petitioner,
13
14
15
Respondent.
16
17
IT IS ORDERED:
That JENNIFER KAY SHIPMAN shall appear in person before this court at
18
19
the place and time below and show cause why the relief requested in the Motion
20
21
Date:
December 6, 2010
22
Time:
9:30 a.m.
23
Place;
24
25
26
ORIGINAL
FAUBION, JOHNSON,
REEDER & FRALEY, P.S
5920 100th Street SW
Suite 25
Lakewood, WA 98499
(253) 581-0660
10294
If you disagree w ith any part of the motion, you m ust respond to the motion
in w riting before the hearing and by the deadline for your county. A t the
Oral testim ony may NOT be allowed. To respond you must: (1) file your
docum ents with the court; (2) provide a copy of those docum ents to the
copies of your docum ents (or have the other party served if that party does
not have an attorney); and (4) com plete your filing and service of documents
within the tim e period required by the local court rules in effect in your
10
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12
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16
day of
2010
17
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S50GE / COMMISSIONER
^
iIN COUNTY
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Presented by:
FAUBION, JOHNSON, REEDER
& FRALEY, P.S.
22
mi.
CLERK'S OFFICE
OCT 1 5 2010
p.m
BY,V-.
23
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BY___________________________
CLINT P. JOHNSON, WSBA14794
Attorney for Respondent
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Page 2
WPF DRPSCU 005.0150 (6/2008)
RCW 26.09.160
FAUBION, JOHNSON,
REEDER & FRALEY, P.S.
5920 100th Street SW
Suite 25
Lakewood, WA 98499
(253) 581-0660
x !3 i&
&0193
The undersigned states that I am a citizen of the United States and of the State of Washington, over the
age of eighteen years, not a party to the above entitled action, competent to be a witness therein, and
was at all times herein mention. I effected service as indicated below:
[a] Number of copies served: One(l)
[b] Title of Papers served: Note for Commissioners Calendar, Motion and Declaration to Show
Cause re: Contempt/Judgment and for Other Relief, Respondents Attachment to Motion and Sealed
Financial Documents.
[c] Date and Time of Service: October 27,2010 at 5:00 P.M.
[d] Person (s) to be served:
[e] Place of Service:
4102 S. Meridian
Puyallup, WA 98373
D E C L A R A T IO N O F SE R V IC E
Page 1
11316
FEES: Service $10.00 Rush: $00.00 Miles: $41.60 Misc: $ 14.00 TOTAL: $65.60
D EC LA RA T tO N O F SE R V IC E
P age 2
68134
1 0 ?9 i
1 1 ^ 2 4 /2 0 1 0
190652
1
10-3-0096 M
35427006
NTWSUB
11-24-10
" cou" cL
&
NOV 1 9 2010 P8
0FF1CE
^ ^ s a s a a -
gPUTY
6
7
10
11
No.
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and
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Respondent.
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TO:
AND TO:
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10-3-00961-1
Petitioner,
YOU AND EACH OF YOU PLEASE TAKE NOTICE that CLINT P. JOHNSON, has
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l 7 9 i
ii/2 4 /2 0 1 0
1900S3
1
COPIES OF ALL FURTHER PAPERS AND PROCEEDINGS herein, except
2
original process, should be served on the substituted Attorney of Record along with all
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5
/9
day of
________ , 2010.
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E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
November 30 20'
KEVIN ST
COUNTY C
NO: 10-3-0
2
3
4
5
6
In re th e M arriage of:
No. 10-3-00961-1
JE N N IF E R KAY SH IPM A N
9
Declaration of
Counsel fo r Petitioner
In Opposition to
R espondents Motion
and Declaration to
Show Cause Re:
C ontem pt/Judgm ent
And fo r O ther Relief
P etitio n er(s),
an d
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11
JA S O N W ILLIAM SH IPM A N
R espondent(s).
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w orse a n d w hich im plies she h a s b een u n d e r a doctors care for th e illness. She in d icates in
th e e-m ail th a t she w ill be g ettin g a doctors note re g a rd in g h e r illness.
22
23
1
2
5
6
26 W n. App. 843, 615 P .2d 508 (1980). F a ilu re to p ay debts or lien s is n o t a n ap p ro p ria te
issu e for co n tem p t proceedings. Corrigeux v. Corrigeux, 37 W n. 2d 403, 224 P .2d 343
(1950); State ex rel. Foster v. Superior Court, 193 W ash. 99, 102, 74 P .2d 479 (1937).
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ATTACHMENT:
NOVEMBER 30, 2010 E-MAIL FROM
JENNIFER SHIPMAN TO DECLARANT
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Page 1 of 1
(No Subject)
From: [email protected]
Sent: Tue 11/30/10 9:07 AM
To: Tim greene ([email protected])
Hi Tim,
I did get your voicemails last night. I have been sick these last couple of
weeks, but I'm not getting better I'm getting worse. Because of that I
haven't been able to get everything ready for you. You mentioned that you
could ask for another date. That would be great. I will see my doctor, again,
and get a note saying I have been ill.
Thanks,
Jennifer Shipman
Sent from my Verizon Wireless BlackBerry
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11/30/2010
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
November 30 20'
KEVIN ST
COUNTY C
NO: 10-3-0
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) Case No.: 10-3-00961-1
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) DECLARATION OF SERVICE
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JASON WILLIAM SHIPMAN
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___________Respondent._____________ )
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I,
Bettyann Walter
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1.
I am over the age of 18 years and not a party to this action. My business/residence address is:
P.O. Box 731063, Puyallup, WA 98373_______________________________________
2.
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(Name)
Declaration of Counsel for Petitioner In Opposition to Respondent's Motion and Declaration to Show Cause Re:
Contempt/Judgment And for Other Relief and Email Attachment
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Daniel Clark_______________
Address(es) of service:
5920 100th Street S.W., Suite 25, Lakewood, WA 98499
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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.
Signed at
(Date)
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Signature
Bettyann Walter
Type or Print Name
DECLARATION OF SERVICE
1 of 1
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
November 30 20'
KEVIN ST
COUNTY C
NO: 10-3-0
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) Case No.: 10-3-00961-1
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) DECLARATION OF SERVICE
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1.
I am over the age of 18 years and not a party to this action. My business/residence address is:
P.O. Box 731063, Puyallup, Wa 98373___________________________________________
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Daniel Cook
(Name)
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Address(es) of service:
5920 100th Street S.W., Suite 25, Lakewood, WA 98499
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4.
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
Puyallup____________ , Washington on
(Place)
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(Date)
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Signature
Bettyann Walter
Type or Print Name
DECLARATION OF SERVICE
1 of 1
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
December 02 2010 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
NO. 10-3-00961-1
Petitioner,
v.
REPLY DECLARATION
OF JASON SHIPM AN
____________________ Respondent.
I, JASON SHIPMAN, make this reply declaration on the basis of my personal
knowledge. I am the Respondent in this matter and competent to testify.
Jennifer has used the family home divisively for months. Her actions have risen to
the level of waste of a community asset. She was specifically ordered to make the
payments and attempt to protect the communitys equity in the house. Not only has she
failed to make the payments but she has failed to use any efforts to protect the community.
Jennifer and I have had marital troubles for years. After several discussions about
divorce it was decided she wanted an apartment. In October of 2009 I went to the bank to
finance the home in my name at her request. Attached as Exhibit A is a bank letter
Reply Declaration of Jason Shipman - Page 1 of 4
Shipman, Jennifer v Jason
S:\CASES1\Shipman, Jason disso'iPLEADINGS\Disso\Reply Declaration of Jason
Shipman.doc
documenting my refinance efforts. After I was approved for refinance Jennifer said no she
wanted the house and that I needed to move out.
After she told me she wanted the house I went to work in Arkansas. When 1returned
for visits I stayed with friends. In February 2010 I came back to Washington for good and
moved into a separate residence because that is what she told me to do.
During that period around the time of separation, we had several arguments where
she threatened not to pay the mortgage. She knew that was a leverage point she could use
because I wanted to keep the house. On May 21st she sent me a text saying I am not
making the house payment. ITS WAR!!!! This text message was filed with our moving
declaration.
She has not paid the mortgage since May 2010 (the month she sent the text
message). In several conversations she has said she is doing all this to hurt me. She has
also bragged to me that by living in the house for several months with no payments she has
been able to save up lots of money. I know that Jennifer lived in the house from May 2010
through August 2010 without making any house payments. I do not know exactly when she
incurred a rent payment for where she is living now but there were at least four months
when she made no house payment at all. She has thus been able to save at least $6,500 in
house payments.
At our hearing in August 2010 the court granted me residential time with the children.
The parenting plan provided that the children could attend school from my residence if I
were living close enough to their school. Within 3 days of the hearing I moved into a
residence across the street from their school and within a few blocks of the family home
where Jennifer was residing. In less than a month Jennifer moved out of the family (that she
Reply Declaration of Jason Shipman - Page 2 of 4
Shipman, Jennifer v Jason
S:\CASES1\Shipman, Jason disso\PLEADINGS\Disso\Reply Declaration of Jason
Shipman.doc
had refused to allow me to refinance, or move into myself) and all the way across town and
changed the childrens school.
1am asking the court to make her pay the mortgage as previously ordered. She
needs to make payments and turn the utilities on so we can sell the home now that she is
not living there and I am locked into a 12 month lease.
Before I left we had two agents come over and say we could sell the home.
Jennifer needs to make sure the landscaping is been done and the home is clean so it can
be shown. Jennifer has had several animals in the home including chickens (inside of the
house). It reeks of ammonia.
As far as not preparing a declaration goes this is the second time she has done this.
Using an illness" as an excuse is not fair. It did not stop her from taking my son on an
extravagant vacation in the San Juan Islands a few weeks ago. Nor did it stop her from
assaulting me on November 10, 2010.
Prior to separation Jennifer first agreed to get her own apartment and changed her
mind and refused to let me refinance the mortgage into my name alone. Jennifer then told
me I had to move out. I asked her again to move out and let me keep the home and she
refused. She asked for use of the family home in her motion and the court authorized her to
have use of the home and ordered her to make the monthly house payments. After the
hearing allowing Jennifer use of the home, I signed a 12 month lease for a rental home near
the family home so that I could have more time with the children (as the court authorized).
Jennifer then, after months of preventing me from refinancing or living in the home and
asking for use of the home herself, moved out of the home. Jennifer has used the family
home as a weapon to inflict conflict and pain in this situation. Jennifer is now allowing the
Reply Declaration of Jason Shipman - Page 3 of 4
Shipman, Jennifer v Jason
S:\CASES1\Shipman, Jason disso\PLEADINGS\Disso\Repty Declaration of Jason
Shipman.doc
only community asset of any value to depreciate and waste because of her desire to be
vindictive and spiteful. The court should find Jennifer in contempt for her willful and
intentional violation of the order. Even if contempt is not found, the court should order
Jennifer to do what is necessary to allow the house to be sold, including moving all of her
stuff out since she is no longer living there and getting the property cleaned up and in
condition for sale. Further, the court can impose financial sanctions for non-compliance with
a valid order even if contempt (and threat of incarceration) is not specifically found. At a
minimum the court should order Jennifer to pay $1,500 in attorneys fees for her actions
which necessitated this matter to be brought before the court.
Signed at
/ , 2010.
Basskof America
Home Loans
This letter is to verify that Jason Shipman applied for a refinance loan in October of 2009. Mr. Shipman
explained that he and his wife were in the process of separating and needs to refinance his current mortgage
removing Jennifer from the loan. An application was taken and a conditional approval was issued for Jason to
proceed with the refinance. In order for us to issue a full approval, Jason was to provide us with some income
and asset documentation. He was provided with a conditional approval letter and was to contact the loan officer if
he so wishes to move forward with the loan. He applied for the loan on 10/14/2009.
If you need any further information or clarification regarding the above statement, please feel free to contact me at
253-904-1081.
Sincerely
Chanthy Lodgd
Mortgage Loan Coordinator
Phone: 253-904-1081
Fax: 1.800.461.3995
Email: [email protected]
Bankof America
Home Loans
Chanffiy Lodge
Mortgage Loan Coordinator
Tel: 253.904.1081 * Fax: 800.461.3995
[email protected]
WAS-962-01-01
5605112th Street E - Ste 600, Puyallup, WA 98373
ts> Equal Housing Lender
Recycled '
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, '
December 03 20'
KEVIN ST
COUNTY C
NO: 10-3-0
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No. 10-3-00961-1
Supplem ental
Declaration of
Counsel fo r Petitioner
In Opposition to
Respondents Motion
and Declaration to
Show Cause Re:
C ontem pt/Judgm ent
And fo r O ther R elief
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1. That I am over 18 years of age and competent, and that I am the attorney for
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2. As I indicated in my November 30, 2010 declaration, Ms. Shipman has been ill recently,
and has been unable to assist me in her defense on this matter. I attached an e-mail from
Ms. Shipman to my declaration in which she indicated that she would be obtaining a note
from her doctor.
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Supplemental Declaration of Counsel
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Supplemental Declaration of Counsel
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ATTACHMENT #1:
LETTER FROM MS. SHIPMANS DOCTOR
REGARDING HER ILLNESS
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Supplemental Declaration of Counsel
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JENNIFER SHIPMAN
2323 7TH ST SE APT B203
PUYALLUP, WA 98374
Date: 11/30/10
To Whom It May Concern;
Jennifer has been ill with a persistent respiratory infection for 2-3 weeks. She has required 2 visits to
her physicians and is still ill, requiring antibiotics and other medications. She has missed several days of
work.
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ATTACHMENT #2:
LETTER FROM MS. SHIPMANS EMPLOYER
REGARDING RESCHEDULING HER WEEKENDS
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Supplemental Declaration of Counsel
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C A T H O L IC HEALTH
INITIATIVES
To W hom It M ay Concern:
Jennifer Shipman is employed at St. Clare H ospital in onr Ortho/Snrgical unit as a Registered
Nurse. She was hired into a specific seat w ithin our scheduling m atrix. It is not our intention
to be noncom pliant in this situation, however, we cannot change her scheduled work weekends,
because this would upset other em ployees set schedules, and create a hardship on the hospital.
Jennifers next scheduled w orking weekend is Decem ber 11 & 12, 2010.
If you have further questions, please contact me at 253-985-6861.
Sincerely,
JtfYTLti _ .
Connie Luu
Clinical M anager, Ortho/Surgical U nit
CC: Jennifer Shipman, RN
CL:bau
ST. CLARE HOSPITAL ST. FRANCIS HOSPITAL ST. JOSEPH MEDICAL CENTER ENUMCLAW REGIONAL HOSPITAL ST. ANTHONY
HOSPITAL FRANCISCAN FOUNDATION FRANCISCAN HOSPICE AND PALLIATIVE CARE FRANCISCAN MEDICAL GROUP
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For Respondent
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Decem ber 6, 2010 9:30 AM
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Show Cause
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E-FILE [
IN COUNTY CLER
PIERCE COUNTY, W
December 08 201
KEVIN S T
COUNTY C
NO: 10-3-CI
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No. 10-3-00961-1
Second
Supplem ental
Declaration of
Counsel fo r Petitioner
In Opposition to
R espondents Motion
and Declaration to
Show Cause Re:
C ontem pt/Judgm ent
And fo r O ther Relief
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2. It is now 2:45 p.m, on Wednesday, and I am concerned that Ms. Shipmans response
to the Motion for Contempt which we have not submitted yet, will be deemed untimely.
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Accordingly, I am submitting on her behalf an e-mail which I sent to the Mr. Shipmans
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counsel (at the time Clint Johnson) on September 29, 2010 in which I gave notice on Ms.
Shipmans behalf that she was moving out of the home, and indicated in the e-mail that
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Ms. Shipman would like to list the home. Mr. Johnson responded that he fully supports
listing the home.
Second Supplemental Declaration of Counsel
for Petitioner in Opposition
to Respondennts Motion to
Show Cause Re: Contempt
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4. I am not s u b m ittin g th is e-m ail for th e tr u t h of th e co n ten ts (w hich w ould be h earsay )
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T his
Joh n so n .
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ATTACHMENT #1:
E-MAIL EXCHANGE BETWEEN COUNSEL
ON SEPTEMBER 29. 2010
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Page 1 of 2
Page 2 of 2
--tim
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i C A T H O L IC HEALTH
T IN ITIATIVES
September 7,2010
ST. CLARE HOSPITAL ST. FRANCIS HOSPITAL ST. JOSEPH MEDICAL CENTER ENUMCLAW REGIONAL HOSPITAL ST. ANTHONY
HOSPITAL FRANCISCAN FOUNDATION FRANCISCAN HOSPICE AND PALLIATIVE CARE FRANCISCAN MEDICAL GROUP
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that an b a a o f taw h thta cam wfe ba hoard on tha (tata below and the etaifc to
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CALENDAR DATE
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ORDER
Respondent(s).
THIS MATTER having come before the Court upon the moving partys Motion, and the
Court having heard the argument of the parties and having considered the records and files
herein, it is now therefore,
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FILED
-------------------------------------------------------------------------------------------------------------W COWTY CLCfiKn OFFICE
ma,
BE6
7 2010
-------------------------------------------------------------------------------------------------------------PIERG&COUNTY WASHINGTON
KEVIN STOCK, County Clerk
BY_____________________ DEPUTY
e - f il e :
IN COUNTY CLERK
PIERCE COUNTY, W
December 09 2010
KEVIN STOC
COUNTY CLE
NO: 10-3-0(9
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No. 10-3-00961-1
Third
Supplem ental
D eclaration o f
C ounsel fo r P etition er
In O pposition to
R espondents M otion
and D eclaration to
Show C ause Re:
C ontem pt/Judgm ent
And fo r O th er R elief
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2. This m atter was set over from Monday, December 6, 2010, to Thursday,
December 9, 2010, in order that Ms. Shipman, who had been ill for between
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two to three weeks prior to the hearing, would have an opportunity to respond
to the allegations of contempt.
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Third Supplemental Declaration of Counsel
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ATTACHMENT #1:
E-MAIL FROM MS. SHIPMAN
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response tojason
From: Jen S ([email protected])
Sent: Wed 12/08/10 4:03 PM
To: [email protected]
Tim,
In jason's motion, it states my that my net earnings are $4,636.22. This is not true. I have printed up my
paystubs from March 2010 thru November 2010. My net monthly income for those months varied from
$3,474.00-$4,128.72. In August 2010 jason was ordered to pay monthly child support in the amount of
$780.02, but he has not. I went to my bank's website and printed up the verification of his child support
checks. In November he paid a total of $750.50; October 2010 $180.00; September 2010 $780.02; August
2010 $525.00; July $2010 $525.00; June 2010 $525.00; May 2010 $875.00; April 2010 $1,000.00 and
March 2010 $0 (nothing). My net monthly income with my earnings and child support is not $5,416.24 as
jason states it is. I have told jason this on several occasions. If you add my earnings from my job and the
child support jason has paid, my monthly net incomes are as follows: March 2010 $4,024.85; April 2010
$5,077.76; May 2010 $4,679.69; June 2010 $3,999.00; July 2010 $4,201.75; August 2010 $4,653.72;
September 2010 $4,754.67; October 2010 $3,436.28 and November 2010 $3,376.86.
In March of 2010 when I filled out the papers regarding my budget I wasnt completely sure what my
budget would be (because jason had left). Even though he had told me he would help with the bills, I
didn't know if he was going to actually follow through with that statement. I realized that going from
two incomes to one income would be difficult. To the best of my ability, I have worked out my current
budget. Some of my bills vary every month (cell phone, power, water, etc) as well as the amount I need
to spend on things like clothes, school supplies, food and gas, but for the most part my monthly budget
is $4,200-$4,300. Since March 2010, there have been some months that my income did not cover all of
my bills. I have also had to pay some medical and dental bills for the children.
In regards to the mortgage payment, I did speak to representatives from both our old mortgage
company (Bank of America) and our current mortgage company (LBPS). I was informed by both
company's that a person's mortgage/rent should not exceed 1/3 of their net income. With our monthly
mortgage payment being $1,670.69, my monthly net income should be a minimum of $5,012.07. As I
have shown my net monthly income is less than that. With my income, both mortgage company's highly
recommended that my monthly mortgage/rent to exceed $1,400. My monthly rent is $1,345.00- $325.69
less than our mortgage payment.
On the weekend of October 2-3, 20101 did move out of the house and into an apartment home two
miles away, not 'across town' as jason stated. The move was necessary for several reasons. I couldnt
afford the mortgage payment. The house needs work and repairs that exceed what I can do. The kitchen
has a mold problem. I am allergic to mold. Since the day we moved into the house it has had problems
with rats, jason did re-do the wiring in the house as well as install the security system. On a couple of
occasions he had to fix the wiring because the rats had chewed through the wires. Since jason installed
the security system he was the only one that had the code to program the system. I asked jason several
times what the code was so that I could have it reprogrammed, but he refused to give it to me. We did
remodel the bathroom but the bathtub drain never worked properly. When jason moved out he took the
weed eater and left behind a non working lawn mower, therefore I had difficulty keeping up on the yard
maintenance as I had to borrow equipment. We had several neighborhood kids that cause problems.
Belongings on our property as well as the neighbors property were being stolen. The neighbors property
as well as the easement between my house and the neighbors were set on fire. I did not feel safe in my
neiahborhood. iason also had the neiahbors watchina me (he told me this in a voicemail). I felt unsafe in
Page 2 o f 3
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work calls a "seat." I work alternating weekends. I CAN NOT CHANGE MY WEEKEND WORK SCHEDULE.
My employer has provided a few letters to that effect. When I moved out off the house on October 2-3,
2010 that was my regular weekend to work but I got two 'per diem' nurses to cover for me. One of them
worked for me on Saturday and the other worked for me on Sunday. Our work schedules are out in
advance by at least six weeks. Once our schedules are out we are commited to that schedule. If for some
reason you need a day off that you are scheduled to work that staff member either needs to trade
days/shifts with another staff member (the change can not put either staff member into OT) or find a 'per
diem' staff member to work for them. I was lucky to find two nurses whom were gracious enough to
work for me that weekend, especially since it was short notice.
I declare under the penalty of perjury in the state of Washington that my statements are true to the best
of my knowledge.
Jennifer Shipman
http://byl47w.bayl47.maiUive.com/mail/PrintMessages.aspx?cpids=adb09823-0327-lle0... 12/8/2010
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Close
P ayro ll D etails
E m ployee d e ta ils
Em ployee ID
55218
Em ployee Name
SHIPMAN, JENNIFER K.
A dvice #
23124838
Em ployee SSN
XXX-XX-2306
Date
Home A dd ress
PO BOX 905
PUYALLUP, WA_98371
Com pany
CATHOLIC HEALTH
INITIATIVES
Tax S ta tu s
5ingle
D e p a rtm e n t
3136
Tax A llo w a n ce s
MBO
ST CLARE HOSPITAL
__
Tax D e ta ils
1
Earnings
c u r r e n t E arn in gs .
YTD Earnings
C u rre n t H ours
C u rre n t Rate
REGULAR
48.00
35.4300
1,700.64
50,218.35
SICK
16.00
35.4300
566.88
3,488.11
08.25
53.1454
43B.45
847.33
DAILY OT
04.75
53.1936
252.67
4,759.04
D e scrip tio n
DOUBLE TIME
00.75
70.8533
53.14
390.4B
WEEKEND DIFF
08.25
3.0000
24.75
951.75
00.00
1.00
21.35
00.00
0-00
1,383.28
00.00
0.00
1,029.42
EDUCATION
00.00
0.00
809.09
PRECEPTOR PAY
00.00
0.00
262.82
ON CALL
00.00
0.00
96.00
SHIFT 2 DIFF
00.00
0.00
30.00
EDUCTION OVERTIME
00,00
0.00
S H IF T 2 D IF F ...........................
00.00
A ccount
Type
C u rre n t Period
Y ea r To Date
MEDICAL PRE-TAX
5-08
116.84
CHECKING
XXXXXX7901
VISION PRE-TAX
2.91
66.93
CHECKING
XXXXXX4757
583.93
11,974.42
43.93
930.18
187.83
3,977.30
50.00
700.00
................ .....33.81
______743.82
FEDERAL INCOME
TAX
Am ount
212.91
_ 1 ,9 1 6 .13_
FTO S u m m a ry
MEDICARE TAX
SOCIAL SECURITY
TAX
CAFETERIA
UNION DUES__ _
20.00
T a x e s /D e d u e tlo n s
D e scrip tio n
26.82
____0.0 0.....
E arned th is
P eriod
A va ila b le
Hours
5.68
120.77
............................3,59
59.40
H ours Type
ANNUAL LEAVE
BALANCE
SICK_BALANCE_
Pay s u m m a ry
C u rre n t
YTD
T o ta l G ross
T o ta l T axes
T o ta l D e du ctions
N et Pay
3,037.53
3,029.54
64,150.07
815.69
907.49
2,129.04
64,333.84
Close
16,881.90 -----
IB ,509,49
... ---------
45,803.00
ec. 8. 20 1 0
4 : 1 5PM
*SCH O r t h o p e d i c s 1 2 5 3 5 8 1 6 8 8 9 :
'
Wo. 1004
P. 2 4 / 4 2
Page 1 of 1
Close
E m ploye s D etails
55218
E m ployee ID
Em ployee Name
SHIPMAN, JENNIFER K.
A dvice #
23082398
Em ployee SSN
XXX-XX-2306
Date
PO BOX 905
PUYALLUP, WA 98371
Tax D etails
C om pany
CATHOLIC HEALTH
INITIATIVES
T ax s ta tu s
Single
D e p a rtm e n t
3136
MBO
ST CLARE HOSPITAL
E arnings
C u rre n t H ours
C u rre n t Rate
C u rre n t E arn in gs
YTD E arnings
REGULAR
72.00
35.4300
2,550.96
48,517.71
DAILY OT
04.00
53.3700
213.48
4,506,37
WEEKEND DIFF
08.25
3.0000
24.75
927.00
PRECEPTOR PAY
07.25
1.2496
9.06
262.82
00.00
1.00
20.35
SICK
00.00
0.00
2,921.23
00.00
00.00
o.oo
T383.2B
0.00
1,029.42
EDUCATION
00.00
0.00
809.09
00.00
408.88
DOUBLE TIME
ON CALL
00.00
00.00
0.00
0.00
Q.QO
96.00
SHIFT 2 DIFF
00.00
0.00
30.00
EDUCTION OVERTIME
00.00
0.00
26.82
SHIFT 2.DIFF
00.00
........o.oo
D e s c rip tio n
T a x e s /D e d u c tlo n s
337.34
----- - _
20.00
__ lxj
5.08
111.76
CHECKING
XXXXXX7901
199.B4
VISION PRE-TAX
2.91
CHECKING
XXXXXX4757
1,798.48
519.59
64.02
11,390.49
40.48
886.25
173.06
3,789.47
CAFETERIA
25.00
650-00
UNION DUES
33.81
710.01
...............
D e s c rip tio n
FEDERAL INCOME
TAX
A ccount
Am ount
C u rre n t P eriod
MEDICAL PRE-TAX
Type
PYO S um m a ry
MEDICARE TAX
SOCIAL SECURITY
TAX
Earned th is
P eriod
A va ila b le
Hours
ANNUAL LEAVE
BALANCE____
5.55
115.10
SICK BALANCE
3.51
71,81
H ours T ype
Pay s u m m a ry
C u rre n t
YTD
T otal Gross
T o ta l Taxes
T o ta l D e d u ctio n s
N et Pay
2,799.25
2,791.26
733.13
799.93
1,998.32
61,296.31
61,120.53
16,066.21
.....17,602,00
43,673.96
Close
ec. 8. 2 0 1 0 ' : 4 : 1 5 P M
.. SCH O r t h o o e d i cs 1 2 5 3 5 8 1 6 8 8 9
No. 1004 P. 2 5 / 4 2
Page 1 of 1
Close
E m ployee D e ta ils
E m ployee ID
55210
Em ployee Nam e
SHIPMAN, JENNIFER K.
A dvice #
23040369
Em ployee SSN
XXX-XX-2306
D ate
Hom e A dd ress
PO BOX 905
PUYALLUP, WA 98371
T ax D e ta ils
C om pany
CATHOLIC HEALTH
INITIATIVES
T ax S tatus
Single
D e p a rtm e n t
3136
Tax A llo w a n ce s
MBO
ST CURE HOSPITAL
E arn in gs
C u rre n t H ours
D e s c rip tio n
C u rre n t Rate
C u rre n t E arn in gs
YTD E arn in gs
45,966.75
REGULAR
48.00
35.4300
1,700.64
08.00
35.4300
283.44
1,383.28
DAILY
ot
01.25
53.4560
66.82
4,292.89
WEEKEND DIFF
08.50
3.0000
25.50
902.25
EDUCTION OVERTIME
00.00
00.00
00.00
00.00
00.00
00.00
00.00
00.00
00.00
00.00
00,00
SICK
HOLIDAY OVERTIME FLSA
EDUCATION
REST BETWEEN SHIFTS FLSA
DOUBLE TIME
PRECEPTOR PAY
ON CALL
SHIFT 2 DIFF
1.00
19.35
0.00
0.00
0.00
0.00
0.00
0.00
0,00
0.00
0,00
0.00
2,921.23
1,029.42
609.09
408.8B
337.34
253.76
96.00
30.00
26.82
20.00
T a x e s /D e d u c tio n s
C u rre n t Period
Y ea r To D ate
MEDICAL PRE-TAX
5.08
106.68
CHECKING
XXXXXX79Q1
VISION PRE-TAX
2.91
61.11
CHECKING
XXXXXX4~7~57~
335.38
10,870.90
30.00
845.77
128.30
3,616.41
25.00
625.00
D e s c rip tio n
FEDERAL INCOME
TAX
A ccount
Am ount
151.60
1,364.32
PTO S um m a ry
MEDICARE TAX
SOCIAL SECURITY
TAX
CAFETERIA
UNION DUE5
T ype
.........______ 33.81
676.20_
Earned th is
P eriod
A v a ila b le
H ours
ANNUAL LEAVE
BALANCE
4.18
109.55
SICK BALANCE
2.64___
H ours Type
_____ 68.30.
Pay S u m m a ry
C u rre n t
T o ta l Gross
F ederal T a xa b le Gross
T o ta l Taxes
T o ta l D e du ctions
N et Pay
2,077.40
2,069.41
493.68
560.48
1,515.92
58,329.27___
Close
15,333.08
..................16,802.07....
41,675354
Dec. 8. 20 1 0
4 : 1 3PM' SCH O r t h o p e d i c s 1 2 5 3 5 8 1 6 8 8 9
STATE OF WASHINGTON
DEPARTMENT OF SOCIAL AND HEALTH SERVICES
DIVISION OF CHILD SUPPORT (DCS)
'M'iiSfiji-aa SMI}
=j9| l\ Utpajonent,bfSocial
/ll l l V-ftKtSjftServices :
li0&rbRi^h:%Vi*W'9^Ps8rt'
233 47 1
16864
JENNIFER KAY SHIPMAN
PO BOX 905
PUYALLUP WA 98371-0078
DATE; 11/05/2010
5. $ ______ jpg______ to the State to repay past public assistance (AFDC/TANF) paid to you. As of the date of
this notice, the State claims an additional $ ________ .00
to repay public assistance paid to you in the past.
6.
$ _____ op
to the State to repay past Medicaid expenses on behalf of you and your children.
B. From the total amounts listed in sections A1 through A4 above, DCS kept the following amounts:
1.
2. $
,oq _______to pay the $25,00.annual fee. The paying parent receivescredit against the support debt
for the full amount of the collection even though DCS kept part of the collection to pay the fee. You are required
to pay the fee if you never received Temporary Assistance for Needy Families (TANF), Tribal TANF, or Aid to
Families With Dependent Children (AFDC) for minor children and DCS has sent at least $500.00 in support
collections to you in the current federal fiscal year.
C. From the total amounts listed in section A above, DCS sent you the following amounts:
1.
2. $ ______j 30_______as a cash support pass-through (if you are currently receiving public assistance).
If you disagree with the way DCS distributed your support, you may:
1. Write or call DCS to discuss your concerns.
2. Ask for a hearing unless your disagreement is about the $25.00 annual fee. You must ask for a hearing before
02/03/2011
T request a hearing, complete page 3 and return it to DCS.
If you disagree with the $25,00 annual fee because it creates a hardship for your family, you may request a Conference
Board. A Conference Board will determine if DCS will waive the fee.
c h il d s u p p o r t d is t r ib u t io n
AND DISBURSEMENT s t a t e m e n t
Page1
* - D e c . 8. 20 1 0 4 : 1 3 P M . . . ^ SCH O r t h o p e d i c s 1 2 5 3 5 8 1 6 8 8 9
No. 1004-
P. 7 / 4 2
STATE OF WASHINGTON
DEPARTMENT OF SOCIAL AND HEALTH SERVICES
DIVISION OF CHILD SUPPORT (DCS)
242 40 1
16970
JENNIFER KAY SHIPMAN
PO BOX 905
PUYALLUP WA 98371-0078
DATE: 10/07/2010
op_______ topay current cash medical support owed for the month.
2. $ ______ .go_______ to pay the $25.00 annual fee. The paying parent receivescredit against the support debt
for the full amount of the collection even though DCS kept part of the collection to pay the fee. You are required
to pay the fee if you never received Temporary Assistance for Needy Families (TANF), Tribal TANF, or Aid to
Families With Dependent Children (AFDC) for minor children and DCS has sent at least $500.00 in support
collections to you in the current federal fiscal year.
C. From the total amounts listed in section A above, DCS sent you the following amounts:
1.
2. $
If you disagree with the way DCS distributed your support, you may:
Page 1
1 2 /S ^ e x a
[')a hi
L I* < )
iv o ii& fh
For Petitioner
RE
For Respondent
( 2 o ivV - *\K k
c)c^cyO
^
o jlty ^ i
1 1 7 9 ? '4 2 6 .1 3 ?
Ct></<.
\
I d - fr ~
ttto u
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C
o o p y & x tX f
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im
j'c ^ G a .*
___________t _________._________"'_______________________________.______________________
(-C
22^
W *
y e t?
O f J
-GA.^
S f
Jr n
v jJ
y q t\
December 9, 2010 9:30 AM
6^ >
ontempt Hearing
Mark L Gelnnan
Salman
KJ4 W p u J
S > c2 j
i 'c t I
Jjgr NMtP&C
S m /P m A a J
No. / o - 1 - 0 0 9 6 / - !
Petitioner(s),
and
ORDER
P /rt/lrJ
Respondent(s).
THIS MATTER having come before the Court upon the moving partys Motion, and the
Court having heard the argument of the parties and having considered the records and files
herein, it is now therefore,
___________ lJH 6n
rOATTFJt
Dfi>r
, 7 0 - V S ' n a te
T )m e
F a st
p /r f f it
IS
CQM aJOSA
ro g A ^
j2 e s o c c ? 7 )o r J .
&
7Z>
fic c o u ;
T an
_______
O ff
C J$T
A c f/7cSiTS>.
P fr/Z /~ ? : 5"*
c ts /tc .
7>+t
F0 6 L
/ / Y ir fZ # A T S
T U (S
_______
C /jr ^ C s
m E a rs A
/- f u s S /t^
(
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t
C / C t / k/
i J//L.L_____ F o L L y
P i f i C C / r t B pSFZ
<fAC ft
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i i T s ? 0 'i - a 9
(S lff
/~fds r lF ..
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
December 30 2010 10:03 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
Please take notice that an issue of law in this case will be heard on the date and time shown below:
P ierce C o u n ty S u p e rio r C o u rt, C o u n ty -C ity B uilding - 930 T a c o m a A v e S - T aco m a , W A 9840 2
Show Cause
N a tu re o f H earin g:
Contempt
1 4 , 2011
9 :3 0
AM
W O R K IN G C O P IE S S H A L L BE S U B M IT T E D T O C O M M IS S IO N E R S S E R V IC E S R O O M 140,
B E F O R E 12:00 NO O N T W O C O U R T D A YS P R IO R T O H E A R IN G
DA TED :
S ign ed :
NA M E:
Daniel N Cook
Phone:
(253) 581-0660
W SBA#:
34866
LAKEWOOD, WA 98499-2751
For:
1 of
10-3-00961-1
35725210
MTSC
01-18-11
AM.
JA N ig 2flii PM
.DEPUTY
I. MOTION
JASON W. SHIPMAN moves the court for an order directing JENNIFER KAY SHIPMAN
to appear personally before the court and show cause why an order should not be
entered:
1.1
FINDING CONTEMPT.
Finding contempt for failure to comply with:
PARENTING PLAN
Signed by the court on August 24, 2010, in Pierce County, Washington.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
11484
IS 1 9 /2 0 1 1
18884
1
12
ESTABLISHING A JUDGMENT.
2
Does not apply.
3
4
1.3
INCLUDE LANGUAGE
GRANTING SANCTIONS.
1.4
OTHER:
10
11
12
13
14
15
II. DECLARATION
16
17
18
JENNIFER KAY SHIPMAN should be held in contempt for the following reasons:
Failure to comply with the Parenting Plan as follows:
19
The parenting plan dated August 24, 2010, said that if I resided in the childrens school
20
district, .the children would be permitted to enjoy more residential time with me. When
21
that parenting plan was entered, the children were enrolled in Woodland Elementary
22
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
11484
19^2811
10B 0S
Petitioner did not notify me or get approval for the move. The parenting plan dated
August 24, 2010, requires joint decision making for educational decisions. The move
out of the school they were in violated the parenting plan because she did not notify,
consult or otherwise obtain consent for the change in schools. The change in schools
was completely unilateral and was an intentional violation of the joint decision making
requirements. The change was in bad faith because it was done entirely to eliminate
the additional residential time the child would be spending with me when l moved closer
to their old school. Petitioner should be held in contempt for violating the parenting
plan.
I declare under penalty of perjury under the laws of the State of Washington that
the foregoing is true and correct to the best of my knowledge.
FAUBJON, REEDER,
FRALEY & COOK, P.S.
11484
1 ^ 1 9 /2 8 1 1
la e & fc
s ^ v /w -W
Petitioner,
vs.
no.
T)/=)a/7 < :
S h -i P / ^ ^
Respondent.
It
(0 -3 -0 O 9 C /-
perjury under the laws of the State of Washington, that the faooimilo documents
attached to this declaration, consisting of
is a complete and legible fseeamtie that I have examined personally and that was
received by me via
Dated
/ /
' &
at the following r
/ /
D /9 /^ t4 c
Printed Name
11484
I
I I Nil
1 /1 9 /2 8 1 i
10807
II II!
ill I
10-3-00961-1
35725221
1
2
IN COUNTYCLERKS OFFICE
AM
...
J a n 18 2011
pu
6
7
8
9
In re the Marriage of:
NO. 10-3-00961-1
10
11
12
13
14
It is Ordered:
15
16
17
18
JENNIFER KAY SHIPMAN shall appear in person before this court at the place and
time below and show cause why the relief requested in the motion should not be
granted.
Date: February 14, 2011
Room/Department: TBA
19
20
21
22
If you fail to appear in person and defend at these proceedings the court may grant all
of the relief requested and/or issue a bench warrant for your arrest without further notice
to you.
If imprisonment is requested in the motion and you cannot afford an attorney, you may
request the court to appoint an attorney to represent you.
23
Other:
24
Dated:
25
Ord to Show Cause re Contempt (ORTSC) - Page
WPF DRPSCU 05.0150 Mandatory (6/2008) - RCW 26.09.160
re
11484
1 /1 9 ^ ^ 8 1 1
18088
1
2
Presented By:
FAUBION, REEDER, FRALEY & COOK, P.S.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Ord to Show Cause re Contempt (ORTSC) - Page 2 of 2
WPF DRPSCU 05.0150 Mandatory (6/2008) - RCW 26.09.160
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
February 08 20'
KEVIN ST
COUNTY C
NO: 10-3-0
2
3
4
5
6
In re th e M arriag e of :
8
No. 10-3-00961-1
JE N N IF E R KAY SH IPM A N
P etitio n er(s),
an d
10
11
JA S O N W ILLIAM SH IPM A N
R espondent(s).
D eclaration of
C O UNSEL IN O PPO SITIO N TO
RESPO N D EN TS MOTION TO
SHOW CAUSE RE CO N TEM PT
(D C LR Modified)
12
13
16
17
18
19
20
rig h t to move for economic reaso n s. T his issu e only a rises b ecau se R esp o n d en t h a s b een
21
provided, u n d e r th e p a re n tin g p la n , w ith s u b s ta n tia l v isita tio n rig h ts allow ing him to have
22
23
Declaration of Counsel
In Opposition to Respndents
Motion to Show Cause Re Contempt
3
4
5
6
7
8
9
10
11
12
T im othy M. G reene
P r in t or Type N am e
13
14
15
16
17
18
19
20
21
22
23
Declaration of Counsel
In Opposition to Respondents
Motion to Show Cause Re Contempt
E-FILED
IN COUNTY' CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
February 09 2011 2:0 PM
KEVIN STOCK
COUNTY CLERI
NO: 10-3-0096 -1
RETURN OF SERVICE
and
JASON VWLLIAM SHIPMAN,
Respondent.
1Declare.
1.
i, \ v~^i I c - ^
party to this action.
2.
Is e r v e d .
1.
2.
3.
3.
Return of Service -1
// ?x \
Time:
a
s ts
0 Q
j.m./^Tm?^
4.
5.
I declare under penalty of perjury under the laws of the state of Washington that
the foregoing is true and correct
Return of Service - 2
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
February 10 2011 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
NO. 10-3-00961-1
Petitioner,
v.
REPLY DECLARATION
OF JASON SHIPMAN
The
only but cannot be used to rebut the factual contentions in my moving declaration.
Furthermore, the statement of Petitioner's counsel is wrong.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
wanted to move by saying Petitioner "allowed the children to transfer to another school.
Not only is the implication the children wanted to move contradicted by the statement
that it was Petitioners voluntary choice, there is absolutely no truth whatsoever to the
implication that the children want to change schools. The fact is, Petitioner forced the
children to change schools.
I do not think even think that Petitioners move to the new apartment "required a
change in schools.
I fully believe that the childrens prior school would have allowed
them to remain in their current classes and buildings and with their current teachers and
peers even though Petitioners residence had changed.
I was not consulted in any manner whatsoever until after the move
had occurred. Petitioner just told me to drop the children off at a new school on Monday
when I picked them up on Friday for visitation.
Petitioners relocation to effectuate a change in schools was a malicious act.
This act is absolutely a bad faith violation of the joint decision making requirements.
The home I moved into was within walking distance (literally next door to the school with
only a field in between) of Tylers school. Tyler has helped me move in and was excited
about the opportunity to spend more time with me.
changed the childrens school because Tyler (our son together) was stopping by and
spending time at my house after school. When the Petitioner found out, she called me
and threw a temper tantrum. Petitioner stating she was going to "put an end to Tytler
spending extra time at my house.
over and over again, as she was yelling at me about Tyler dropping by after school.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood WA 98499
253-581-0660
Petitioners attorney also somehow tries to assert that changing a childs school
is not an educational decision. This is absurd. Changing a childs school is perhaps,
the most basic and essential educational decision which can be made.
This decision was made right in the middle of a semester.
in the children being taken out of the schools they had attended for many years. For
Hunter he has been in the same school building for four years.
in his school building for three years and it was less only because he recently moved up
to high school.
Prior to Petitioners unilateral act Tyler had been with the same group
school since his freshman year of high school and I absolutely think that moving him in
the middle of his Junior year has compounded those problems.
after the move he refused to go to school - at least when he was attending with the
class he had been with for years he was going to school.
Significantly, Petitioner moved into an apartment complex. In other words, it was
not as if she even found a perfect rental home for her situation that she absolutely could
not pass up.
apartments which would have been on the same side of Meridian as the childrens
schools.
Petitioners argument that her decision was necessitated by finances is also
completely ridiculous.
pay - she had not even been paying. She had saved and had money in the bank from
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood WA 98499
253-581-0660
months of unpaid mortgage payments and in fact, her non-payment of the mortgage is
another reason I am asking the court to find her in contempt.
In summary, Petitioner made a unilateral decision that substantially affected the
childrens education and her failure to make this a joint decision was clearly in bad faith.
Petitioner did not talk to me in advance. Petitioner did not attempt dispute resolution. I
was not allowed to get input from the children or the childrens teachers or offer
alternatives (e.g., leaving the children where they were in school but still allowing
Petitioner to move). Petitioner just decided she did not like how close the children were
to me, and the fact that they were spending extra time at my house, so she Petitioner
chose to move and change their school.
was on the other side of Meridian and therefore Petitioner was allowed to change the
childrens schools. There are lots of apartments she could have moved into that would
have left the kids in their schools. All of those apartment complexes do price matching.
The petitioner has been using the children as a weapon for a long time.
The semester just ended, so I am asking the court to find the petitioner in
contempt and order the children back to their original schools.
It is my understanding
that both children would prefer to be in the prior school than remain at the new school. I
would not ask for this relief if I did not believe that was what the children wanted.
believe the children miss their friends and the teachers they had in the old school.
also believe that since the semester just ended the timing for a move back is also more
advantageous.
Finally the Petitioner asked for half the daycare fees and gave a made up
number. I told the court there was no daycare and was no plans for daycare. Back in
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood WA 98499
253-581-0660
August, the court ordered me to pay half upon being given a receipt.
are not in daycare.
off at my home or my mothers home before school because both my mom and I live
very close to the childrens school and can ensure the children are cared for between
the time Petitioner has to go to work and when school begins.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE
OF W ASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
Signed at
L t ^
, 2011.
JASON SHIPMAN
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
\a ^ g .r ~ f
Q u o t 'd . I
L lrti/J
For Respondent
For Petitioner
RE: _
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C O L K < f i l ; * ci ,
Show Cause
MARY E. DICKE
Clerk:*fr)*<JLu^
R -A > .' 7
1867 2 -'15x2*5! j
10-3-00961-1
35885434
ORCN
3-*9_i0tf jlij
02-14-11
2
3
4
IN C0UNTYFCLERK'S OFFICE
S S S K ^ - t. .
------- " y DEPm
8
9
10
In re the Marriage of:
NO. 10-3-00961-1
11
12
13
14
Petitioner,
v.
JASON W ILLIAM SHIPM AN
_______________________ Respondent.
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I. Judgm ent Summary
16
Applies as follows:
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18
19
20
A.
B.
C.
D.
E.
21
F.
22
G.
H.
23
24
25
J.
K.
L.
Judgment creditor
~
Jason William Shipman________
Judgment debtor
Jennifer Kav Shipman_________
Principal judgment amount (back child suuuui l/i8eJ]caTsupporf7othQjLohligatinng/
naaintonanooH iuin (UateT
through (date)
_______
$
/,*
Interest to date of judgment
$ ________________
Attorney fees
$ ________________
Costs
$ ________________
Other recovery amount
$
Principal judgment shall bear interest at \ D
% per annum
Attorney fees, costs and other recovery amounts shall bear interest at
|
% per annum
Attorney for judgment creditor
Daniel N. Cook_____
Attorney for judgment debtor
Timothy Greene
Other:
Ii8t'7
15/2611
398183
1
II. Findings and Conclusions
2
This Court Finds :
3
4
2.1
2.2
Nature of Order
8
2.3
This order was violated in the following manner (include dates and times, and
amounts, if any):
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2.4
pc
JENNIFER K. SHIPMAN did at-have the ability to comply with the order as
follows:
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2.5
pc
JENNIFER K. SHIPMAN does-flt have the present ability to comply with the order
as follows:
See Motion and Declaration to Show Cause re Contempt entered on
January 18, 2011.
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22
23
24
JENNIFER K. SHIPMAN does Bftt have the present willingness to comply with the
order as follows:
See Motion and Declaration to Show Cause re Contempt entered on
January 18, 2011.
25
Ord on Show Cause re Cntmpt/Jdgmnt (ORCN) - Page 2 of 6
WPF DRPSCU 05.0200 Mandatory (10/2009) - R C W 26.09.160, 7.21.010
:9ii
39e
1
2
2.6
4
5
2.7
the fSiSontial (m itS fgn) provisions of the parenting pian and had the ability
to comply with the parenting plan, and is currently janwilling to comply. The
noncompliance with the residential provisions was in bad faith.
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9
2.8
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It is Ordered:
14
3.1
15
16
3.2
3.3
, ^
A t^ [
^ IAf i7 N
ch/ld&n
c Moot
22
24
Im prisonm ent
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in contempt of court.
19
20
Contem pt Ruling
JENNIFER K. SHIPMAN [^Is [$
17
18
f>^
Th
S//&X
m yoweo
Z U tN M rf
Of
v t
id
pe/o/Z
fp r
so m e
* *
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S a m p fi& p e s S M c c e m m s M e ^
3.4
25
7 r/ 1-q~f -/ 7l.pu 4i ^
390165
UD i
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2
3.5
3.6
6
3.7
7
Does not apply.
8
3.8
9
[ ]y
M
10
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(njm p u A ^ c _
u j/fH
3 .3
/) r * jD
j> J / ,
0 ^
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3.9
16
vT
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3.10
fo e fH 0
Review
fiew Date
P>mHHY
## .
& / >
F r -
DO
s r ttu lir 1.
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[]
at (time)
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3.11
Other
in n
f m w p-vw orJ6 e
'
^
Aencj a t
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Ck f S P ^ L e ^ ^ A c t C C 0P & 4X
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I
te r n * * * * * * * < - & * * * ^ 5 ^
11867
2 /1 5 '2 8 1 1
398166
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3.12
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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.
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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
19
relocation, the relocation will be permitted and the proposed revised residential
20
schedule may be confirmed.
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24
25
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 W PF 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.
Ord on Show Cause re Cntmpt/Jdgmnt (ORCN) - Page 5 of 6
WPF DRPSCU 05.0200 Mandatory (10/2009) - R C W 26.09.160, 7.21.010
186?
2 / i 5 ^ 2 l l
39616?
1
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.
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3
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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5
6
7
W arning: 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 orderjpoayL^ubject a violator to arrest.
8
Dated:
'r ^
I t (_________
\
/ ' s C ~ ^ M a r y E . D icke
Jtfdg& Com m issioner
10
11
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Presented by:
FAUBION, REEDER, FRALEY & COOK,
P.S.
Approved by;
Noticaof presentation
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ne, W S B A # 17499
etitioner
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20
son Shipman, Respondent
Date
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Ord on Show Cause re Cntmpt/Jdgmnt (ORCN) - Page 6 of 6
WPF DRPSCU 05.0200 Mandatory (10/2009) - RCW 26.09.160, 7.21.010
Shipman, Jennifer v Jason
S:\CASES1\Shipman, Jason disso\Word\PLEADINGS\Disso\Orderre Contempt.doc
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
February 25 20'
KEVIN ST
COUNTY C
NO: 10-3-0
2
3
4
5
6
In re th e M arriage of :
8
No. 10-3-00961-1
JE N N IF E R KAY SH IPM A N
P etitio n er(s),
an d
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11
JA S O N W ILLIAM SH IPM A N
R espondent(s).
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la w fu l o r d e r o f th e c o u r t d a te d o n A u g u s t 24, 2 0 1 0 ....T h e o r d e r is r e la te d to
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dated.
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1
2
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P a r a g r a p h 2.7:
J e n n if e r K. S h ip m a n h a s n o t c o m p lie d w ith th e jo in t d e c is io n
b a d fa ith :
11
P a r a g r a p h 2.8: T h e a tt o r n e y fe e s a n d c o s t s a w a r d e d in p a r a g r a p h 3.7 b e lo w h a v e
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be strick en .
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1
2
P o r tio n s o f th e r ec o r d r e le v a n t to t h is m o tio n :
10/15/10
10/15/10
10/15/10
11/30/10
12/02/10
12/03/10
7) C lerks M in u te E n try
12/06/10
8) O rd er for C o n tin u an ce
12/07/10
12/09/10
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5
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12/09/10
12/06/10
12/09/10
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12/30/10
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01/18/11
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01/18/11
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02/08/11
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02/10/11
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02/14/11
02/14/11
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E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
February 25 20'
KEVIN ST
COUNTY C
NO: 10-3-0
2
3
4
5
6
In re th e M arriage of :
8
No. 10-3-00961-1
JE N N IF E R KAY SH IPM A N
P etitio n er(s),
an d
10
11
JA S O N W ILLIAM SH IPM A N
R espondent(s).
12
13
14
resp ectfu lly m oves th e co u rt for reco n sid eratio n of its F e b ru a ry 14, 2011 O rd er of
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D E C L A R A T IO N
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a p a rtm e n t u n til S ep tem b er 25, 2010, a n d I d idnt sign a lease u n til S ep tem b er 29, 2010.
4
5
6
2011.
8
9
14
c h ild ren now have to tra v e l long d istan ces to a tte n d school a n d daycare before a n d a fter
15
school (daycare for H u n te r). They boys have to get up a t 5:30 a.m . to a tte n d school in s te a d
16
of th e form er 8:00 a.m . for H u n te r a n d 6:30 a.m . for T yler . I w ill now have to stop w orking
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overtim e so th a t I can tra n s p o rt th e c h ild ren long d istan ces to a co u rt o rd ered school.
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/s/Je n n ifer S h ip m an
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J e n n ife r S h ip m an
DECLARANT
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FILED
DEPT 12
n o pen c o uri
FEB 2 *! 2011
Pierce County fC lo rk
02-2B-11
10-3-00961-1
.By
No. 10-3-00961-1
vs
JASON WILLIAM SHIPMAN
NOTICE OF NONCOMPLIANCE
A N D ORDER SETTING
NO NCO M PLIANCE HEARING
Respondent(s)
Court records indicate that the attorneys and/or parties listed below have failed to comply with the Case Schedule in
regard to the following item
Settlement Conference not confirmed by deadline - (See PCLR 16 & PCLSPR 94 04)
Deadline 02/21/11
You are hereby ORDERED to appear for a hearing at 1 30 pm on Friday, 05/06/11 to comply with the Case
Schedule, or deliver a report of the same no later than the time set for the hearing
The court may impose sanctions or terms for failure to comply with the Case Schedule 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 lustice
requires See PCLR 1( j )
*
^
DATED 02/24/11
TO:
Superior Court Clerk for Filing
(Court File Copy)
PAGE 1 OF 1
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
March 01 2011 4:01 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
NO. 10-3-00961-1
OBJECTION AND MOTION TO
STRIKE
DATED this
day of
FAUBION, REEDER,
FRALEY & COOK, P.S.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
1
PCLR 7 reads:
2
3
4
5
6
7
Section (a) Judge's Motions and Trial assignments- (11) Motions for Revision.
Within 10 days of the entry of a written order or judgment by a court
commissioner, either party may file a motion for revision. Such motion shall be
schedule for argument on the assigned judicial departments next available
motion date...
Section (c) Motions held before Judges or Commissioners- (1) Motions for
Reconsideration . A Motion for Reconsideration shall be heard by the Judge or
Commissioner who initially ruled on the motion or to the Presiding Judge or
his/her designee upon a showing of good cause.
8
ARGUMENT:
9
10
11
Robertson involves the authority of the superior court to extend the time for reviewing a
12
superior court commissioner's order beyond the 10 days set forth in RCW 2.24.050. The
13
court held that the plain language of the statute requires the party seeking review to file
14
a motion for revision within 10 days and that after that time, the party must obtain review
15
from the appellate court. Neither the statute nor court rules allow the superior court to
16
treat a late motion for revision as a timely motion for reconsideration. Roberts v.
Roberts, 113 Wn.App. 711, 54 P.3d 708 (Wash.App. Div. 2 2002). In this matter, the
17
motion for reconsideration and motion for revision were served on Mr. Shipman
18
February 24, 2011. Both motions were not filed with the court until February 25, 2011.
19
February 25, 2011 was the eleventh (11th) day and therefore is outside the timeline put
20
forth by statute and case law. Therefore, the motion for revision should be dismissed.
In a motion for reconsideration, the matter must be filed within ten days of the
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22
23
order, it must be noted at the time of filing, and the motion must identify the reasons in
law and fact the motion is based. CR 59. A motion for reconsideration is to be before
the judge or commissioner who ruled on the original motion.
24
A motion for revision must be heard by a judge in superior court. PCLR 7. After a
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formal order has been entered, it is improper to offer new evidence. New evidence may
Objection and Motion to Strike - Page 3 of 4
Shipman, Jennifer v Jason
C:\Documents and Settings\dcook\Local Settings\Temporary Internet
Files\Content.Outlook\13RLZYMV\Motion to Strike.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
not be submitted to a court for purposed of reconsideration after a formal order has
been entered. AIMCOR v. Melton , 74 Wn. App. 73, 872 P.2d 87 (1994). The motion for
reconsideration by Ms. Shipman was also filed on the eleventh (11th) day on February
25, 2011 with the court. It is outside the timeline required by the statute. The motion was
not noted at the time of filing. The motion lists facts of why the contempt motion should
be reconsidered, but it does not identify the reasons in law why the motion should be
allowed. The motion for revision and reconsideration cannot be heard before the same
judge. It is unclear who will hear the motions since they are not noted, but they must be
heard separately.
For all of these the reasons, the court should grant this motion and strike the
pleadings untimely filed by Petitioner as a Motion for Revision or Reconsideration.
RELIEF REQUESTED:
Wherefore, the Respondent requests that the court strike and/or dismiss both the
motion for revision and the motion for reconsideration. The Respondent further requests
an award of attorneys fees and costs in the amount of $1,500 for the cost of responding
to petitioners improper motions.
FAUBION, REEDER,
FRALEY & COOK, P.S.
10-3-00961-1
35990595
LTRSTC
Court
OF THE
S tate of Washington
for Pierce County
uperior
SUPERIOR COURT
(253) 798-6630
March 3, 2011
ROBERTO LLOYD
ATTORNEY AT LAW
4115 S MERIDIAN, SUITE B
PUYALLUP, WA 98373
DANIEL N COOK
ATTORNEY AT LAW
5920 100TH ST SW STE 25
LAKEWOOD, WA 98499-2751
Dear Counsel
This is to confirm the following settlement conference
Case:
Cause No.:
Before:
Date & Time:
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,
DEA FINIGAN
Dea Fintgan
Judicial Assistant
CC Pierce County Clerk for Filing
/
1
10-3-00961-1
36109256
NOTE
03-25-11
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W ^ 2 4 2o
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Superior Court of W ashington
County of Pierce
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10-3-00961-1
Petitioner,
and
R ESPO N D EN TS
CALCULATIONS
13
JASON WILLIAM SHIPMAN
14
Respondent.
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16
17
18
20
Judgment entered February 14, 2011
Interest from 2/15/11 to 3/23/11 (37 days @ $0 49 per
diem)
$1,500 00
$
18 13
TOTAL
$1,518 13
25
RESPONDENTS CALCULATIONS-1
S \CASES1\Shipman, Jason disso\Garnishmeni\CALC doc
:S
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jl 413-e %
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Dated this ? 5 *
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FAUBION, REEDER, FRALEY
& COOK, P.S.
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RESPONDENTS CALCULATIONS- 2
S \CASES1 \Shipman, Jason disso\Garmshment\CALC doc
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3^ *
10-3-00961-1
3610S264
AFGAR
Ct/*ryp'i
03-25-11
Oi
* *-s
& E?C-
**>
& ff
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In re the marriage of
No.
10-3-00961-1
12
Petitioner,
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and
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Respondent.
FRANCISCAN HEALTH S YSTEM
17
G arnishee Defendant
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I. APPLICATION
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1 1
The amount alleged to be due is the balance of the judgment or amount of claim,
24
$1,500 00, plus interest and estimated garnishment costs as indicated in the writ
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1.3
1
HEALTH SYSTEM, Garnishee, whose residence and/or business location is 11315
2
Bridgeport Way SW, Lakewood, Washington, is:
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5
[]
[]
to the Petitioner which are not exempted from garnishment by any state or federal law
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9
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II. CERTIFICATION
I CERTIFY under penalty of perjury under the laws of the State of Washington
that the foregoing is true and correct.
Dated th is P ^ ? _ day of March, 2011, at Lakewood, Washington
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FAUBION, REEDER, FRALEY
& COOK, P S.
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APPLICATION FOR WRIT OF GARNISHMENT (APL) Page - 2
WPF GARN 01 0100 (8/2000), R C W 6 27 060
1
10*3-00961-1
36109265
SWRG
4^12
03-25-11
3
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No.
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Petitioner,
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and
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10-3-00961-1
Respondent.
FRANCISCAN HEALTH SYSTEM
17
Garnishee D efendant
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STATE OF W ASHINGTON TO
AND TO.
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The Respondent in this action has applied for a Writ of Garnishment against you,
claiming that the above-named Petitioner is indebted to Respondent and that the
amount to be held to satisfy that indebtedness is $1,808 13 (total amount), consisting of
23
Balance of Judgment:
$1,500.00
24
$18 13
25
$300.00
$ 20.00
Answer Fee
$ 10.00
$ 20 00
$250.00
Total
$300.00
YOU ARE HEREBY COM M ANDED, unless otherwise directed by the court, by
the attorney of record for the Respondent, or by this writ, not to pay any debts, whether
wages subject to this garnishment or any other debt, owed to the Petitioner at the time
this writ was served and not to deliver, sell, or transfer, or recognize any sale or transfer
of, any personal property or effects of the Petitioner in your possession or control at the
time this writ was served. Any such payment, delivery, sale, or transfer is void to the
extent necessary to satisfy the Respondents claim and costs for this writ with interest
YOU ARE FURTHER COM M ANDED to answer this writ by filling in the attached
form according to the instructions in this writ and in the answer forms; and within twenty
(20) days after the service of the writ upon you, to mail or deliver the original of such
answer to the court, one copy to the Respondent or the Respondents attorney, and one
copy to the Petitioner in the envelopes provided.
If, at the time this writ was served, you owed the Petitioner any earnings (that is,
wages, salary, commission, bonus, or other compensation for personal services or any
periodic payments pursuant to a pension or retirement program), the Petitioner is
entitled to receive amounts that are exempt from garnishment under federal and state
law You must pay the exempt amounts to the Petitioner on the day you would
customarily pay the compensation or other periodic payment. As more fully explained in
the answer, the basic exempt amount is the greater of 75 percent of disposable
earnings or a minimum amount determined by reference to the employees pay period,
to be calculated as provided in the answer
IF THIS IS A W RIT FOR A CONTINUING LIEN ON EARNINGS, YOU MAY
DEDUCT A PROCESSING FEE FROM THE REMAINDER OF THE EMPLOYEE'S
EARNINGS AFTER W ITHH O LDING UNDER THIS W RIT. TH E PROCESSING FEE
MAY NOT EXCEED TW E NTY DOLLARS ($20) FOR THE FIRST ANSW ER AND TEN
DOLLARS ($10) AT THE TIM E YOU SUBMIT THE SECOND ANSW ER
WRIT OF GARNISHMENT (CONTINUING LIEN ON
EARNINGSBAFTER JUDGMENT) (WRG or $WRG) - 2
WPF GARN 01 0250 (7/2003) - RCW 6 27 100, 340
S \CASES11Shipman, Jason disso\Gamishment\wnt doc
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If you owe the Petitioner a debt payable in money in excess of the amount set
forth in the first paragraph of this writ, hold only the amount set forth in the first
paragraph and any processing fee, if one is charged, and release all additional funds or
property to the Petitioner.
THIS IS A W R IT FOR A CONTINUING LIEN THE G ARNISHEE DEFENDANT
SHALL HOLD the nonexempt portion of the Petitioners earnings due at the time of
service of this writ and shall also hold the Petitioners nonexempt earnings that accrue
through the last payroll period ending on or before SIXTY (60) days after the date of
service of this writ HOW EVER, IF THE GARNISHEE DEFENDANT IS PRESENTLY
HOLDING THE N O N EXEM PT PORTION OF THE P ETITIO N ER S EARNINGS UNDER
A PREVIOUSLY SERVED W R IT FOR A CONTINUING LIEN, THE GARNISHEE
DEFENDANT SHALL HOLD UNDER THIS W RIT only the Petitioners nonexempt
earnings that accrue from the date the previously served writ or writs terminate and
through the last payroll period ending on or before sixty (60) days after the date of
termination of the previous writ or writs IN EITHER CASE, TH E GARNISHEE
DEFENDANT SHALL STOP W ITHHOLDING W HEN THE SUM W ITHHELD EQUALS
THE AMOUNT STATED IN TH IS W R IT OF GARNISHMENT.
IF YOU FAIL TO A NSW ER THIS W R IT AS COMMANDED, A JUDGMENT MAY
BE ENTERED AGAINST Y O U FOR THE FULL AM OUNT OF THE RESPONDENTS
CLAIM AGAINST TH E PETITIO NER W ITH ACCRUING INTEREST, ATTORNEY
FEES, AND COSTS W H E TH E R OR NOT YOU OW E ANYTHING TO THE
PETITIONER. IF YOU PROPERLY ANSW ER THIS W RIT, ANY JUDGM ENT
AGAINST YOU WILL NOT EXCEED THE AM OUNT OF ANY N O N EXEM PT DEBT OR
THE VALUE OF ANY N O N EXEM PT PROPERTY OR EFFECTS IN YOUR
POSSESSION OR CONTROL
JUDGMENT MAY ALSO BE ENTERED AGAINST TH E PETITIO NER FOR
COSTS AND FEES INCURRED BY THE RESPONDENT.
WITNESS, the Honorable BRYAN CHUSHCOFF, Judge of the Superior Court,
and the seal thereof, th i& g ^ ^ d a y of March, 2011.
20
21
22
23
24
25
KEVIN STOCK f
CLERK OF THE'SUF'ERIOR CO U RT
C
B y :^ _
Deputy
930 Tacoma Avenue South #110
Tacoma, WA 98402
WRIT OF GARNISHMENT (CONTINUING LIEN ON
EARNINGSBAFTER JUDGMENT) (WRG or $WRG) - 3
W PF GARN 01 0250 (7/2003) - RCW 6 27 100, 340
S \CASES1\Shipm an, Ja so n disso\G arnishm ent\w rit d o c
"T
1
2
3
4
5
6
7
B y .____________________________
DANIEL N COOK, W SBA #34866
Attorney for Respondent
5920 100th Street S.W , Suite 25
Lakewood, WA 98499
8
9
10
11
12
13
14
15
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25
12567
3 /3 8 /2 8 1 1
118870
2
3
4
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,
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iiitiiniiti, ...
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36133474
AFML
03-30-11
tePUYy
6
7
8
Superior Court o f W ashington
County of Pierce
9
10
11
12
and
13
Petitioner,
No.
10-3-00961-1
AFFIDAVIT OF MAILING
14
Respondent.
15
16
17
State of Washington
County of Pierce
) ss
)
18
19
Sally DuCharme, being first duly sworn upon oath, deposes and says:
20
That on the 28th day of March, 2011, she placed true copies of the following
21
22
23
documents:
1.
24
2.
Respondents Calculations
25
3.
Writ of Garnishment
AFFIDAVIT OF M A IL IN G -1
S:\CASES1\Shipman, Jason disso\Gamishment\MAILdef.doc
ORIGINAL
-IfESer?*. 3 ^ 34*X 2 9 1 1
118871
4.
Copy of Judgment
5.
Notice of Garnishment
6.
Exemption Claim
2
3
4
5
6
7
8
That she placed and affixed proper postage stamps to each said envelope,
9
10
11
12
certified mail, return ijeceipt, and first class mail, sealed the same, and placed them in a
receptacle maintained by the United States Post Office for the deposit of letters for
mailing in the City of Lakewood, County of Pierce, State of Washington.
13
14
15
Subscribed and sworn to before me this 28th day of March, 2011.
16
17
NOTARY PUBLIC in and for the State of
Washington residing at Pierce County.
Name: Paula J. Ledbetter
My commission expires: 3/27/13
18
19
20
21
22
23
24
25
AFFIDAVIT OF MAILING- 2
S:\CASES1\Shipman, Jason cJisso\Gamishment\MAILdef.doc
1258?
3 /3 0 ^ 2 8 1 1
110872
1
2
3
4
5
6
7
8
S uperior Court of W ashington
County of Pierce
9
10
11
12
Petitioner,
13
and
14
15
16
No.
10-3-00961-1
Respondent.
FRANCISCAN HEALTH SYSTEM
17
Garnishee Defendant
18
19
State of Washington
)
)s s
20
County of Pierce
21
Sally DuCharme, being first duly sworn upon oath, deposes and says:
22
That on the 28th day of March, 2011, she placed true copies of the following
23
documents:
24
1-
25
AFFIDAVIT OF M A IL IN G -1
S:\CASES1VShipman, Jason disso\Gamishment\MAILempl.doc
qR1
\NM-
253-581-0660
12567
3 / 3 8 / 2 8 1 1 U *87.3
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1
2.
Respondent's Calculations
3.
Writ of Garnishment
4.
Copy of Judgment
5.
2
3
4
5
6.
7
On file in the above entitled matter in envelopes addressed as follows:
8
9
10
11
12
That she placed and affixed proper postage stamps to each said envelope,
13
certified mail, return receipt, sealed the same, and placed them in a receptacle
14
maintained by the United States Post Office for the deposit of letters for mailing in the
15
16
17
Bally
DuC&sfirme
-^ S a
lly DuCfctSrrme
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19
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23
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25
AFFIDAVIT OF MAILING- 2
S:\CASES1\Shipman, Jason disso\Gamishment\MAILempl.doc
4 S X 2 K 2 &11
10-3-00961-1
36205050
ANWRGR
,N c unty CLERK'*
OFF/C
04-12-11
10
APS J J 2fl)(
8
9
132 27 413517 3
In re the marriage of
JENNIFER KAY SHIPMAN
No.
10-3-00961-1
11
Petitioner,
12
and
13
14
15
16
Garnishee Defendant
17
18
19
20
21
22
23
24
25
SECTION I
On the date the Writ of Garnishment was issued as indicated by the date
appearing on the last page of tJie writ,
(A)
The Petitioner [*] was [ ] was not employed by Garnishee If not
employed, and you have no possession or control of any funds of Petitioner, indicate
the last day of employment _________________; and complete Section III of this
Answer and mail or deiivepdhe forms as directed in the Writ.
(B)
Petitioner [vf did [*Ldid not maintain a financial account with Garnishee.
(C)
The Garnishee did [ ] did not have possession of or control over any
funds, personal property, or effects of Petitioner {List all of the Petitioner's personal
property or effects in your possession or control on the bottom of the last page of this
answer form or attach a schedule if necessary )
If you are withholding the Petitioners nonexempt earnings under a previously
ANSW ER WPF GARN 01 0750 (7/2003) - RCW 6 27 190, 340
S \CASES1\Shipman Jason disso\Garnishment\answer doc
<*
1
2
3
4
5
6
7
4 ^ l2 /2 g J L l
13227
4 b 8 1 7 4
served writ for a continuing lien answer only Sections I and III of this form and mail or
deliver the forms as directed in the writ Withhold from the Petitioners future
nonexempt earnings as directed in the writ and a second set of answer forms will be
forwarded to you later
ANSWER I am presently holding the Petitioner s nonexempt earnings under a
previous writ served o n __________________ (date) that will terminate not later than
____________
(date)
If you are NOT withholding the Petitioners earnings under a previously served
writ for a continuing lien, answer this entire form and mail or deliver the forms as
directed in the writ A second set of answer forms will be forwarded to you later for
subsequently withheld earnings.
SECTION II
8
9
10
11
12
13
14
At the time of service of the Writ of Garnishment on the Garnishee, there was
due and owing from the Garnishee to the above-named Petitioner $______________.
This writ attaches a maximum of 25 percent of the Petitioners disposable
earnings (that is, compensation payable for personal services, whether called wages,
salary, commission, bonus, or otherwise, and including periodic payments pursuant to a
nongovernmental pension or retirement program). Calculate the attachable amount as
follows.
Gross Earnings
$__________________ (D
Less deductions required by law (Social Security, federal
withholding tax, etc. Do not include deductions for child
support orders or government liens here. Deduct child
support orders and liens on line 7):
15
16
17
18
19
20
21
22
23
24
25
$______
Monthly
$_
$______
*These are minimum exempt amounts that the Petitioner must be paid If
your answer covers more than one pay period, multiply the preceding amount
by the number of pay periods and/or fraction thereof your answer covers If
you use a pay period not shown, prorate the monthly exempt amount.
Subtract the larger of lines 4 and 5 from line 3:
Enter amount (if any) withheld from this paycheck for
ongoing government liens such as child support:
Subtract line 7 from line 6. This amount must be held
out for the Respondent
ANSW ER WPF GARN 01 0750 (7/2003) - RCW 6 27 190, 340
S \CASES1 \Shipman Jason disso\Garnishment\answer doc
$________________ (6)
$________________ (7)
$________________ (8)
FAUBION, REEDER, FRALEY
& COOK, P S
5920 - 100mSt SW #25
Lakewood, WA 98499
253-581-0660
13ZZ7
4& S175
This is the formula that you will use for withholding each pay period over the
2
required 60-day garnishment period Deduct any allowable processing fee you may
3
5
6
SECTION III
Under penalty of perjury, I affirm that I have examined this answer, including
10
11
12
accompanying schedules, and to the best of my knowledge and belief, it is true, correct
and complete.
Dated:
V - ? ' / / ___________
13
14
15
16
f J
17
18
19
20
J e t iM F e e .
Print name of person signing
21
24
Phnnp Nrimhpr
Catholic Health Initiatives
Garnishment Department
3900 Olympic Blvd , Suite 400
Erlanger, KY 41018-1099
25
pages
22
23
340
ST CLARE HOSPITAL
55218
23546907
FIPS
SHIPMAN, JENNIFER K
Payment Type Direct Deposit
Gross Pay
10-3-00961-1
Department
3071 34
Disposable
Income
Exempt Wages
2333 88
1750 41
3136
Page
company 8900
CATHOLIC HEALTH INITIATIVES
Garnishment Audit Report
Report Sequence Proc Level/Dept/Emp Name
ORTHOPEDIC SURGICAL
SSN 536-88-2306
Payment Date 04/08/2011
Garn
Ded
G20P
Amount
583 47
ClrHse
Fee
0 00
Arr
Court Fee Ded
0 00
Amount
0 00
Fee
Com t
Arreas Fee Ded
0 00
Amount
0 00
583 47
0 00
0 00
0 00
583 47
0 00
0 00
0 00
583 47
0 00
0 00
0 00
583 47
0 00
0 00
0 00
Employee Total
Department 3136
Total
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
5
6
7
Superior Court of Washington
County of Pierce
8
9
10
JENNIFER KAY SHIPMAN
No.
10-3-00961-1
11
12
13
14
15
Petitioner,
and
FIRST ANSW ER TO W R IT OF
G ARNISHM ENT FOR
CONTINUING LIEN ON
EARNINGS (ANWRGR)
16
G arnishee Defendant
17
18
19
20
21
22
23
24
25
SECTION I
On the date the Writ of Garnishment was issued as indicated by the date
appearing on the last page of the writ,
(A)
The Petitioner [*] was [] was not employed by Garnishee. If not
employed, and you have no possession or control of any funds of Petitioner, indicate
the last day of employment: ___________________ ; and complete Section III of this
Answer and mail or delivep-the forms as directed in the Writ.
(B)
Petitioner M did |U/did not maintain a financial account with Garnishee.
(C)
The Garnishee [fdid [ ] did not have possession of or control over any
funds, personal property, or effects of Petitioner. (List all of the Petitioner's personal
property or effects in your possession or control on the bottom of the last page of this
answer form or attach a schedule if necessary.)
If you are withholding the Petitioners nonexempt earnings under a previously
ANSWER: W PF GARN 01.0750 (7/2003) - RCW 6.27.190, .340
S:\CASESHShipman, Jason disso\Garnishment\answer.doc
served writ for a continuing lien, answer only Sections 1and III of this form and mail or
deliver the forms as directed in the writ. Withhold from the Petitioners future
nonexempt earnings as directed in the writ, and a second set of answer forms will be
forwarded to you later.
ANSWER: I am presently holding the Petitioners nonexempt earnings under a
previous writ served o n __________________ (date) that will terminate not later than
_
(date).
If you are NOT withholding the Petitioners earnings under a previously served
writ for a continuing lien, answer this entire form and mail or deliver the forms as
directed in the writ. A second set of answer forms will be forwarded to you later for
subsequently withheld earnings.
SECTION ii
At the time of service of the Writ of Garnishment on the Garnishee, there was
due and owing from the Garnishee to the above-named Petitioner $
This writ attaches a maximum of 25 percent of the Petitioners disposable
earnings (that is, compensation payable for personal services, whether called wages,
salary, commission, bonus, or otherwise, and including periodic payments pursuant to a
nongovernmental pension or retirement program). Calculate the attachable amount as
follows:
Gross Earnings:
$__________________ (1)
Less deductions required by law (Social Security, federal
withholding tax, etc. Do not include deductions for child
support orders or government liens here. Deduct child
support orders and liens on line 7):
Disposable Earnings (subtract line 2 from line 1):
Enter 75 % (percent) of line 3:
Enter one of the following exempt amounts*:
If paid Weekly $______ Semi-monthly
-
Bi-weekly
$_______
Monthly
$_
$.
*These are minimum exempt amounts that the Petitioner must be paid. If
your answer covers more than one pay period, multiply the preceding amount
by the number of pay periods and/or fraction thereof your answer covers. If
you use a pay period not shown, prorate the monthly exempt amount.
Subtract the larger of lines 4 and 5 from line 3:
Enter amount (if any) withheld from this paycheck for
ongoing government liens such as child support:
$______________
$_________________(8)
$_________________(6)
(7)
This is the formula that you will use for withholding each pay period over the
required 60-day garnishment period. Deduct any allowable processing fee you may
charge from the amount that is to be paid to the Petitioner.
If there is any uncertainty about your answer give an explanation on the last
page of this answer form, or on an attached page.
SECTION III
7- / /
P h o n e N um ber
___________ ___________-
Af
pages
ANSW ER: W PF GARN 01.0750 (7/2003) - RCW 6.27.190, .340
S:\CASES1VShipman, Jason disso\GarnishmentVanswer.doc
Company 8900
CATHOLIC HEALTH INITIATIVES
Garnishment Audit Report
Report Sequence Proc Level/Dept/Emp Name
ST CLARE HOSPITAL
55218
23546907
FIPS
SHIPMAN, JENNIFER K.
Payment Type Direct Deposit
Gross Pay
10-3-00961-1
3071 .34
Employee Total
Department
Disposable
Income
Exempt Wages
2333.88
1750,41
3136
Page
ORTHOPEDIC SURGICAL
SSN 536-88-2306
Payment Date 04/08/2011
Garn
Ded
G20P
Amount
583 .47
ClrHse
Fee
0.00
Arr
Court Fee Ded
0.00
Amount
0.00
Court
Fee
Arreas Fee Ded
0.00
Amount
0.00
583 .47
0 .00
0.00
0.00
583.47
0 .00
0.00
0.00
583.47
0 .00
0.00
0.00
583.47
0 .00
0.00
0.00
Department 3136
Total
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
May 17 2011 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
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
Motion - Modify Temp Order
Calendar: Show Cause/Family Law
9:30 AM
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
LAKEWOOD, WA 98499-2751
1 of
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
May 18 2011 11:24 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
NO. 10-3-00961-1
PETITION FOR M ODIFICATION /
MOTION FOR A D JU STM EN T OF
TEM PORARY CHILD SU PPO R T AND
PARENTING PLAN
COMES NOW the Respondent, JASON SHIPMAN, by and through his attorney
of record, Daniel Cook, of FAUBION, REEDER, FRALEY, & COOK, P.S., and moves
the court for:
An order adjusting the support provisions of the most recent Order of Child
Support.
This motion is based upon the following declaration, the Sealed Financial
Source Documents and the Child Support Worksheet and Financial Declaration which
have been, are or will be filed with herewith.
Modifies the parenting plan to give the father first right of refusal for daycare and
orders the mother to allow the children to bring clothes, toys and games to the fathers
during residential time the children spend with the father.
Petition / Motion to Modify / Adjust Child Support
and Parenting Plan - Page 1 of 5
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
Orders that the Mother be 100% responsible for daycare expenses she incurs
2
when the father is available as an alternate care provider for before and after school care
3
4
5
8
Daniel N. Cook, WSBA 34866
Of Attorneys for Respondent
9
10
DECLARATION
11
12
My wife and I were married on April 24, 1994. Two children were born during our
13
14
temporary child support order was entered on August 24, 2010. I am filing this motion
15
16
17
The child support order was based upon both parents working full-time as they
had during their marriage.
18
worked as an installation and maintenance technician for two security companies for 7
19
20
21
22
23
On or around May 1 ,2 0 1 1 , I was laid off from my job when, at the time of layoff, I
had worked for 8 years in the industry with no periods of unemployment.
My wife
contributed to the lay off. She called my employer and falsely stated that I had stolen
24
from the company and that the stolen materials and equipment were located in her
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
Based upon my wifes allegations, my employer and the corporate attorney set
up a time to meet with my wife to retrieve the allegedly stolen property; however, only a
day or two before the scheduled meeting my wife called and canceled the meeting.
Since that time I have been viewed suspiciously by my employer and when decisions
were made to lay individuals off I was at the top of the list.
Prior to my wifes
allegations 1 was a good employee with a long term future at the company. There is no
question in my mind that her allegations substantially contributed to the loss of my job.
I am now on unemployment and need to modify the support order which was
based upon my income before I was laid off. I will receive $479 a week and 10% will be
taken out for Federal income Tax. I will not have to pay FICA while on unemployment.
My child support worksheets use this calculation for my income and adopt the same
figures the court reached at the Temporary Order hearing for my wife.
I am a Union Member.
number in priority for being re-assigned to a new job. I understand the estimated time
for a position to open for me is approximately 12 months from now. During this period
of unemployment I am absolutely available to care for the children and would welcome
the opportunity to spend extra time with them while I am off.
It would be a wonderful
opportunity for me to use this unfortunate event (layoff) to some good as the children
can utilize this opportunity to make up time they have sorely needed and missed since
our separation.
My wife is very angry at me.
and emotionally make this process difficult on me. I incorporate herein by reference my
motions and declarations regarding use of the home and payment the house when she
Petition / Motion to Modify / Adjust Child Support
and Parenting Plan - Page 3 of 5
FAUBION, REEDER,
FRALEY & COOK, P.S.
2
regarding the house she took the opposite position in order to make things more
3
4
5
difficult.
My wife was also found in contempt for changing the childrens school
because of her bitterness toward me even though it would be financially beneficial to the
10
11
12
better for the children to spend more time with me. My home is less than five minutes
walking distance from either childs school but my wife refuses to authorize the children
to even come over after school before she gets done with work.
13
modify the parenting plan to allow me first right of refusal for before and after school
14
care and to order my wife to be 100% responsible for any daycare expenses she incurs
15
16
17
18
their residential time with me. I have asked her to send clothes with them for weekend
19
visits.
20
and after they wear them back to her house I never see the clothes I bought again. My
21
son has often told me he would like his bike at my house, and I have asked my wife to
22
23
24
independently, but since I am going to court anyway because of the change regarding
25
FAUBION, REEDER,
FRALEY & COOK, P.S,
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
would hope that my wife wiil agree to a temporary reduction in support because of my
unemployment, but I do not think she will. Even though our trial date is coming soon, I
need the relief from the current Order of Support so that my unemployment checks are
not garnished at a higher level and so that there is not uncertainty as to the daycare
situation.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
STATE OF W ASHINGTON THAT THE FOREGOING IS TR U E AND CORRECT.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
May 18 2011 11:24 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
MOTHER
COUNTY
FATHER
JASON WILLIAM SHIPMAN
SUPERIOR COURT/OAH CASE NO. 10-3-00961-1
WORKSHEETS
Children and Ages Tyler 16, Hunter 9
Part I: Basic S upport O bligation (See instructions, page 1)
1. Gross Monthly Income
Father
M other
$2,075.67
$6,192.00
$0.00
$0.00
c. Business Income
$0.00
$0.00
d. Maintenance Received
$0.00
$0.00
e. Other Income
$0.00
$0.00
$2,075.67
$6,192.00
Father
M other
$207.57 j
$1,475.78
$0.00
$0.00
$0.00
$0.00
$0.00
$80.00
$0.00
$0.00
f. Maintenance Paid
$0.00
$0.00
$0.00
$0.00
$207.57
$1,555.78
$1,868.10
$4,636.22
$887
Hunter
$718
(advisory)
28.72%
71.28%
$460.96
$1,144.04
obligation of $25 per child. Number of children: 2. 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 for Child(ren)
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$ 0.00
$80.25
$0.00
$ 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 parent's day care and special expenses from line 9e)
WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2008 page 2 of 5
$ 0.00
11. Total Extraordinary Health Care, Day Care, and Special Expenses
Mother
$0.00
$0.00
$460.96
$1,144.04
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$460.96
$1,144.04
$840.65
$2,086.30
$737.10
$3,505.22
$460.96
$1,144.04
Father's
Household
Mother's
Household
Father's
Household
M other's
H ousehold
j
18. 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. Income of Children (If considered extraordinary)
Name
Name
d. Income From Child Support
Name
Name
e. Income From Assistance Programs
Program
Program
f. Other Income (describe)
Judge/Reviewing Officer
Date
This worksheet has been certified by the State of Washington Administrative Office of the Courts.
Photocopying of the worksheet is permitted.
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
May 18 2011 11:24 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
NO. 10-3-00961-1
RESPO N D EN TS W ITNESS LIST
JA SO N W ILLIAM SHIPM AN
_______________________ Respondent.
COMES NOW the Respondent, JASON SHIPMAN, by and through his attorney
of record, Daniel Cook, of FAUBION, REEDER, FRALEY, & COOK, P.S., and hereby
discloses the following possible primary witnesses:
W ITN ESSES EXPECTED TO BE CALLED A T TIM E OF TRIAL:
Jason Shipm an
C/O Faubion, Reeder, Fraley & Cook P.S.
5920-100th Street SW, Ste 25
Lakewood, W A 98499
253-581-0660
Witness is Respondent in this matter. He will testify to all relevant matters.
Respondent's Witness List - Page 1 of 3
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
Jennifer Shipman
c/o Timothy Greene, attorney for Petitioner.
Witness is Petitioner in this matter.
Charles Papas
262 s. 3rd Street
Buckley, W A 98321
253-569-0228
Witness is a real estate agent and he can testify as to circumstances surrounding sale
of the home and cooperation of both parties regarding the same.
C hanthy Lodge
5605 112th Street E, Suite 600
Puyallup, W A 98373
253-904-1081
Witness is a Mortgage Loan Coordinator and she can testify as to the Respondents
attempts to refinance and keep house prior to separation.
B ecky Ram bo
11721 80th Avenue East
Puyallup, W A 98373
253-840-2301
Witness is Respondents mother who can testify about the both parents performance of
parenting functions, the childrens bonding and attachment with both parents and the
practicality of the Respondent/father or herself providing before and after school care.
FAUBION, REEDER,
FRALEY & COOK, P.S.
of May 2011.
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
June 02 2011 2:38 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
NO. 10-3-00961-1
Petitioner,
v.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
DECLARATION OF MAILING
I, Sally DuCharme, am over the age of 18, and competent to testify in the abovecaptioned case.
On May 18, 2011, I mailed true and correct copies of the above Notice of Intent
to Withdraw. The documents were mailed via first class mail, via regular mail,
postage pre-paid, to:
Jason Shipman
8811 - 133rd St Ct. E.
Puyallup, W A 98373
l DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
STATE OF W ASHINGTON, THAT THE FOREGOING IS TR U E AND CORRECT.
Sally DuGfiarme
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100TH Street SW, Ste 25
Lakewood WA 98499
253-581-0660
1 3 8 2 b 6 / 1 6 / 2 0 1 1
3201S9
4
5
6
7
No. 10-3-00961-1
Petitioner(s),
and
10
11
12
DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
FOR MODIFICATION
OF TEMPORARY ORDERS
13
14
15
16
17
18
19
Jennifer Shipman
Age:
First of all. I worked as an RN for ten years, not the 5-6 years that Jason states in his
Declaration. This is not a material mistake for the purposes of this Declaration, but f
wanted to set the record straight.
20
I did not contribute to Jasons layoff. I did call Jason's employer and said that Jason had
21
left company materials and equipment in his garage. I did that over one year ago.
22
23
c":
DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
TO MODIFY TEMPORARY ORDERS
laS-25.
3 2 d i6 g
1
2
T nailed
Jasons employer because Jason had moved out of the house and, in fact, had left
materials and equipment belonging to his employer in the garage. I acted in good faith
because the equipment and materials belonged to Jason's employer and I wanted to give
the rightful owner the opportunity to get the equipment back: and, also. I did not want to
be held responsible for the equipment, and accused of being in possession of stolen
property, since 1 had not taken the equipment and materials in the first place, and Jason
had not consulted me when he started storing the equipment and materials in our garage.
7
8
9
A meeting was never set up between me and the attorney for Jasons employer. I was
advised by Jasons employer to have mv attorney call the attorney for Jasons employer,
and I told mv attorney. Mr. Greene. Mr. Greene advised me that if Jasons
employer
wanted the equipment and materials, the employer would just come out and retrieve it.
and that I had done mv duty bv giving his employer notice that the equipment and
10
materials were there. If Jason had not wanted me to be concerned about the material and
11
equipment from his employer in our garage, he should have removed it when he moved out
or shortly thereafter. Jason provides no proof that he was laid off because of this incident.
12
13
14
If Jasons employer was concerned, certainly there would have been an investigation that
Jason could have documented, and certainly the employer would not have waited over a
year to terminate Jason.
15
Jason has the right to have his support payments modified if he has been laid off. But he
16
should first provide proof of how much his unemployment checks are through payment
stubs from Employment Security. He should also be required to provide an updated
17
18
19
20
Financial Declaration. Finally, he should provide evidence of his job searching efforts, as he
is required bv Employment Security to contact three prospective employers weekly. Also
the figures that Jason has provided regarding mv income are incorrect. I am filing a
Financial Declaration and Sealed Financial Source Documents which document mv correct
income. I am accordingly also filing mv own proposed Child Support Worksheets.
21
22
23
DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
TO MODIFY TEMPORARY ORDERS
i38Z b
6^ 1 6 ^ 2 8 1 1
328161
refused to disclose anv information about her for the last 10 months that I have inquired.
Jason refused to give me her name, and called m v crazv (and worse), when I asked to have
a background check done on her. Certainly. I have the right to know about anv adult living
in Jason's household if the bovs are going to be staving with him. And, if I ever chose to
have anv other adult living with me. Jason would have the same rights of disclosure. The
7
8
9
womans name is Melissa Jill Hart. When I asked Jason about her. I received phone and
text messages filled with verbal abuse. I finally obtained her name and some information
about her. So. I did some checking on mv own and discovered that a Melissa Jill Hart was
either arraigned or convicted in Kittitas County Superior Court ( Case #10-1-00121-1) of
second degree burglary and malicious mischief). I also had obtained Ms, Harts maiden
10
name and determined that she has had some issues in state district courts, though at this
11
time 1 do not know if they are criminal matters or traffic infractions.. When I confronted
Jason with this information, he admitted that Ms. Hart had been in trouble with the law.
12
13
14
and that she had caught a previous boyfriend cheating on her, and she damaged his car
with thrown rocks, and entered his home and continued to commit property damage inside.
I have ordered a
copy
Superior Court to find out mvself what has happened, and, among other things, determine
15
if this was a prior act of domestic violence. Besides the potential nature of the crimes
16
themselves. I am concerned because Jason owns several guns, and keens them in his
apartment: I am fearful that Ms. Hart may have a violent disposition with guns on the
17
property.
18
19
20
21
This being said, a full disclosure of Ms. Harts criminal record and rehabilitation (if any)
mav change mv position on this issue. 1 do want to be reasonable, and do want mv bovs to
have a normal relationship with their father. But this information on Jasons girlfriend is
disturbing. I note that she often drives the bovs around, and her involvement with the hoys
would only increase under the right of first refusal proposal of Jasons.____________
22
23
DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
TO MODIFY TEMPORARY ORDERS
i3fcJ2b
6 / i fe / ^ 2 8 1 i
326162
1
2
Jason is a hypocrite on this issue, and on the issue of saving daycare costs me changing
schools._______________________________________________________________________
3
4
I was found in contempt because I moved and 1 enrolled the children in different schools
close bv to where I live without Jasons input. The court found I had abused the joint
decision-making clause of the parenting plan bv acting
manner which affected the childrens education. I will live with the courts decision,
although I will note that at least I e-mailed Jason and advised him I was moving. I advised
mv attorney and he thought the move was OK. and the new schools were within the same
8
9
school district and were the schools the children would normally go to given the move.
Jason, on the other hand, has for ten months verbally abused me for asking about the
woman he is living with. He savs it is none of mv business. Jason only believes in joint
decision making when it is in his interests.
10
n
Also, the only reason Hunter was put in davcare was because J had to change schools back
again after I was found in contempt. There is nothing wrong with that in and of itself.
12
13
14
1 respect the courts decision. But then Jason has refused to pay a dime for the davcare
anvwav. Accordingly. I have been subsidizing his choice of schools for the bovs (this would
not bother me if Jason would obey the child support order and nav his share of the
support!. The right of first refusal argument is a pretext, because Jason is not paving for
15
davcare anvwav. so the fact that he is unemployed doesnt change anything! I have mailed
16
Jason the carbon copy portions of the checks I used to pav for the davcare bv certified mail
and he has refused to pick them
17
18
19
20
21
up.
m a ile d
the invoices to him bv certified mail. Unless Jason becomes current on his hill immediately.
1 reserve the right to file contempt charges against him for not paving his child care bill.
Jason talks about wonderful opportunities to spend time with the bovs. hut, his
performance as a father has troubled me lately in this dissolution process. He has refused
to help pav anv share of the bovs" expenses in extracurricular activities, and he has not
attended meetings with juvenile probation over Tvlers diversion program, a program Tvler
22
23
DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
TO MODIFY TEMPORARY ORDERS
1382b
621622811
J28163
I
2
3
needs and which has heen very helpful for Tvler.Jason is not doing this to hurt the bovs. T
know he loves the bovs. He is angrv at me. But his anger is hurting the bovs.____________
Regarding the issue of me being ordered to let the bovs bring clothes and toys from mv
household into Jason's . l a m opposed. The reason is that I allowed the bovs to bring their
own clothes from mv household, and then the clothes would not be returned. So. I wisely
stopped letting the bovs bring clothes from mv household. Unless Jason has lost the clothes
I have already sent over, they should have clothes at Jasons household, anvwav.
Regarding tovs. I also am opposed to letting the bovs bring them, as again they will likely
not be returned.. Jason has tovs for the bovs at his house, including video games and
skateboards.
The court should not agree to "right of first refusal until more is known about_________
10
the woman living with Jason. Melissa Jill Hart. The court should adopt mv proposed
11
Child Support Worksheets and Order of Temporary Child Support. The court orderd Jason
and I to enter into co-parenting counseling when the contempt motion is heard, and T
12
13
would ask that the parties enter into that counseling forthwith, and that we split the costs
of the counseling 50/50.
14
15
16
I declare under penalty of perjury under the laws of the state of Washington that the
foregoing is true and correct.
Signed at Puyallup, Washington on June 15, 2011.
17
18
19
20
21
22
23
DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
TO MODIFY TEMPORARY ORDERS
13825
6/18X 2811
328164
fc-g O FFIC E
1HCQU'
15201'
p.m
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF PIERCE
7
8
)
)
) Case No.: 10-3-00961-1
)
) COVER SHEET:
) PETITIONERS FINANCIAL
) DECLARATION
)
)
9
10
JENNIFER SHIPMAN,
Petitioner,
11
And,
12
JASON SHIPMAN,
____________Respondent.
13
To the above named Court
14
Attached please find Petitioners Financial Declaration.
15
16
17
18
19
20
21
22
COVER SHEET:
PROOF OF PARENTING CLASS
1 of 1
0 6 /1 5 /2 0 1 1
0 9 :3 8
FEDEX
253 841-3484
&W
2 S il
3 2 8 i4 ^G E
mounriaQo s
Tim vfer
6fiipm&n
No,
Petitioner.
and
to y
S h ip m
Financial Declaration
D4 Petitioner
[ ] Respondent
(FNDCLR)
a n
Date o f Birth: e h J M
/H
3.3 below)
$ V / 9 /9 0 *
&
[ ] $ _____ _
1X3 unknown
Occupation:
2.2
2.3
H U T Se.
(1)
Yes [ ] No
Where do you work. Employers name and address must be listed on the
Confidential Information Form.
06
0 6 /1 5 /2 0 1 1
09:38
2 5 3 -8 4 1 -3 4 8 4
b. If no:
"
FEDEX
&w
2 s ii
32
(2)
e b o 2 .e >
(0
(2)
(3)
lU a
$
b i
* ^
ge
_____
O ld .
b.
c.
Business Income
d.
Name
s k n r w sh tp n w i ___________
s 5, &/5~. '33
s
j 0
$
$p
$
From
c.
Other Income
f.
g.
p
_
s p
S 5] &*(&>>
s
S
! DU Ofd p
a.
Income Taxes
b.
nCA/Self-emnioymcm Taxes
c.
d.
e.
f-
s tp
g-
h.
S jp ___
%ft Lfi3Qt ~}p
$
$ 4 ______
q .a W .O g ,
$
$
0 6 /1 5 /2 0 1 1
3.4
2 S ii
FEDEX
2 5 3 8 4 1 -3 4 8 4
0 9 :3 8
3 2 8 1 6 PAGE
Miscellaneous Income
a.
b.
$ j f ) _______
% J>
1
$
$
% (p
c.
$ 6V*
Total Miscellaneous Income (add lints 3.4a throuiih 3.4b> $ (t)
__
$
S
S (f>
If the income of either party is disputed, state monthly income you believe is correct and explain below:
Cash on hand
4.2
On deposit in banks
s M
4.3
sjzS_______
4.4
_______
5.1
Housing
Rent, 1st mortgage or contract payments
sh & iS J X )
%a b . b b
Total Housing
5.2
Utilities
Heat (gas & oil)
* -$ ____
Electricity
j iS tD .o o
0B /15/2011
09 :3 8
fedexM
253--B 41-3484
b/M 4 Z B ly
P age
09
s (p O.OD
Telephone
Bui)4 k i - J s aaO'Qd
C,blc .
L *
s Q fto .co
Total Utilities
5.3
320
s^
itZU2Q.
$ ST).DO.
persons
5.4
Other
s 4
$?OCUXi
Children
DO
S i00-00
S0
Day Care/Babysitting
Clothing
Tuition (if any)
Other child-related expenses
(SpOtis)
s 3UD
5.5
Transportation
s S M .lfo
s G jfn .n o
_______
IdfUUUth
$ $//96>.=?s) I M
Total Transportation
5.7
IS J .W
S^
sS h l f
b f s z u io
$z> ,co
o fm sM
0 6 /1 5 /2 0 1 1
FEDEX W P S !
2 5 3 --8 4 1 -3 4 8 4
09 :3 8
b / M
t Z 011
3 2 0 1 fc PAGE
5.8
Education
________
5 SD'OO
Gifts
$ 52.00
Other
$/
(trf. SD
Miscellaneous Expenses
Life insurance (if not deducted from income)
otherlm
).
%AQP-..QD
________
M l.2 k
5.9
s M & 3Q . to
5.10
Re/i Canoe.
JSsUJli. M/te.
5.11
Balance
L o e J ffJ re jk h
JJiD ,LW
shiAs/rf- loan
4 3 , pop
Tast Payment
ib
Month of
Description
of Debt
Description
of Debt
Balance
G uar d
Month of
Last Payment
Amount of
Monthly
Payment
7 i ?
S a lk t Hop
$______
%______
5 ________
$______
Total Monthly Payments for Other Debts and Monthly Expenses
Financial Declaration (FNDCLR) - Page 5 of 6
W PF DRPSCU 01.1550 (6&006) - RCW 26.16.220(1)
s lleQ jfl
0 6 /15 /2 0 1 1
5.12
FEDEX
253 84 i - 34 84
0 9 :3 8
2811
3 Z t1 1 y PaGE *
6. t
6.2
6.3
6.4
6.5
Other:
x4,131. CD
$________
1 declare under penalty o f perjury under the laws of the state of Washington that the foregoing is true and correct.
[City]
LQ^___[Stale] on _ M
______ '
i/
___[Date].
KJ e ,n n & r k ip m a s )___________
Print or Type Name
The follow ing financial records are being provided to the other party and filed separately with the court.
Financial records pertaining to myself:
f t Individual [ ] Partnership or Corporate Income Tax returns fin the years
________
_________________________ . .
. j______________including all W -2s and schedules;
^ Pav stubs for the dates o f 4 / &J/J-'i d w
l l ________________________________ _
[ j Other..
Do not attach these financial records to the financial declaration. These financial
records should be served on the other party and filed with the court separately
using the sealed financial source documents cover sheet (WPF DRPSCU
09.0220). If filed separately using the cover sheet, the records w ill be sealed to
protect your privacy (although they w ill be available to a ll parties in the case,
their attorneys, court personnel and certain state agencies and boards.) See GR
22(C )(2),
13^47
6 /1 W 2 B 1 1 88836
1 111 1
FILED
36617522
AFRSP
06-17-11
a .m .
JUN 16 2011
p.m .
ja y is g g
No. 10-3-00961-1
Petitioners),
DECLARATION OF
JASON SHIPMAN
And
Jason William Shipman
Respondent(s)
Jason Shipman
Age:
I am the respondent
I Declare:
The petitioner did not tell the truth in her response. First, she made many phone calls to
me threatening to call my employer and tell them that 1 had stolen property from them. I
explained to Jennifer that everything in the garage belonged to me and told her where I
got it from. I also told her, that if she felt she was in possession of stolen property, she
should call the police. She also was not truthful about allowing my employer to come to
the house and check the equipment. They tried to set up a time with her and she refused
to allow them to come over. I have a representative from the company on my witness list
who can explain this during the hearing on July 25th.
13947
8 /1 7 / 2 8 1 1
Jennifer is also lying about me not giving her information about my girlfriend, Melissa. I
sent her an e-mail with Melissas phone number and told Jennifer to call her. I have
enclosed a copy of that e-mail. I also told her that Melissa would answer any question she
might have. Melissa has always been willing to sit down and talk to Jennifer. Melissa is
an honest person and always takes responsibility for her actions. The charge against her
was an isolated incident. She is not an angry or violent person. The state prosecutor
wanted to drop the charges against her, but the owner of the property wanted her to pay
for the damages to his shop, even some that she didnt even do. The state and Melissas
attorney hired a private investigator to look into all the damages. I have also enclosed a
copy of the order for the investigator. Melissa has nothing to hide from Jennifer and has
offered to give her a copy of her criminal history. Which only includes this offense and
one when she was nineteen (non-violent offense). There have been several incidents with
Jennifer being violent towards me and our kids. She has tried to say that she is scared of
me but yet I have police reports stating that Jennifer has attacked me.
As for the guns Jennifer says I have in my house, which is also untrue. I gave her all my
guns when 1moved out. Since then I have acquired a shotgun and a youth model rifle for
my son. I keep those guns locked in a safe at my parents home. Melissa doesnt believe
in carrying guns. Jennifer has told me a couple of times that she carries a gun in her purse
so I better watch out. Jennifer continues to do spiteful things and accuses me doing them.
She doesnt see that the things she is doing are wrong. I have tried on numerous
occasions to get Jennifer to go to counseling with me. My employer would have paid for
it. She refused to go. She just keeps saying that as long as I live with another woman she
will never talk to me.
Jennifer has never allowed the kids to bring toys or clothes to my house. I tried to take
the boys to her house to get clothes and she locked the boys out. Our youngest son has
come to my house crying because his mom refuses to let him bring his bike to my house.
I have purchased clothes for the kids, but when the go to their mothers house I never see
those clothes again. I have asked her to send at least one change of clothes so they dont
have to go to school in clothes that they have been wearing all weekend. She also refuses
to do that. It is ridiculous that she doesnt see how badly she is hurting the boys by doing
things like this.
1 am enclosing copies of my unemployment check stubs. I make $267.00 a week after
child support, I am having a hard time paying rent let alone all other expenses, electric,
water and etc. The daycare expense for Hunter could be completely avoided, if Jennifer
would allow me or my parents to take him to school in the mornings. She is being
completely unreasonable about this.
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WE REDUCED YOUR PAYMENT FOR THE WEEK( S) ENDING 0 6 / 1 1 / 1 1 YOUR WEEKLY B E N E F IT AMOUNT j lS REDUCED BECAUSE:
1.
2.
OR
YOU WERE NOT A BLE TO WORK OR A V A IL A B L E FOR WORK ONE OR TWO DAYS DURING THE
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1347
^ 1 7 /2 6 1 i
a63S
Page 1 o f 4
g IK
tyt'OO^le
To: [email protected]
What r u talking about
[Quoted text hidden]
[email protected] <[email protected]>
To: [email protected]
I don't know what your problem is this time. What stuff r u making up today. What do you mean stuff I left
behind. Ueft everything behind, i took my clothes and a few personal items. You have everything we
acquired over 16 years. I left it all to be nice. You cant appreciate that. I have always though of you through
this. You treated me awful anyway. Be. Specific what did I leave behind. Oh yea my whole life. You did this.
You wanted this not me. Stop being crazy. Think about the kids. Stop telling them bad stuff about their dad. I
don't do that to you.
On Oct 2, 2010 8:54 PM, <chewQirl015fSlvzw.blackberrv.net> wrote:
> I have witnesses you foo)
> Original Message
> From: jason shipman <[email protected]>
> Date: Sat, 2 Oct 2010 20:53:44
> To: <[email protected]>
> Subject: Re:
>
> What r u talking about
>
https://mail.google.com/mail/?ui=2&ik=8bfal 3ada4&view=pt&search^inbox&th=12b70...
10/14/2010
13847
f e /i7 ^ Z o ll
.8 1 5 8 4 8
Page 1 o f 1
hyOooglc'
(no s u b ject)
2 messages
[email protected] <[email protected]>
To: [email protected]
Melissa's phone number is 253-278-3940. She has nothing to hide. She will give you her name. She is a nice
person. Just ask her anything you want.
[Quoted text hidden]
hrtps://mail.google.corn/mail/?ui=2&ik=8bfal3ada4&view=spt&search=inbox&th=12b6b...
10/14/2010
13847
& /1 7 /Z 8 1 1
@ 8 64 1
[email protected] <[email protected]>
Reply-To: chevygirlOl [email protected]
To: ASSHOLE <[email protected]>
Page 2 o f 4
You know what, just fuck off. Lies. That's all you know. You are your fathers son.
From: jason shipman <[email protected]>
Date: Sat, 2 Oct 2010 21:03:09 -0700
[Quoted text hidden]
Jennifer please stop acting like this. I will always try to be your friend. I will always do my best to keep the
kidding mind. Please think of them. I wish you could calm down. You have a great man in your life. Two
wonderful kids. You found God. But you still want to make my life miserable. I don't understand. You are
hurting the boys
On Oct 2, 2010 9:31 PM, [email protected]> wrote:
> You know what, just fuck off. Lies. That's all you know. You are your fathers son.
> Original Message
> From, jason shipman <[email protected]>
> Date: Sat, 2 Oct 2010 21:03:09
> To: <[email protected]>
> Subject: Re:
>
> I don't know what your problem is this time. What stuff r u making up
> today. What do you mean stuff I left behind. I left everything behind. I
> took my clothes and a few personal items. You have everything we acquired
> over 16 years. I left it all to be nice. You cant appreciate that. I have
> always though of you through this. You treated me awful anyway. Be. Specific
> what did I leave behind. Oh yea my whole life. You did this. You wanted
> this not me. Stop being crazy. Think about the kids. Stop telling them bad
> stuff about their dad. I don't do that to you.
> On Oct 2, 2010 8:54 PM, [email protected]> wrote:
I have witnesses you fool
Original Message
From: jason shipman cputiawOOl [email protected]>
Date: Sat, 2 Oct 2010 20:53:44
To: <[email protected]>
Subject: Re:
>
For the last time, fuck off! Why am I like this? Really? U don't know? Well then u never loved me. Be happy
with ur scank. A scank living w/a married man...
I wish you would stop texting me this stuff.
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view^pt&search=mbox&th=12b70...
10/14/2010
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>
> I don't know what your problem is this time. What stuff r u making up
> today. What do you mean stuff I left behind. I left everything behind. I
> took my clothes and a few personal items. You have everything we acquired
> over 16 years. I left it all to be nice. You cant appreciate that. I have
> always though of you through this. You treated me awful anyway. Be. Specific
> what did I leave behind. Oh yea my whole life. You did this. You wanted
> this not me. Stop being crazy. Think about the kids. Stop telling them bad
> stuff about their dad. I don't do that to you.
> On Oct 2, 2010 8:54 PM, <[email protected]> wrote:
l have witnesses you fool
Original Message
From: jason shipman <[email protected]>
Date: Sat, 2 Oct 2010 20:53:44
To: <[email protected]>
Subject: Re:
>
You are so immature you text nasty stuff then block my number
III cut and past it. Then put it in email form. I'm done being treated like this. Its all for you. I tolerate you
craziness for our kids. I love you and them. I can't live with you. I'll try to be your friend
On Oct 2, 2010 9:31 PM, <[email protected]> wrote:
> You know what, just fuck off. Lies. That's all you know. You are your fathers son.
> Original Message
> From: jason shipman <[email protected]>
> Date: Sat, 2 Oct 2010 21:03:09
> To: <[email protected]>
> Subject: Re:
>
> I don't know what your problem is this time. What stuff/ u making up
> today. What do you mean stuff I left behind. I left everything behind. I
> took my clothes and a few personal items. You have everything we acquired
> over 16 years. I left it all to be nice. You cant appreciate that. I have
> always though of you through this. You treated me awful anyway. Be: Specific
> what did ! leave behind. Oh yea my whole life. You did this. You wanted
> this not me. Stop being crazy. Think about the kids. Stop telling them bad
> stuff about their dad. I dont do that to you.
> On Oct 2, 2010 8:54 PM, <[email protected]> wrote:
I have witnesses you fool
Original Message
From: jason shipman <[email protected]>
10/14/2010
138 4 7
fc/l W Z H l i
88043
Page 4 o f 4
>
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search=inbox&th-12b70..*
10/14/2010
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Unbelievable mansion. He treats me well, like a man should treat a woman. I will have him get her last name.
I'm in a good place. Good bye.
From: jason shipman <[email protected]>
Date: Fri, 1 Oct 2010 21:26:03 -0700
[Quoted text hidden]
Do you read what you say. You dont want a divorce but you have a wonderful man in your life. And get
whose last name is that a threat. For the third, time what info do you want l will sigh the papers. The only
thing I ask is stay in the house until it sells. Please don't switch the kids schools. Ill help in any way I can w
work at the house or whatever I can. What info do you need.
On Oct 1, 2010 9:42 PM, <[email protected]> wrote:
> I'm done. You didn't give me the info.
>
> I did not and still don't want this divorce. This is 100% your doing. Not mine. You are the one insisting to
ruin our family. You brought that trash into our kids lives. How disgusting.
>
> Im better off without you now. I'm going to church. I'm accepting my faults as well as my goods. My man is
wonderful. He is Marvelous. Excellent job. Well respected in the community. His kids are super. Great cook.
Unbelievable mansion. He treats me well, like a man should treat a woman. I will have him get her last name.
I'm in a good place. Good bye.
> Original Message---> From: jason shipman <outlaw0015faiQmail.com>
[Quoted text hidden]
[email protected] <[email protected]>
Repty-To: [email protected]
To: ASSHOLE <[email protected]>
What part of I can't afford the mortgage payments don't you get? I can't.
No threat. I have every right to know about the woman of the month you have around my kids. Just like you
have the same right. What is her name?
From: jason shipm an <o u tlaw 0015@ Q m ail.com >
Date: Fri, 1 Oct 2 01 0 2 2 :1 8 :1 7 -0 7 0 0
[Quoted text hidden]
All you had to do is ask Melissa. What is your boyfriends name. What was your last boyfriends name. The
Guy that took my kids to Seattle. And the Guy before him. Melissa is the only woman around your kids.
Changing schools sucks. Ill help w the house work. Just don't put the kids through that. You r a nurse. I give
you money. Keep them in the same school.
On Oct 1, 2010 10:31 PM, <[email protected]> wrote:
> What part of I can't afford the mortgage payments don't you get? I can't.
>
> No threat. I have every right to know about the woman of the month you have around my kids. Just like you
have the same right What is her name?
Vittnc7/mailpooyle.com/mai!/?ui=:2&ik^8bfal3ada4&view=Dt&search=:inbox&th=12b69...
10/14/2010
Page 6 o f 8
You are pathetic. You can't even provide the simple necessities for your children.! have to do that for you.
Hunter left shoes and jeans at your house on wed. Socks and yet another pair of shoes in football bag. I sent
three shirts with Tyler. 1expect them all (2 sets of shoes, 2 sets of jeans, 3 t-shirts & a sweatshirt) back with
Hunter on Monday.
No games. Give me her last name.
From: jason shipman <[email protected]>
Date: Fri, 1 Oct 2010 21:08:46 -0700
To: <[email protected]>
Subject: Re.
[Quoted text hidden]
Again with fights and lies. He left a pair of shoes and pants here Wednesday. I offered to bring them or you
could come get them. He still has no underwear or socks. I pay my child support through support enforcement
like you asked. This fighting only hurts the kids. Why are you being like this it only hurts the kids. I wouldn't
do this to you. You asked for a divorce three times. I gave it to you. You have a "real man" yet you continue
to be so mean to me. Jennifer l will always care about you. I only want to be friends and work as a team to
raise the boys. Again I ask what info do you need.
On Oct 1,2010 9:15 PM, <[email protected]> wrote:
> You are pathetic. You can't even provide the simple necessities for your children. I have to do that for you.
Hunter left shoes and jeans at your house on wed. Socks and yet another pair of shoes in football bag. I sent
three shirts with Tyler. I expect them all {2 sets of shoes, 2 sets of jeans, 3 t-shirts & a sweatshirt) back with
Hunter on Monday.
>
>
> I picked the boys up at 5. You sent them with no clothes. You picked up
> Tyler took him home to get clothes. Brought him back to my house. Yet
> hunter still didn't get any clothes. How is he going to go to school in the
> food stained clothes. What info are you talking about. Ill get you any
> info you want just ask. What game are you playing now.
> On Oct 1, 2010 4:42 PM, <[email protected]> wrote:
[email protected] <[email protected]!ackberry.net>
Reply-To: [email protected]
To: ASSHOLE <outlaw0015@gmai!.com>
I'm done. You didn't give me the info.
I did not and still don't want this divorce. This is 100% your doing. Not mine. You are the one insisting to ruin
our family. You brought that trash into our kids lives. How disgusting.
Im better off without you now. I'm going to church. I'm accepting my faults as well as my goods. My man is
wonderful. He is Marvelous. Excellent job. Well respected in the community. His kids are super. Great cook.
httDs://mail.oode.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search=inbox&th=12b69...
10/14/20)0
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> Original M es sa g e
> From- jason shiDman <o u tla w 0 0 1 5 @ a m a il.c o m >
[Quoted text hidden]
\
F ri, O c t 1 ,2 0 1 0 a t 1 0 :4 6 P M
F ri, O c t 1 ,2 0 1 0 a t 1 0 :4 8 P M
I didn't or have no reason to check on Troy . Dont know his last nam e. Let help you need medication. If this
Guy w h o m you haven't told me his n am e is so special why r u being like this. Y o u r going to look up my
girlfriend through your FBI boyfriend. D o you forget who I w ork with. T h a t is abuse of his work. If he is a
normal person he wouldn't get cought up in your dram a. G oodnight Jennifer.
On O c t 1, 2 0 1 0 10:38 PM , <chevvQ irl015@ vzw .blackberrv.net> wrote:
S a t, O c t 2, 2 0 1 0 a t 1 :1 7 A M
Fuck you
F ro m : jason shiDman < o u tia w 0 0 1 5 0 a m a il.c o m >
D ate: Fri, 1 O ct 2 01 0 2 2 :4 8 :3 4 -0 7 0 0
T o : < n h e w a ir!0 15 @ vzw .b lackb errv.net>
S u b je c t: Re:
[Quoted text hidden]
httDS://mail-google.com/mail/?ui=2&ik=8bfal 3 ada4&view=pt&search=inbox&th=12b69:.'.
1 0 /1 4 /2 0 1 0
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STATE OF WASHINGTON,
Plaintiff,
vs.
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MELISSA HART,
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No.: 10-L00121-1
Defendant.
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COMES NOW C.K. Powers, Attorney for Defendant, MELISSA HART, and moves the
court for an order appointing the expert services of Marlene Goodman, Investigator, to
investigate and to interview and evaluate parties and witnesses in order to assist in preparing
Defendants defense. This motion is based upon the record and files herein and the declaration
of C,K. Powers, Attorney for the Defendant, subjoined below.
19
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DATED this
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T 3 rt
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DECLARATION
3
4
1.
lam the attorney of record for the above named Defendant in this matter.
2.
Based upon the discovery provided by the State, Defendant is in need of expert
3.
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4.
The Defendant believes that these interviews and evaluations and investigative
services are necessary in providing additional information that will be beneficial
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5.
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6.
The Defendant requests a minimum amount of fifteen (15) hours at $60.00 per
hour for a total of $900.00 for the services of Marlene Goodman for this case.
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Motion for Appt of Expert
Page 2 of 2
cn o oM
130843
FILED
JUL 2 6 2010
JOYGELJULSRUD,CLERK
KITTITASCOUNTYWASHMSTON
/
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9
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STATE OF WASHINGTON,
Plaintiff,
No.: 10-1-00121-1
ORDER APPOINTING EXPERT
SERVICES AND DIRECTING
PAYMENT THEREOF
VS.
MELISSA HART,
Defendant.
12
13
14
ORDER
15
THIS COURT having examined the declaration of counsel for the Defendant and upon
16
the motion of Defendant herein for an order appointing Marlene Goodman, an Investigator, as
17
expert services for the Defendant in the amount not to exceed $900.00, upon completion of
20
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DATED this
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SCOTT R. SPARKS
24
JUDGE
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4 n Q _ < m _ 7 ? 1 1
1384?
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Bi1&5B
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PRESENTED BY:
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Order Appt Expert Services
Page 2 o f2
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J306bl
n
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w ny
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.fi n' f
r. f CL[{7K
No. 10-1-00121-1
V5.
(fjs)
MELISSA J. HART,
Defendant.
10- 9
0 0 7 9 3- 6
SID;
DOB; 04-27-77
I. Hearing
1,1 The court conducted a sentencing hearing this date; the defendant, the defendant's lawyer, and the (deputy) prosecuting
attorney were present.
!L Findings
2.1 Current Offenses: The defendant is guilty of the following offenses, based upon
[Xj guilty plea (dale) 11-19-2010 ) jury-verdict (date) ___________ [ \ bench trial (date):
Count
C rim e
RCW
C la s s
(Wsi/6sec/onJ
i
9A. 52.030
FB
D a te o f
C rim e
04-20-10
(If die crime is a drug offense, include the type of drug in the second column.)
[ | Additional current offenses are attached in Appendix 2.1a.
The jury returned a special verdict or the court made a special Gilding with regard to the following:
[ J The defendant used a firearm in the commission of the offense in Count______________. RCW 9.94A.602,
9.94A.533.
[ j The defendant used a deadly weapon other than a firearm in committing the ofTense in Count________
__ ____________________ . RCW 9.94A.602, 9.94A.533.
I ) Count________________is a criminal street gang-related felony offense in which the defendant compensated,
threatened, or solicited a minor in order to involve that minor in the commission of the offense. RCW 9.94A.833.
[ J Count________
is the crime of unlawful possession of a firearm and the defendant was a criminal street gang
member or associate when the defendant committed the crime. RCW 9.94A.702, 9.94A.
[ ] The defendant has a chemical dependency that has contributed to the offensefs). RCW 9.94A.607.
[ j The crime(s) charged in Count_____________ _______ involve(s) domestic violence. RCW 10.99.020.
[) Count________ is a felony in the commission of which the defendant used a motor vehicle. RCW46.20.285.
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[ i Counts____________;_____ encompass the same criminal conduct and count as one crime in determining the offender
score (RCW 9.94A.5S9).
[ ] Other current convictions listed under different cause numbers used in calculating the offender score are (list
offense and cause n u m b e r):_____ _____________________________ _______________ ____ ____________
Crime
1.
2.
( J Additional current convictions listed under different cause numbers used in calculating the offender score are attached in
Appendix 2.1b.
Date o f
Crim e
Date o f
Sentence
Sentencing Court
(C ounty A State)
A or J
Adult,
Juv.
Type o f
Crim e
3
4
5
[ ] Additional criminal history is attached in Appendix 2.2.
[ J The defendant committed a current offense while on community placement/community custody (adds one point to score).
RCW 9.94A.525.
[ j The prior convictions listed as numbers___________above, or in appendix 2.2, are one offense for purposes of
determining the offender score (RCW 9.94A.525).
a a a 4 v ^ a/. i v / 2 a u
Offender
Score
Serious-
Standard
nose
Range (not
Level
0
nt
Plus
Enhancements*
Total Standard
Range (in c lu d in g
Maximum
Term
enhancements)
in c lu d in g
enhancements)
1 - 3 inos.
1 - 3 mos.
10 years
(F) Firearm f (D) Other deadly weapons, (CSG) criminal street gang involving minor.
[ ] Additional current offense sentencing data is attached in Appendix 2.3.
2.4 [J Exceptional Sentence. The court finds substantial and compelling reasons that justify an exceptional
sentence:
[ ] below the standard range for Count(s) _____________ .
[ ] above the stahdurd range for Count(s)______________ .
[ ] The defendant and state stipulate that justice is best served by imposition of the exceptional sentence above the
standard range and the court finds the exceptional sentence litrthers and is consistent with the interests of
justice and the purposes of the sentencing reform act.
[ J Aggravating factors were [ ] stipulated by the defendant, [ ] found by the court after the defendant waived jury
trial. (] found by jury, by special interrogatory.
[ ] within the standard range for Count(s)_________, but served consecutively to C o u n ts)____________.
Findings of fact and conclusions of law are attached in Appendix 2.4. [ ] Jurys special interrogatory is attached.
The Prosecuting Attorney [ ] did [ ] did not recommend a similar sentence.
111. Judgment
3.1
The defendant is g u ilty of the Counts and Charges fisted in Paragraph 2.1 and Appendix 2. L
3.2
It is ordered:
4.1 Confinement.
(a)
rnonthC on Count l
..months on Count
^months on Count
months on Count
months on Count
J
aAf>
Actual number of manias of total confinement ordered is:
a -A
*Y >
ias4
?y28 i i
seas4
All counts shall be served concurrently, except for the following which shall be served consecutively.
The sentence herein shall run consecutively with the sentence in cause number(s)
but concurrently to any other felony cause not referred to in this Judgment, RCW 9.94A.589.
Confinement shall commence immediately unless otherwise set forth here:_______________________ ___
______ / &
_________________________________________________
M^Partial Confinement The defendant may serve die sentence, if eligible and approved, in purtial confinement
*ln the foiluwing programs, subject to the following conditions:_______________^
_____________ /W
jKJ-work crew RCW4.94A.725
[ ] work release RCW 9.94A.731
| | Conversion of JaU Confinement (Nonviolent and Nonsex Offenses). RCW 9.94A.680(3). The county jail
is authorized to convert jail confinement to an available county supervised community option, to reduce the time
spent in the community option by earned release credit consistent with local correctional facility standards, and may
require the offender to perform affirmative conduct pursuant to RCW 9.94A.
[ J The defendant shall receive credit for time served in an available county supervised community option prior
to sentencing. The jail shall compute rime served.
[ J Alternative Conversion. RCW 9.94A.680, _______________ days of total confinement ordered above are
hereby converted to _______
hours o f community restitution (service) (8 hours = 1 day. nonviolent
offenders only. 30 days maximum) under the supervision of the Department of Corrections (DOC) to be completed
on a schedule established by the defendant's community corrections officer but not less than ___________
hours
per month.
[ | Alternatives to total confinement were not used because of: _____________________________ _
[ ] criminal history [ ] failure to appear (finding required for nonviolent offenders only) RCW 9.94A.680.
(b)
Credit for Time Served: The defendant shall receive credit for time served prior to sentencing if that confinement
was solely under this cause number. RCW 9.94 A.505. The jail shall compute time served.
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The court orders Uiat during the period of supevision the defendant shall;
l ] consume no alcohol.
t | have no contact with:_______________________________________________ __________________
f ] remain [ J within [ j outside of a specified geographical boundary, to wit:
[ | participate in the following crime-related treatment or counseling services:
f J undergo an evaluation for, and fully comply with, treatment for {] domestic violence [ J substance abuse
[ ] mental health [ ] anger management.
[ ] comply with the following crime-related prohibitions:_____________ ___________________________
[ ] Other conditions;
(C) The conditions of community custody shall begin immediately upon release from confinement unless otherwise set
forth here:___________________ ___________________________
Court Ordered Treatment: If any court orders mental health or chemical depenency treatment, the defendant must notify
DOC and the defendant must release treatment information to DOC for the duration of incarceration and supervision.
RCW9.94A.562.
4.3 Legal Financial Obligations: The defendant shall pay to the clerk of this court:
JASS CODE
FCV
PDV
CRC
pun
500
Victim assessment
RCW 7.68.035
RCW 10.99.080
2QQ
600
CLP
RCW 43.43.690
ONI
RCW 43.43.7541
FPV
RCW 76.48.140
. 'U U / F C W
Kittitas County
RCW 9.94 A. 7 60
c d f
S IF -S A D /S D I
WFR
100
RCW 9.94A.760
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S____________ emergency response costs (Vehicular Assault, Vehicular Homicide, Felony DUI only,
$1000 maximum)
RCW J8.52.430
Agency:____ ________________________________________
$ 500________ Restitution to: Seth Grove, 5290 Nelson Siding Rd.. Cle Elum. WA 98922
RTN/RJN
$ 1.250
T&P>
& W-H81.
Restitution to: Straight Arrow NW. PO Box 590. North Bend. WA 98045
Restitution to: Straight Arrow NW. PO Box 590. North Pend. WA 98045
(Name and Address--address may be withheld and provided confidentially
to Clerk of the Courts office.)
Total
KCW9.94A.760
jp^The above total does not include all restitution or other legal financial obligations, which may be set by later order
of the court. An agreed restitution order may be entered. RCW 9.94A.753. A restitution hearing;
j^shail be set by the prosecutor.
f 1 is scheduled for____________________________________________________________ _(date).
[ ] The defendant waives any right to be present at any restitution hearing (sign initials):_____ _______.
( j Restitution Schedule attached.
[ ] Restitution ordered above shall be paid jointly and severally with:
Name of other defendant
C au se Number
(Victims name)
RJN
(Amount-S)
( ] The Department of Corrections (DOC) or clerk of the court shall immediately issue a Notice of Payroll Deduction.
RCW 9.94A.7602, RCW 9.94A.760(8).
j 1All payments shall be made in accordance with the policies of the clerk of the court and on a schedule established by
DOC or the clerk of the court, commencing immediately, unless the court specifically sets forth the rate here: Not
less than $_______ per month commencing______________ _______________ . RCW 9.94A.760.
The defendant shall report to the clerk of the court or as directed by the clerk of the court to provide financial and other
information as requested. RCW 9.94A.760(7)(b).
[ ] The court orders the defendant to pay costs of incarceration at the rate of $__________ per day, (actual costs not to
exceeds 100 per day). (JLR) RCW 9.94 A.760.
The financial obligations imposed in this judgment shall bear interest from the date of the judgment until payment in
full, at the rate applicable to civil judgments. RCW 10.82.090. An award of costs on appeal against the defendant may
be added to the total legal financial obligations. RCW 10.73.160.
4 .4
D N A T e s tin g . The defendant shall have a biological sample collected for purposes of DNA identification analysis
and the defendant shall fully cooperate in the testing. The appropriate agency shall be responsible for obtaining the
sample prior to the defendant's release from confinement. RCW 43.43.754.
[ ] HIV Testing. The defendant shall submit to HIV testing. RCW 70.24.340.
:-1 3 a 4 7
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4.5 No Contact:
[ ] The defendant shall not have contact with--------------------------------------------------------- -- ----------------__________ _________________ (name) including, but not limited to,
personal' veTbal, telephonic, wri(ten or contact through a third party until__________ _____ _ (which does not
exceed (lie maximum statutory sentence).
[ ] The defendant is excluded or prohibited from coming within ___________________ __ (distance) of:
[j
,
__________ __________
____ (name of protected person(s))'s [} home:/ residence [
] work place [ ] school f ] (other location(s)).......... .......................................................................
__________________ __________________ _ _________________________________________ , or
[ ] oilier location______________________ _______________________________________________ __.
until__________ ____ _______ (which does not exceed the maximum statutory sentence).
[ ] A separate Domestic Violence No-Contact Order or Antiharassment No-Contact Order is Hied concurrent with this
Judgment and Sentence.
4.6 Other:
4.7 Off-Limits Order. (Known drug trafficker). RCW 10.66.020. The following areas are off limits to the defendant
while under the supervision of the county jail or Department of Corrections:
__________
5.2 Length of Supervision. If you committed your offense prior to July 1, 2000, you shall remain under the court's
jurisdiction and the supervision of the Department of Corrections for a period up to 10 years from the date of sentence or
release from confinement, whichever is longer, to assure payment of all legal financial obligations unless the court
extends the criminal judgment an additional 10 years. If you committed your offense on or after July 1, 2000, the court
shall retain jurisdiction over you, for the purpose of your compliance with payment of the legal financial obligations,
until you have completely satisfied your obligation, regardless of the statutory maximum for the crime. RCW 9.94 A. 760
and RCW 9.94A.505(5). The clerk of the court has authority to collect unpaid legal financial obligations at any time
white you remain under the jurisdiction of the court for purposes of your legal financial obligations. RCW
9,94A.760(4) and RCW 9.94A.753{4).
5.3 Notice of Income-Withholding Action. If the court has not ordered an immediate notice of payroll deduction
in Section 4.1, you are notified that the Department of Corrections (DOC) or the clerk of the court may issue a notice of
payroll deduction without notice to you i f you ore more than 30 days past due in monthly payments in aa amount equal
to or greater than the amount payable for one month. RCW 9.94A.7602. Other income-withholding action under RCW
9.94A.760 may he taken without further notice. RCW 9.94A.7606.
i 38 47
8 /1 7 /2 8 1 1
88858
5.5 Firearms. You may liot own, use or possess any firearm unless your right to do so is restored by a superior
court in Washington State, and by a federal court if required. You must immediately surrender any concealed
pistol license. (The clerk of the court shall forward a copy of the defendant's driver's license, identicard, or comparable
identification to the Department of Licensing along with the date of conviction or commitment.) RCW 9.41.040,
9.41.047.
FIREARM RIGHTS STATEMENT: RCW 9.41.040. I acknowledge that my right to own, use or possess any firearm
has been lost due to felony conviction, or crimes involving domestic violence. My right to own, use, or possess a
firearm may only be restored by a court of record. I acknowledge that I must immediately surrender any concealed pistol
license. Owning, using,possessing a firearm before the right u restored is a class C felony, RCW 9.41.040.
Defendants signature
5.6 Reserved.
5.7 Motor Vehicle: If the court found that you used a motor vehicle in the commission of the offense, then the Department
of Licensing will revoke your drivers license. The clerk of the court is directed to immediately forward an Abstract of
Court Record to the Department of Licensing, which must revoke your drivers license. RCW 46.20.285.
5.8 Other:___________________________________________________________________ .
S.y [X] BOND IS HEREBY EXONERATED. Kittitas County Clerk is hereby authorized to repay cash bail to the payor
thereof or his/her designee.
Candace Hooper
C. K. Powers
Melissa J. Hart
Voting! Rights Statement: [ acknowledge that 1have lost my right to vote because of this felony conviction. If I am
registered to vote, my voter registration will be cancelled.
My right to vote is provisionally restored as long as I am not under the authority of DOC (not serving a sentence of
confinement in the custody of DOC and not subject to community custody as defined in RCW 9.94A.Q30). I must re-register
before voting. The provisional right to vote may be revoked if I fail to comply with all the terms of my legal financial
obligations or an agreement for the payment of legal financial obligations.
My right to vote may be permanently restored by one of the following for each felony conviction: a) a certificate of discharge
issued by the sentencing court, RCW 9.94A.637; b) a court order issued by the sentencing court restoring the right, RCW
9.92.066: c) a final order of discharge issued by the indeterminate sentence review board, RCW 9.96.050; or d) a certificate of
restoration issued by the governor, RCW 9.96.020. Voting before the right is restored is a class C felony, RCW 29A.84.660.
Registering to vote befonythe right is restored is a class C felony, RQtf 29A.84.140.
Defendants signature:
I am a certified interpreter of, or the court has found me otherwise qualified to interpret, the_____________
____ _______ ______ _______ language, which the defendant understands. I translated this Judgment and
Sentence for the defendant into that language.
Interpreter signature/Prinl name:
-G s n s z B 'il 0a8S3.
_______
_________________________Date of Birth
Local ID No.
PCN No.
Other
[ ] Black/African-American
\ ] Caucasian
[ ] Native American
[ ] Other:________________________
Ethnicity:
Sex:
[ ] Hispanic
;V ['j Male
[ ] Non-Hispanic
LI female
Fingerprints: 1attest that I saw die defendant who appeared in court affix his or her fingerprints andsignaturc on
this document
a |
r
The defendants signature:
f V if | \
Left
Thumb
K __ ___ ___________ _
1384V
08B&H
Defendant shall report to the Department of Corrections at 1109 Industrial Way, Ellensburg, Washington, within 72
hours of the commencement of community supervision.
[X]
to
[X] (2)
Defendant shall not associate with codefendant(s) or anyone on active supervision without
permission of his/her supervising Community Corrections Officer.
EX]
(3)
Defendant shall not change his/lver place of residence without first obtaining permission of his/her
Supervising Community Corrections Officer.
1X1
(4)
Defendant shall maintain full-time employment, if unemployed, defendant shall actively seek full
time employment and report weekly to the superv ising Community Corrections Officer until full-time
employment is found. Defendant shall not terminate or change employment without prior approval
from the supervising Community Corrections Officer, Employment can include educational and
training programs.
[ ]
(5)
Defendant shall obtain a substance abuse evaluation through a qualified, certified substance abuse
evaluatiun/treatment agency. Defendant shall enter Into; make reasonable progress in; and
successfully complete any recommended inpatient or outpatient treatment programs resulting from
this evaluation, including any additional recommendations and/or program changes made by
treatment staff during the course of treatment. Defendant shall not terminate treatment without prior
written authority of the program officials in conjunction with the approval of the supervising
Community Corrections Officer. Defendant must follow all rules, regulations, and requirements of
tlic treatment providerfs).
j j
(6)
Defendant will not purchase, possess, or consume any dangerous drugs, narcotics, or controlled
substances without a valid prescription from a licensed physician. Defendant must provide
verification of all prescriptions to the supervising Community Corrections Officer within 72 hours of
receipt.
[ ]
(7)
Defendant shall not associate with persons involved in the use, sales and;or possession of dangerous
drugs, narcotics or controlled substances.
[ ]
(8)
Defendant shall not enter into or remain in areas where dangerous drugs, narcotics, or controlled
substances are being sold/purchascd, possessed, and/or consumed.
] (9)
Defendant shall not purchase, possess, and/or consume any intoxicating liquors.
j (10)
Defendant shall not enter into or remain in establishments where alcohol is the main source of
revenue. This does not include a restaurant which is attached to but separate from a bar/Iounge area.
] (11)
Defendant shall submit to testing of his/her blood, urine, and/or breath as directed by the supervising
Community Corrections Officer to monitor compliance with drug and/or alcohol conditions of
supervision. This testing shall be at the defendants own expense.
1384?
[ I
02)
6 < i ? > 2 e 11
ts ts 8 fa f ;
Defendant shall obtain a batterers treaunent/anger management evaluation. Defendant shall enter
into, make reasonable progress in, and successfully complete any program of treatment
recommended as a result of this evaluation, including any additional recommendations and/or
program chunges made by treatment stall during the course of treatment. Defendant shall not
terminate treatment without prior written authority of the program officials and in conjunction with
the approval of the supervising Community Corrections Officer.
[ 1 03)
l 1 (14>
(15)
Defendant shall obtain a sexual devtariey evaluation from a certified sexual deviancy treatment
provider. Defendant shall enter into, make reasonable progress in and successfully complete any
program of treatment recommended as a result of this evaluation, including any additional
recommendations und/or program changes made by the treatment staff during the course of
treatment. Defendant shall not terminate treatment or change treatment providers without prior
written authorization from the court. Defendant must follow alt rules, regulations, and requirements
of die treatment provider.
l 1 (16)
Defendant shall have no direct and/or indirect contact with minors under the age of 18, without the
prior approval of the treatment provider and the supervising Community Corrections Officer.
( I
07)
Defendant shall not frequent areas where minors are known to congregate including but not limited
to schools, parks, playgrounds, arcades, and swHmming pools.
[ ]
08)
Defendant is not to purchase, possess, or use pornographic material. Pornographic material will be
defined by the treatment provider, the supervising Community Corrections Officer, and the Court.
l 1
O )
Other:__________________________________________________________
13847
b /i? /2 8 ii
88862 -
a p p e n d ix _________
Page 12 of 12
3 H 4 V 16/1-7/2-811 0 8 8 6 3
Cause No.
Plaintiff.
vs.
ORDER ON SENTENCING
WORK CREW ADDENDUM
TO JUDGEM ENT AND SENTENCE
DOB;
Defendant.
APPENDIX A.5
THIS MATTER HAVING COME ON for a sentencing hearing before the undersigned judge o f the above
entitled Court, it is hereby
ORDERED THAT the defendant shall serve
Washington State Department o f Corrections Work Crew (one day of Work Crew equals one day o f confinement)
$4-beginiiing on
-fr*,
/a ,
z*> s < 3
[ resented by .
i ic p u iv IV u s e c .u iin g A tto r n e y . W S B A f#
Appro1,cl!u .- Im [ oiiii h
1364?
6 /1 7 /2 8 1 i
188863
July 27,2010
Melissa Hart
109 West 4th
Cle Elum, WA. 98922
Re: 10-1-00121-1
Dear Ms. Hart,
As you know, Ms. C.K. Powers has been appointed to represent you in the case listed
above. Enclosed please find your copies of the following documents:
Motion and Declaration for Order of Appointment of Expert Services
Order Appointing Expert Services
The special investigators name is Marlene Goodman and she will be in contact with you.
Please cooperate with her fully as she was hired to assist in your defense.
As part of the co u rt-a p p o in ted a tto rn e y program* yo u are req u ire d to m a in ta in
weekly contact with our office. If you do not stay in weekly contact with our office
then the Judge will be notified.
Should you have any questions or concerns, please do not hesitate to contact our office.
Sincerely,
Legal Assistant to
C.K. Powers
Enclosures
'1 3 8 4 ?
8806S
CiX
C D
CO
C IO
6
7
STATE OF WASHINGTON,
NO. 10-1-00121-1
Plaintiff,
9
10
11
vs.
MELISSA HART,
Defendant
12
COMES NOW C.K. POWERS Attorney for the Defendant, and moves the Court for an order
13
Amending the Order on Sentencing on the Felony Judgment and Sentence for the above named
14
defendant. This date on the Judgment and Sentence that was entered on November 19,2010.
15
This motion is based upon the record and files herein and the declaration of C.K. Powers,
16
DATED this
of December, 2010.
21
22
23
24
25
W.S.B.A. #6705
707 N. Pearl, Ste A
130 4 /
b / j . 7 'S z n i . X i i H 8 U &
DECLARATION
1.
I am the attorney o f record for the above named Defendant in this matter.
2.
The defendant was going to com plete her sentence by doing work crew in Pierce
County. Pierce County only allow s people to do work crew w ho are referred by
their district court. They do not allow felony work crew or out o f tow n persons.
3.
The defendant in a single Mother who works full tim e. She needs additional tim e
to make arrangements for her son w hile she is incarcerated. She also needs tim e
10
11
12
13
14
DATED this 2
15
16
17
18
19
20
21
22
23
24
25
W.S.B.A. #6705
707 N. Pearl, Ste A
t 7 /Z g l i
B15#b {
DEC 03 2010
Cv
jnflSLMSRUO,ClK
KITTITASCOUNTY,WASHINGTON
2
0
<y>!
6
7
8
NO. 10-1-00121-1
STATE OF WASHINGTON,
Plaintiff,
vs.
MELISSA HART,
Defendant
10
11
12
13
The attorney, C.K. Powers, for the Defendant, MELISSA HART, having filed a Motion
14
and Declaration for and an agreed Order Amending the Order on Sentencing on the felony
15
judgment and sentence on December 1, 2010, and the Prosecuting Attorney, agreeing hereto;
-/p
fkri/hAStf
IT IS HEREBY ORDERED that the Order
Sentences^ be amended from December
16
17
10, 2010 to January 3, 20/^. The clerks office is ordered to provide the Kittitas County
18
19
20
DATED this
21
22
Judge
23
24
25
W .S .B .A . # 6 7 0 5
7 0 7 N. Pearl, S te A
E lle n sb u rg , W a. 9 8 9 2 6
P h o n o ^ n Q - Q T i^ i n /F a v FnQ-QT?-7"5l 1
6 / 1 ? -2 '8 i .088633
Presented by:
2
3
4
5
6
7
8
-9
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
25
W.S.B.A. #6705
707 N. Pearl, Ste A
Ellensburg, Wa. 98926
Phone 509-933-777n/Fav
3384 V
S /^
AJ/xH.
/o l
l(
Middle
No. D10-6
4/27/1977
11/6/1978
|fl
Respondent Identifiers
88883
J / z & i l
Last
Sex
dob
N/A
Height
Race
U 3
Weight
Hair
Eyes
ftu u _
2 T5
Respondents Distinguishing Features:
C aution:
i n . Respondent is Restrained from causing petitioner physical harm, bodily injury, assault, including sexual
assault, and from molesting, harassing, threatening, or stalking ^petitioner CDthe minors named in the
table above G these minors only:
&T2. Respondent is Restrained from coming near and from having any contact whatsoever, in person or
through others, by phone, mail, or any means, directly or indirectly, except for mailing or service of process
of court documents by a 3rd party or contact by respondents lawyers) with [^petitioner G the minors
named in the table above Q these minors only:
Additional no contact provisions are on the next page.
The terms of this order shall be effective until
1 iJ-S 4 /2
hcZ:j 2..-Z
0 & .& / !
J^T 3. Respondent is Restrained from going onto the grounds of or entering petitioner's ^residence
^w orkplace school D the day care or school o fD the minors named in the table above
these minors only:
other:
Petitioner's address is confidential. S f Petitioner waives confidentiality o f the address which is:
IO 9
kJ 'HsCg-
\-e
r(.^ ,/> f
o (/y f
4. Petitioner shall have exclusive right to the residence petitioner and respondent share. The respondent
shall immediately V a c a te the residence. The respondent may take respondent's personal clothing
and respondent's tools o f trade from the residence while a law enforcement officer is present. This
address is confidential. Petitioner waives confidentiality o f this address which is:
J 5 5. Respondent is
care or school o f the minors named in the table above these minors only:
other:
6. Petitioner shall have possession of essential personal belongings, including file following:
8.
~
Other.
-.1 f"L- '*:'R
.Gonipletfefhe'ffiillowmgjdhlydfipffitectidh^^ant^jihvolyihg^imjnor::#,
12. Petitioner is
above
nL't,,-,j-.vij..;:->.j,,j,iu,,,,,
13. Respondent is Restrained from interfering with petitioner's physical or legal custody of the
minors named in the table above these minors only:
14. Respondent is Restrained from removing from the state the minors named in the table above
these minors only:
The respondent is directed to appear and show cause why this temporary order should not be made effective for
one year or more and why the court should not order the relief requested by the petitioner or other relief which
may include electronic monitoring, payment of costs, and treatment. Failure to Appear at the Hearing
May Result in the Court Granting Such Relief. The Next Hearing Date is Shown on
Page One.
Temp Ord for Protection/Nt o f Hrg (TMORPRT) - Page 2 o f 3
WPF DV-2.015 Mandatory (7/2007) - R C W 26.50.030
Warnings to Respondent: A violation of provisions 1 through 5 of this order with actual notice of its
terms is a criminal offense under chapter 26.50 RCW and w ill subject you to arrest I f the violation of the
protection order involves travel across a state line or the boundary of a tribal jurisdiction, or involves conduct
within the special maritime and territorial jurisdiction of the United States, which includes tribal lands, you may
be subject to criminal prosecution in federal court under 18 U.S.C. 2261,2261A, or 2262.
A violation of provisions 1 through 5 of this order is a gross misdemeanor unless one of the following conditions
appty: Any assault that is a violation of this order and that does not amount to assault in the first degree or second
degree under RCW 9A.36.011 or 9A.36.021 is a class C felony. Any conduct in violation of this order that is
reckless and creates a substantial risk of death or serious physical injury to another person is a class C felony.
Also, a violation of this order is a class C felony if you have at least two previous convictions for violating a
protection order issued under Titles 7, 10, 26 or 74 RCW.
If the court issues a final protection order, and your relationship to the petitioner is that of spouse or former
spouse, parent of a common child, or former or current cohabitant as intimate partner, you may not possess a
firearm or ammunition for as long as that final protection order is in effect 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/govemment-issued
firearms. IS U.S.C. 925(a)(1). I f you are convicted of an offense o f domestic violence, you w ill be forbidden
for life from possessing a firearm or ammunition.
18 U.S.C. 922(g)(9); RCW 9.41.040.
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.
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._______
It is further ordered that the clerk of the court shall forward a copy of this order on or before the next judicial day 1
to
KITCOM
W here P etitio n er Lives which shall enter it in a computer based criminal intelligence system available in this
state used by law enforcement to list outstanding warrants.
D The clerk of the court shall also forward a copy of this order on or before the next judicial day to
Dated
^ ~7j (
at
.nyp.m.
Judge/Ccmmissioner
A Law Enforcement Information Sheet (LEIS)
must be completed.
1384?
6^17^2811
138872
State of Washington
KITTITAS SHERIFFS OFFICE
Civil Division
Ellensburg, WA 98926
Process Number: S10-00369
by MARX, BERT
231 HAWTHORNE
EASTON, WA 98925
Returned on the 30th day of April, 2010
20.00
3.5.00
-55.00
0.00
resentative
13847
04/30/10
10:42
Page:
155
1
04/30/10
04/30/10
04/30/10
04/30/10
13 88 7 3
Responsible Party:
MELISSA JILL HART
109 W 4TH ST
CLE ELUM, WA 98922
Date
6 /1 7 /2 8 1 1
98922
98925
Typ Description
1
2
3
4
CHG
CHG
CHG
CHG
Affidavit
Mileage Charge
TEMP ORDER FOR PROTECTION - DV
Fee Waiver - PO DV
FINAL REFUND DUE :
Amount
10.00
35.00
20.00
-65.00
0.00
If not contacted
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
June 20 2011
1
KEVIN ST
COUNTY C
NO: 10-3-0
3
4
5
6
7
8
9
10
J A S O N W . S H IP M A N
11
P e titio n e r
12
v.
13
J E N N IF E R K . S H IP M A N
14
)
)
)
)
C A S E N O .: 1 0 -3-00961-1
)
)
N O TIC E OF A PPEA R A N C E
)
)
)
)
)
R e sp o n d e n t,
15
16
17
18
TO:
Ja s o n W . S h ip m a n , P ro Se.
19
20
21
22
25
jurisdiction, improper service, or improper venue, and requests that all further
26
1 of 2
1
2
20 th
day of
June______, 2011.
3
4
5
6
By:
/s/ T im o th y M . Greene
Timothy M. Greene
WSBA #17499
Attorney for Respondent
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
NOTICE OF APPEARANCE
2 of 2
b '2 i -'2 8 il
10*3-00961-1
36633014
ANWRGR2
14838
BSBSS
06-21-11
IN COUNTYtJtlR^'S OFFWE
_1
No.
10-3-00961-1
Petitioner,
and
JASON WILLIAM SHIPMAN
Respondent.
FRANCISCAN HEALTH SYSTEM
Garnishee Defendant
SECTION I
ANSWER SECTION II OF THIS FORM WITH RESPECT TO THE TOTAL AMOUNT OF
EARNINGS WITHHELD UNDER THIS GARNISHMENT, INCLUDING THE AMOUNT, IF ANY,
STATED IN YOUR FIRST ANSWER, AND WITHIN TWENTY (20) DAYS AFTER YOU
RECEIVE THESE FORMS, MAIL OR DELIVER THEM AS DIRECTED IN THE WRIT
Amount due and owing stated in
the first answer
$ S F
. 7
FAUBION, REEDER,
FRALEY & COOK, P S
5920- 100th St SW #25
Lakewood, WA 98499
253-581-0660
fe /'2 1 / 2 S 11
1
2
$_
14S 3B
S B lB iS
<2- 2 .
3
4
SECTION II
5
6
7
8
9
10
11
12
At the time of service of the Writ of Garnishment on the Garnishee, there was due and owing
from the Garnishee to the above-named defendant $ _____________
This writ attaches a maximum of 25 percent of the Petitioner / Respondents disposable
earnings (that is, compensation payable for personal services, whether called wages, salary,
commission, bonus, or otherwise, and including periodic payments pursuant to a
nongovernmental pension or retirement program) Calculate the attachable amount as follows
Gross Earnings
$ ______________ (1)
14
15
$ _______________ (3)
16
$ _______________ (4)
17
$ _______________ (5)
18
If paid Weekly
Bi-weekly
13
$_____
$_____
Semi-monthly $_____
Monthly
$_____
19
*These are minimum exempt amounts that the__ (employee Pet / Resp) must be paid If your
20
21
22
23
24
25
answer covers more than one pay period, multiply the preceding amount by the number of pay
periods and/or fraction thereof your answer covers If you use a pay period not shown, prorate
the monthly exempt amount
Subtract the larger of lines 4 and 5 from line 3.
$ _______________(6)
FAUBION, REEDER,
FRALEY & COOK, P S
5920 - 100tfl St SW #25
Lakewood, WA 98499
253-581-0660
2 1 / Z 31.1
1403B
$ ____________
(8)
This is the formula that you will use for withholding each pay period over the required 60-day
garnishment period Deduct any allowable processing fee you may charge from the amount
that is to be paid to the___ Petitioner / Respondent.
If there is any uncertainly about your answer give an explanation on the last page or on an
attached page
SECTION III
An attorney may answer for the Garnishee
Under penalty of perjury, I affirm that I have examined this answer, including accompanying
schedules, and to the best of my knowledge and belief, it is true, correct and complete
____________________
-A S ~ - / /
Date
s of Garnishee
Phone Number
3Uc H ealth
Initiatives
jshment Department
If necessary, use the space below to supplement your answer from the first and second pages
FAUBION, REEDER,
FRALEY & COOK, P S
5920-1 0 0 th St SW #25
Lakewood, WA 98499
253-581-0660
Employee
Payment Nbr
14S 3S
MB
ff*lCase
File Number /
tf*.. ..........
10-3-00961-1
Company 8900
CATHOLIC HEALTH INITIATIVES
Garnishment Audit Report
Report Sequence Employee Name
55218
23546907
FIPS
SHIPMAN, JENNIFER K
Payment Type Direct Deposit
Gross Pay
3071 34
Disposable
Income
Exempt Wages
2333 88
1750 41
Page
SSN 536-88-2306
Payment Date 04/08/2011
Garn
Ded
G20P
Amount
583 47
ClrHse
Fee
0 00
Art
Court Fee Ded
0 00
Amount
0 00
Court
Fee
Arreas Fee Ded
0 00
Amount
0 00
yi
^Payment Nbr
^Case
^ F 1 1e Numbe r /
23588817
FIPS
Gross Pay
3007 40
^10-3-00961-1
Disposable
Income
Exempt Wages
2289 05
1716 78
Amount
572 26
ClrHse
Fee
0 00
Arr
Court Fee Ded
0 00
Amount
0 00
Court
Fee
Arreas Fee Ded
0 00
Amount
0 00
sO
Payment Nbr
Case
File Number /
23630632
FIPS
10-3-00961-1
Payment Nbr
Case
File Number /
Gross Pay
3198 54
23672421
FIPS
10-3-00961-1
Di sposable
Income
Exempt Wages
2423 06
1817 29
Gross Pay
3062 85
Disposable
Income
Exempt Wages
2327 93
1745 94
Amount
605 77
ClrHse
Fee
0 00
Ari
Court Fee Ded
0 00
Amount
0 00
Court
Fee
Arreas Fee Ded
0 00
Amount
0 00
Amount
46 63
ClrHse
Fee
0 00
Arr
Court Fee Ded
0 00
Amount
0 00
Court
Fee
Arreas Fee Ded
0 00
Amount
0 00
1,808 13
0 .00
0 00
0 00
1,808 13
0 00
0 00
0 00
'1 /k
h u u d j &
lr\L &
J p jL h tji/x
r fm
o /
L---------------------------------------------------------------- ----------------------------------
J _ r ig ju t a f j/ y y i_
9 - 5
. f l)
Clerk
Courtroom number 2-A
) b
- b
S /2 2 /2 g il
10-3-00961-1
36638947
ORRE
,
06-22-11
I404S
FILED
43014
COURT COMMISSIONER
IN OPEN COURT
JUN 2 J aw
PIERCE
^
nEPI ITV
THIS MATTER having come before the Court upon the moving party's Motion, and the
Court having heard the argument of the parties and having considered the records and files
herein, it is now therefore,
^ 2 2 /2 8 1 1
( /3 )
o f r i^ C
c J !7 ^
k > A / ls ; k R
p6
/ 4 r^~
..
1484&
438
US
S W h u ? ,jd ry [ t v r n h 7<gy / W W r 1 t
rR rJ rN < U \ 4
p trh )-k (T A (^ 6 r
DAVID H. JOHNSON
COURT COMMISSIONFR
Dated
- ^ - l - < /
Judge/ C ourt C o m m is
Approved for entry
Notice of presentation waived
iqnature/WSBA #
Print Name
3 hfet*. a ^
: i 4 *"*P
10-3-00961-1
36697014
TMORSW
S * /-rn4
I?
07-01-11
_
T FILED
IN COUNTY CLERKS OFFICE
A.M.
JUN 30 2011 RM
5
6
7
No. 10-3-00961-1
Petitioner,
10
and
JASON WILLIAM SHIPMAN
11
Respondent.
12
13
[x ] Temporary (TMORS)
[] Final Order (ORS)
Clerk's Action Required
I. Judgment Summary
1.1
14
[X ]
[]
15
A.
B.
C.
Judgment creditor
___________
Judgment debtor
___________
Principal judgment amount (back child support/other obligations) $
from (date)____________ through (date)____________
Interest to date ofjudgment
$
Attorney fees
$
Costs
$
Other recovery amount
$
Principal judgment shall bear interest at________ % per annum
Attorney fees, costs and other recovery amounts shall bear interest at______ % per annum
Attorney for judgment c r e d i t o r _________________________ ___
Attorney for judgment debtor
________________________ ____
Other:
16
D.
E.
F.
G.
H.
I.
J.
K.
L.
17
18
19
20
21
22
1.2
23
[X ]
[]
Applies as follows:
A.
B.
C.
Judgment creditor
___________
Judgment debtor
___________
Judgment for medical support
$
from (date)____________ through (date)_____________
Interest to date ofjudgment
$
Attorney fees
$
Costs
$
Principal judgment shall bear interest at_________ % per annum
Attorney fees, costs and other recovery amounts shall bear interest at_____ %per annum
Attorney forjudgment c r e d i t o r _______________________ _____
Attorney for judgment d e b t o r ________________________ ____
Other
D.
E.
F.
G.
H.
I.
J.
K.
II. Basis
2.1
Type of Proceeding
This order is entered under a petition for dissolution of marriage or domestic partnership, legal
separation, or declaration concerning validity:
[]
[]
[X ]
[]
[]
[]
2.2
The child support worksheet which has been approved by the court is attached to this order and is
incorporated by reference or has been initialed and filed separately and is incorporated by reference.
2.3
Other
It Is Ordered:
3.1
Name (first/last)
Age
TS
16
HS
# a4 O A n
> .
f
j. a
1
3.2
2
3
The Obligor Parent Shall Update the Information Required by Paragraph 3.2
Promptly After any Change in the Information. The Duty to Update the
Information Continues as long as any Support Debt Remains due Under
This Order.
8
9
10
For purposes of this Order of Child Support, the support obligation is based upon the following
income:
A.
[X ]
11
12
B.
[]
13
14
15
16
17
OR
18
C.
[]
19
20
21
22
23
[]
[]
[]
4 4 n n i)
[]
[]
[]
[]
3.3
4 4
+V -1*- ' /Ofi
i-V A
X
Other:
The Obligee Must Immediately File With the Court and the Washington
State Child Support Registry and Update as Necessary the Confidential
Information Form Required by RCW 26.23.050.
The Obligee Shall Update the Information Required by Paragraph 3.3
Promptly After any Change in the Information. The Duty to Update the
Information Continues as Long as any Monthly Support Remains Due o r
any Unpaid Support Debt Remains Due Under This Order.
For purposes of this Order of Child Support, the support obligation is based upon the following
income:
A.
[X ]
B.
[]
*.<4n n r ^
[]
[]
[]
[]
Other:
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
A"t -C-?
4<
t * JLr *7Q
O X i
*7/4
Transfer Payment
2
3
The obligor parent shall pay the following amounts per month for the following child(ren):
Name
Amount
IS_______________________________________
HS_______________________________________
$_____________________
$_____________________
_______________________________________
_______________________________________
$____________________
$____________________
$460.96_________________
[]
The parents combined monthly net income exceeds $12,000 and the court sets child
support in excess of the presumptive amount for $12,000 because:
[]
The court finds that the obligors child support obligations owed for all his or her
biological or legal children exceed 45% of his or her net income and it is [ ] just
[ ] unjust to apply the 45% limitation based upon the best interests of the child(ren) and
the circumstances of each parent as follows:
[]
If one of the children changes age brackets, the child support shall be as follows:
[]
[]
[]
Other:
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
/r 4
v *>i2 4 aavann
X ^ .11 4. JL U W U < U
V 'S '
2
3
4
3.6
$ 460.96
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Standard Calculation
3.7
[X ]
The child support amount ordered in paragraph 3,5 does not deviate from the standard
calculation.
[ ] The child support amount ordered in paragraph 3.5 deviates from the standard calculation for
the following reasons:
[ ] Income of a new spouse or new domestic partner of the parent requesting a deviation for
other reasons;
[ ] Income of other adults in the household of the parent requesting a deviation for other
reasons;
[ ] Child support actually paid or received for other children) from other relationships;
[] Gifts;
[ ] Prizes;
[ ] Possession of wealth;
[ ] Extraordinary income of children);
[ ] Tax planning which results in greater benefit to the child(ren);
[ ] Income from overtime or second jobs that was excluded from income of the parent
requesting a deviation for other reasons;
[ ] A nonrecurring source of income;
[ ] Extraordinary debt not voluntarily incurred;
[ ] A significant disparity in the living costs of the parents due to conditions beyond their
control;
[ ] Special needs of disabled children);
[ ] Special medical, educational, or psychological needs of the child(ren);
[ ] The child(ren) spend(s) a significant amount of time with the parent who is obligated to
make a support transfer payment. The deviation does not result in insufficient funds in
the receiving parents household to meet the basic needs of the children). The
children) do(es) not receive public assistance;
[ ] Children) from other relationships;
[ ] Costs incurred or anticipated to be incurred by the parents in compliance with courtordered reunification efforts or under a voluntary placement agreement with an agency
supervising the children);
[ ] The obligor has established that it is unjust to apply the presumptive minimum payment
of $50.00 per child;
[ ] The obligee has established that it is unjust to apply the self-support reserve.
22
-* 4 n n a
1
2
3
3.8
[]
[X ]
[]
4
5
6
7
3.9
Starting Date:
Day(s) of the month support is due:
8
9
3.10
10
Incremental Payments
[]
[]
11
12
13
3.11
14
15
[X ]
16
17
18
19
20
21
22
23
Enforcement and collection: The Division of Child Support (DCS) provides support
enforcement services for this case because: [ ] this is a public assistance case, [ ] this is
a case in which a parent has requested services from DCS, [ ] a parent has signed the
application for services from DCS on the last page of this support order. (Check all
that apply.) Support payments shall be made to:
[]
Payment services only: The Division of Child Support will process and keep a record of
all payments but will not take any collection action. Support payments shall be made to:
Washington State Support Registry
P. O. Box 45868
Olympia, WA 98504
Phone: 1-800-922^306 or
1-800-442-5437
Law Offices of G reene & Lloyd, PLLC
Street; 4115 S. M eridian
Mailing; P.O. Box 731063
Puyallup, W ashington 98373
(253) 770-0808, F ax (253) 770-0259
<*5 n n
[]
A party required to make payments to the Washington State Support Registry will not receive
credit for a payment made to any other party or entity. The obligor parent shall keep the registry
informed whether he or she has access to health insurance coverage at reasonable cost and, if so,
to provide the health insurance po)icy information.
Any time the Division of Child Support is providing support enforcement services under
RCW 26.23.045, or if a party is applying for support enforcement services by signing the
application form on the bottom of the support order, the receiving parent might be required to
submit an accounting of how the support, including any cash medical support, is being spent to
benefit the children).
3.12
Withholding action may be taken against wages, earnings, assets, or benefits, and liens enforced
against real and personal property under the child support statutes of this or any other state,
without further notice to the obligor parent at any time after entry of this order unless an
alternative provision is made below:
[If the court orders immediate wage withholding in a case where Division of Child Support does
not provide support enforcement services, a mandatory wage assignment under Chapter 26.18
RCW must be entered and support payments must be made to the Support Registry.]
[]
the parties have reached a written agreement that the court approves that
provides for an alternate arrangement.
[]
the Division of Child Support provides support enforcement services for this
case [see 3.11] and there is good cause [as stated below under "Good Cause"]
not to require immediate income withholding which is in the best interests of the
children) and, in modification cases, previously ordered child support has been
timely paid.
[]
the Division of Child Support does not provide support enforcement services for
this case [see 3.11] and there is good cause [as stated below under "Good
Cause"] not to require immediate income withholding.
Good Cause:
rj <
' . "
i- U
A -
J
nQaQn
nti
^JL
UJ
Unn
11
u J4
1
3.13
Termination of Support
[X ]
[ ]
5
[ ]
6
f]
7
[]
8
9
[]
3.14
10
[]
11
[ ]
12
provided that this is a temporaiy order, until a subsequent child support order is entered
by this court.
until the children) reach(es) the age of 18 or as long as the child(ren) remain(s) enrolled
in high school, whichever occurs last, except as otherwise provided below in Paragraph
3.14.
until the children) reach(es) the age of 18, except as otherwise provided below in
Paragraph 3.14.
after the age of 18 for (name!
who is a dependent
adult child, until the child is capable of self-support and the necessity for support ceases.
until the obligation for post secondary support set forth in Paragraph 3.14 begins for the
child(ren).
Other:
[ ]
[X ]
The right to request post secondary support is reserved, provided that the right is
exercised before support terminates as set forth in paragraph 3.13.
The parents shall pay for the post secondary educational support of the children). Post
secondary support provisions will be decided by agreement or by the court.
No post secondary educational support shall be required.
Other: Reserved
13
14
15
Id
3.15
[X l
17
18
19
20
Does not apply because all payments, except medical, are included in the transfer
payment.
The petitioner shall pav 28.72
%and the respondent 71.28 % teach
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:)
pC ]
day care within 30 days of presentation of receipts by petitioner, respondent
shall reimburse
[ ]
educational expenses.
[ ]
long distance transportation expenses.
pC ]
other; Boys organized sports activities that the parties agree upon in writing
Payments shall be made to [ ] the provider of the service [ ] the parent receiving the
transfer payment.
21
22
The obligor shall pay the following amounts each month the expense is incurred on
behalf of the child(ren) listed in Paragraph 3.1:
23
11
[ ]
day care: $
1
[J
2
[]
[]
parent;
educational expenses: $
payable to the [ ] educational
provider [ ] other parent;
long distance transportation: $
payable to the
[ ] transportation provider [ ] other parent,
other:
4
5
3.16
Periodic Adjustment
[X ]
[]
[]
Other:
7
8
3.17
10
[]
[X ]
t]
[]
The parents shall sign the federal income tax dependency exemption waiver.
Other:
11
12
13
14
15
16
17
18
19
20
3.18
Each parent shall provide health insurance coverage for the children) listed in paragraph 3.1, as
follows:
3.18.1 Health Insurance (either check box A(1 )>or check box A(2) and complete sections B
and C. Section D applies in all cases.)
A.
Evidence
(1) [ ] There is insufficient evidence for the court to determine which parent must
provide coverage and which parent must contribute a sum certain. Therefore, the
court is not specifying how insurance coverage shall be provided. The
petitioners and respondents medical support obligations may be enforced by
the Division of Child Support or the other parent under RCW 26.18,170 as
described in paragraph 3.18.2, below.
21
OR
22
23
(2) [ ] There is sufficient evidence for the court to determine which parent must provide
coverage and which parent must contribute a sum certain. Fill in B and C below.
Law Offices of G reene & Lloyd, PLLC
S treet: 4115 S. M eridian
M ailing: P.O. Box 731063
P uyallup, W ashington 98373
(253) 770-0808, Fax (253) 770-0259
B.
2
4
(Parents Name)
(Parents Name)
5
[]
6
[ 3
7
8
[ 3
9
[ 3
10
11
[3
12
E3
13
14
15
[ 3
E3
[ 3
[ 3
16
17
18
19
20
21
C.
Parties obligations:
[]
[]
22
23
Law Offices of G reene & Lloyd, PLLC
Street: 4115 S. M eridian
Mailing: P.O. Box 731063
Puyallup, W ashington 98373
(253) 770-0808, Fax (253) 770-0259
1
2
(Parents Name)
(Parents Name)
[]
[ ]
[]
[]
4
5
6
7
8
9
[]
[ ]
10
11
[]
12
13
14
[
[ ]
[ ]
[ ]
[ ]
15
16
17
18
19
20
21
22
23
Law Offices of G reene & Lloyd, PLLC
Street: 4115 S. M eridian
Mailing: P.O. Box 731063
Puyallup, W ashington 98373
(253) 770-0808, P ax (253) 770-0259
D.
A parent required to provide health insurance coverage must notify both the Division of Child
Support and the other parent when coverage terminates.
If the parents* circumstances change, or if the court has not specified how medical support shall
be provided, the parents medical support obligations will be enforced as provided in
RCW 26.18.170. If a parent does not provide proof of accessible coverage for the child(ren)
through private insurance, a parent may be required to satisfy his or her medical support
obligation by doing one of the following, listed in order of priority:
1) Providing or maintaining health insurance coverage through the parents employment or
union at a cost not to exceed 25% of that parents basic support obligation;
2) Contributing the parents proportionate share of a monthly premium being paid by the
other parent for health insurance coverage for the children) listed in paragraph 3.1 of
this order, not to exceed 25% of the obligated parents basic support obligation; or
3) Contributing the parents proportionate share of a monthly premium paid by the state if
the children) receives state-financed medical coverage through DSHS under RCW 74.09
for which there is an assignment.
A parent seeking to enforce the obligation to provide health insurance coverage may apply for
support enforcement services from the Division of Child Support; file a motion for contempt (use
form WPF DRPSCU 05.0100, Motion/Declaration for an Order to Show Cause re Contempt); or
file a petition.
3.19
Both parents have an obligation to pay their share of uninsured medical expenses.
The petitioner shall pay 28,72_______ % of uninsured medical expenses (unless
stated otherwise, the petitioners proportional share of income from the Worksheet, line
6) and the respondent shall pay 71.28________%of uninsured medical expenses
(unless stated otherwise, the respondents proportional share of income from the
Worksheet,
line 6).
2
3
4
5
6
3.20
7
8
[]
[]
Back child support that may be owed is not affected by this order.
Back interest that may be owed is not affected by this order.
(Name)____________ __________
(name)_______________________
child support for the period from (date)
(Name)_______________________
(name)_______________________
interest for die period from (date)____
9
n
10
11
12
[]
[]
13
PC]
14
3.21
15
16
[]
[]
Unpaid medical support that may be owed is not affected by this order.
Back interest that may be owed is not affected by this order.
[]
17
[]
18
19
20
[]
[]
21
[]
Other:
22
3.22
23
Law Offices of G reene & Lloyd, PLLC
S treet: 4115 S. M eridian
M ailing: P.O. Box 731063
P uyallup, W ashington 98373
(253) 770-0808, Fax (253) 770-0259
[]
[]
Other obligations that may be owed are not affected by this order.
Back interest that may be owed is not affected by this order.
[]
[]
3.23
[]
[]
[]
Other:
AM JUN 3 0 2011
Pl KEwfsTOCK, County*TerH
.DEPUTY
Other
Dated:
imissioner
Print Name
[]
I apply for full support enforcement services from the DSHS Division of Child Support (DCS).
(Note: If you never received TANF, tribal TANF, or AFDC, an annual $25 fee applies if over
$500 is disbursed on a case, unless the fee is waived by DCS.)
Signature of Party
[]
Approval required in Public Assistance cases. The DSHS Division of Child Support received
notice required by RCW 26,23.130. This order has been reviewed and approved as to:
[]
[]
[]
[]
P.M.
GTON
/
*4 tj ^L! *1
* r
44
JL X
n oo
nu
n rut
liu
E-FILED
IN COUNTY CLERK'S O FFICE
PIERCE COUNTY, WASHINGTON
May 18 2011 11:24 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
FATHER
JASON WILLIAM SHIPMAN
SUPERIOR COURT/OAH CASE NO. 10-3-00961-1
WORKSHEETS
Children and Ages Tyler 16, Hunter 9
Part I: Basic Support Obligation (See instructions, page 1)
1. Gross Monthly Income
Father
Mother
$2,075.67
$6,192.00
$0.00
$0.00
c. Business Income
$0.00
$0.00
d. Maintenance Received
$0.00
$0.00
e. Other Income
$0.00
$0.00
$2,075.67
$6,192.00
Father
Mother
$207.57 !
$1,475.78
$0.00
$0.00
$0.00
$0.00
$0.00
$80.00
$0.00
$0.00
f. Maintenance Paid
$0.00
$0.00
$0.00
$0.00
$207.57
$1,868.10
$887
Hunter
$1,555.78
$4,636.22
$6,504,32
>)
$1,605.00
$718
(advisory)
28.72%
$460.06
$1,144.04
Part tl: Health Care, Day Care, and Special Child Rearing Expenses (See instructions, page 3)
8. Health Care Expenses
a. Monthly Health Insurance Premiums Paid for Child(ren)
b. Uninsured Monthly Health Care Expenses Paid for Child(ren)
c. Total Monthy Health Care Expenses (line 8a plus line 8b)
0.00
$0.00
$0.00
0.00
$0.00
$0.00
$0.00
$B0.25
0.00
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 fines 9a through 9d)
10. Combined Monthfy Total of Day Care and Special Expenses
(add parent's day care and special expenses from line 9e)
W SCSS-W orfrsheets-M andatory (CSW/CSWP) 6/2008 page 2 o f 5
0.00
vi.
^ c*
11. Total Extraordinary Health Care, Day Care, and Special Expenses
(line 8f plus line 10)
Father
12. Each Parent's Obligation for Extraordinary Health Care, Day Care, and Special Expenses
(multiply each number on tine 6 by line 11)
$0.00
Mother
$0.00
$460.96 J
$1,144.04
...
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$460.96
$1,144.04
$840.65
$2,086.30
$737.10
$3,505.22
$460.96
$1,144.04
a. Real Estate
b. Stocks and Bonds
c. Vehicles
d. Boats
e. Pension/)RAs/Bank Accounts
f. Cash
g. Insurance Plans
h. Other (describe)
17. Household Debt (List Gens against household assets, extaordinary debt)
Fathers
Household
Mother's
Household
Fathers
Household
ii
i
i
I
Mother's
Household
This worksheet has been certified by the State of Washington Administrative Office of the Courts.
Photocopying of the worksheet is permitted.
E-FILED .
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
July 06 2011 2:06 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
No. 10-3-00961-1
FAUBION, REEDER,
FRALEY & COOK P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
14X36
10-^-00961-1
3672B8B7
MTJ
7 /8 /2 6 1 1
958315
07-06-11
JUL 0? 2011
RM.
rKEVIN STOCrf^untyClerk^
12
Petitioner,
13
and
14
15
16
17
No.
10-3-00961-1
Respondent.
FRANCISCAN HEALTH SYSTEM
G arnishee Defendant
18
I.
19
MOTION
20
COMES NOW the Respondent, JASON SHIPMAN and moves the Court for entry
21
Judgment against Defendant in the amount of $286.23 for recoverable costs as shown
25
24
VMI IU
23
of an order as follows:
22
41^8
7 /8 X 2 81 1
95B323
Dated this
4
5
II. DECLARATION
8
9
10
11
12
13
the garnishment are listed as follows:
14
15
16
17
18
$1,500.00
$ 18.13
$20.00
$0.00
$16.23
$0.00
$0.00
24
$250.00
25
Other: (describe)
$0.00
19
20
21
22
23
14199
7 /8 ^ 2 9 1 1
95B321
2
$286.23
The undersigned further states that more than twenty (20) days have elapsed
since service of the Writ of Garnishment and Garnishees answer thereto; that a signed
affidavit or return of service of the Writ of Garnishment plus the following checked
documents, indicating service upon the Judgment Debtor either by personal service or
10
I declare under penalty of perjury under the laws of the State of Washington that
11
12
day of June,
13
14
DANIEL N. COOK
15
16
17
18
19
20
21
22
23
24
25
MOTION AND DECLARATION FOR JUDGMENT AND ORDER TO
PAY P age-3
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Jun-22-20l 1 11:55:51
First/Middle
Begin Date
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 Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard). HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF
DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT
THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE
OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL.
Y fa b fy y k .
https://www.dmdc.osd.mil/appj/scra/popreport.do
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Page 2 of 2
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-ofcontact.
M ore inform ation on "A ctive D u ty Sta tu s "
Active duty status as reported in this certificate is defined in accordance with 10 USC 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage U nder the S C R A is B roader in S o m e Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
Report ID:LM71E02QQC
https://www.dmdc.osd.mil/appj/scra/popreport.do
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958324
1
2
3
4
5
6
7
Superior Court of W ashington
County of Pierce
8
9
10
No.
J E N N IF E R KAY S H IP M A N
10-3-00961-1
11
Petitioner,
12
and
F IR S T A N S W E R T O W R IT O F
13
J A S O N W IL L IA M SHIPMAN
C O N T IN U IN G L IE N O N
E A R N IN G S (A N W R G R )
14
15
Respondent.
FRANCISCAN HEALTH SYSTEM
16
Garnishee Defendant
17
18
19
20
21
22
23
24
25
SECTION I
O n the date the Writ of G arnishm ent w as issued as indicated by the d a te
ap p earin g on the last page of the writ,
(A )
The Petitioner [*f w as [ ] w as not em ployed by G arnishee. If not
em p lo yed , and you have no possession or control o f a n y funds o f Petitioner, indicate
the last d ay of em ploym ent: _____________________ ; and com plete Section III of this
A n sw er and mail or delivepthe forms as directed in the Writ.
(B )
Petitioner M did M /did not m aintain a financial account with G a rn is h e e ..
(C )
T h e G arnishee [*f did [ ] did not have possession o f or control over any
funds, personal property, or effects of Petitioner. (List all of the P etitio n er's personal
property or effects in your possession or control on the bottom o f the last page of this
an sw er form or attach a schedule if necessary.)
If you are withholding the P e titio n e r's nonexem pt earnings under a previously
ANSW ER: W PF GARN 01.0750 (7/2003) - RCW 6.27.190, .340
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7 / ^2 0 1 1
358325
served writ for a continuing lien, answer only Sections I and III of this form and mail or
deliver the forms as directed in the writ. Withhold from the Petitioner's future
nonexempt earnings as directed in the writ, and a second set of answer forms will be
forwarded to you later.
ANSWER: l am presently holding the Petitioner s nonexempt earnings under a
previous writ served o n __________________ (date) that will terminate not later than
____________________(date).
If you are NOT withholding the Petitioners earnings under a previously served
writ for a continuing lien, answer this entire form and mail or deliver the forms as
directed in the writ. A second set of answer forms will be forwarded to you later for
subsequently withheld earnings.
SECTION II
At the tim e of service of the W rit of G arnishm ent on the G arnishee, there w as
d u e and owing from the G arnishee to the ab o ve -n a m e d P etitioner $_________________ /
This writ attaches a m axim um of 25 percent o f the P etitioner s disposable
earnings (that is, com pensation payable for personal services, w h eth er called w ag es ,
salary, com m ission, bonus, or otherwise, and including periodic paym ents pursuant to a
nongovernm ental pension or retirem ent program ). C alcu late the attachable am ount as
follows:
G ross Earnings:
$__________________ (1)
Less deductions required by law (Social Security, federal
withholding tax, etc. Do not include deductions for child
support orders or governm ent liens here. Deduct child
support orders and liens on line 7):
DisposabJe Earnings (subtract line 2 from line 1 ):
E n ter 75 % (p ercent) of line 3:
E n ter one of the following exem pt am ounts*:
If paid W e e k ly $ _______
Sem i-m onthly
$_
B i-w eekly
$_______
Monthly
. $
*T h e s e are m inim um exem pt am ounts that the P etitioner m ust be paid. If
your an sw er covers m ore than one pay period, multiply the preceding am o u n t
by the num ber of pay periods and/or fraction thereof your an sw er covers. If
you use a pay period not shown, prorate the m onthly exem pt am ount.
Subtract the larger of lines 4 and 5 from line 3:
E n ter am ount (if any) withheld from this paycheck for
ongoing g overn m en t liens such as child support:
(6)
(7)
(8)
1 4 I3 &
7 /8 ^ 2 g iI
950326
1
This is the form Lila that you will Lise for withholding each pay period over the
z
required 60-day garnishment period. Deduct any allowable processing fee you may
3
4
5
6
7
8
10
11
12
I have
accom panying schedules, and to the best of my know ledge and belief, it is true, correct
a n d com plete.
Dated:
//
13
14
15
16
-j
f /
17
18
19
20
21
24
Phnnft Numhfir
Catholic Health Initiatives
Garnishment Department
3900 Olympic Blvd., Suite 400
Erlanger,KY 41018-1099
25
pages
22
23
55218
23516909
Employee
Payment Nht
Case
Fiie Number /
FIPS
Department
ST CLARE HOSPITAL
3091.31
LQ-3-00961-1
Disposable
Income
Exempt Wages
2333.B8
1750-11
3136
ORTHOPEDIC SURGICAL
SSN 536-86-2306
Payment Date 01/08/2011
SHIPMAN, JENNIFER K.
Payment Type Direct Deposit
Gross Pay
Page
company B900
CATHOLIC HEALTH INITIATIVES
Garnishment Audit Report
Report Sequence Proc Level/Dept/Emp Name
Time 06:29
Garn
Ded
G2 0P
Amount
583 .19
ClrHse
Fee
Arr
Court Fee Ded
0.00
0.00
Amount
0.00
Fee
Court
Arreas Fee Oed
0.00
Amount
0.00
583.19
0 .00
0,00
0.00
583.19
0 .00
0.00
0.00
583.19
0 .00
0.00
0.00
583 .19
0 .00
0.00
0.00
Employee Total
Department 3136
Total
A*
h*
KO
CO
"0
X
CP
\
CP
k*<
M
-'
\
\
Ui
si
tii
M
Aj
\\
-J
*1
\
\
i4 i9 8
7 ^8 /2 8 i i
5S8328
2
3
4
5
6
7
8
Superior Court o f W ashington
County o f Pierce
9
10
In re the m arriage of:
11
No.
J E N N IF E R KAY S H IP M A N
1 0 -3 -0 0 9 6 1 -1
12
Petitioner,
13
14
SEC O N D A N S W E R TO W R IT OF
G ARNISHM ENT FO R CO NTINUING
LIEN ON EARNING S
and
J A S O N W IL L IA M S H IP M A N
15
R espondent
16
Garnishee Defendant
18
19
SECTION I
20
21
22
23
24
25
. 9
Answer.doc
7
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 - 100th S t SW#25
Lakewood, WA 98499
253-581-0660
4198
1
Amount accrued since first answer
$ /2 -Z V
TOTAL A M O U N T W ITHHELD
/ e a r . / 3
? y Qy 2 8 i I
958329
(*>
3
4
SECTION II
At the time of service of the Writ of Garnishment on the Garnishee, there was due and owing
from the Garnishee to the above-named defendant $ _________________ .
7
This writ attaches a maximum of 25 percent of the Petitioner / Respondents disposable
8
earnings (that is, compensation payable for personal services, whether called wages, salary,
9
commission, bonus, or otherwise, and including periodic payments pursuant to a
10
nongovernmental pension or retirement program). Calculate the attachable amount as follows:
11
Gross Earnings:
$ __________________ (1)
12
14
( 2)
15
(3)
16
(4)
17
(5)
18
If paid Weekly
Bi-weekly
13
$_
$_
Semi-monthly $_
Monthly
$_
19
These are minimum exempt amounts that th e ___ (employee Pet / Resp) must be paid. If your
20
answer covers more than one pay period, multiply the preceding amount by the number of pay
21
periods and/or fraction thereof your answer covers. If you use a pay period not shown, prorate
22
the monthly exempt amount.
23
Subtract the larger of lines 4 and 5 from line 3:
$ __________________ (6)
24
25
Answer.doc
(7)
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 -1 0 0 th St. SW #25
Lakewood, WA 98499
253-581-0660
1
2
$ ______________ _
(8 )
This is the formula that you will use for withholding each pay period over the required 60-day
garnishment period. Deduct any allowable processing fee you may charge from the amount
that is to be paid to th e ____ Petitioner / Respondent.
6
If there is any uncertainly about your answer give an explanation on the last page or on an
attached page.
SECTION III
An attorney may answer for the Garnishee.
10
Under penalty of perjury, I affirm that I have examined this answer, including accompanying
11
schedules, and to the best of my knowledge and belief, it is true, correct and complete.
12
____________________________
Signature of Garnishee Defendant
14
15
6 - a s *"- / / ________
Date
/ ty y < e .d >
Signature of Person Answering for Garnishee
//e
16
y
tfr ?
18
19
- s '?
y -ir
ess of Garnishee:
Phone Number
20
21
if necessary, use the space below to supplement your answer from the first and second pages:
*
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 - 100th St. SW #25
Lakewood, WA 98499
253-581-0660
SS21G
23546907
Employee
Payment Nbr
350331
Case
File Number /
FIPS
SHIPMAN, JENNIFER K .
Payment Type Direct Deposit
Gross Pay
3071 ,34
10-3-00961-1
23S00017
Payment Nbr
Case
File Number ;/
FIPS
Gross Pay
23630632
Case
File Number /
FIPS
Payment Nbr
Case
File Number /
Gross Pay
23672421
FIPS
10-3-00961-1
2333.BB
1750.41
Ga rn
Ded
G20P
Di sposable
Income
Exempt Wages
2289.05
1716.78
Di sposable
Income
Exempt Wages
2423 .06
18 17.29
3062.85
Di sposable
Income
Exempt Wages
2327.93
ClrHse
Amount
583 .47
Ga rn
Ded Amount
G20P
Fee
Arr
Court Fee Ded
0.00
0.00
Amount
0, 00
Court
Fee
Arreas Fee Ded
0 .00
Amount
0.00
572,26
ClrHse
Fee
Arr
Court Fee Ded
0.00
0.00
Amount
0.00
Court
Fee
Arreas Fee Ded
0.00
Amount
0.00
Amount
605.77
ClrHse
Fee
Arr
Court Fee Ded
0,00
0.00
Amount
0.00
Court
Fee
Arreas Fee Ded
0.00
Amount
0.00
Grogs Pay
3190.54
10-3-00961-1
Di sposable
Income
Exempt Wages
Page
SSN 536-89-2306
Payment Date 04/08/2011
3007.40
10-3-00961 -1
Payment Nbr
Company 0900
CATHOLIC HEALTH INITIATIVES
Garnishment Audit Report
Report Sequence Employee Name
Ga rr.
Ded
1745.94
G20P
Amount
46.63
ClrHse
Fee
Arr
Court Fee Ded
0.00
0.00
Amount
0.00
Court
Fee
Arreas Fee Ded
0,00
Amount
0,00
1.808.13
0,00
0.00
0.00
1,808.13
0,00
0.00
0.00
14138
7SB/2&11
358332
1
10-3-00961-1
36728093
JDOAGD
07-08-11
2
3
IN COUNTY ClI
4
5
r K'S OFFICE
6
7
8
9
10
11
No.
12
Petitioner,
10-3-00961-1
13
and
JUD G M EN T A N D ORDER TO
PAY
14
15
16
17
Respondent.
FRANCISCAN HEALTH SYSTEM
Garnishee Defendant
18
19
21
22
23
24
Judgments to bear interest at 12% per annum.
25
Attorney for Judgment Creditor:
JUDGMENT AND ORDER TO PAY P ag e -1
WPF GARN 01.0800 (7/2003); RCW4.64.030; 6.27.__
S:\C ASE S 1\Shipman, Jason disso\Gamishment\payorderemp.doc
DANIEL N. COOK
ORIGINAL
20
14138
7 /S /2 8 1 1
358333
II. BASIS
IT APPEARING TH A T Garnishee was indebted to Petitioner in the nonexempt
amount of $1,808.13; that at the time the Writ of Garnishment was issued, Petitioner
was employed by Garnishee, or Garnishee had in its possession or control funds,
personal property, or effects of Petitioner; and that Respondent has incurred
recoverable costs and attorney's fees of $286.23, it is NOW, THEREFO RE,
III. ORDER
ORDERED that Respondent is awarded judgment against Garnishee in the
amount of $1,808.13; that Respondent is awarded judgment against Petitioner in the
amount of $286.23 for recoverable costs; that Garnishee shall pay its judgment amount
to through the Registry of the Court, and the Clerk of the Court shall note receipt thereof
and forthwith disburse such payment to DANIEL N. COOK, Attorney for Respondent.
Garnishee is advised that the failure to pay its judgment amount may result in execution
AM.
DANIEL N. COOK, W S B 7 n m 8 6 6
Of Attorneys for Respondent
1428&
1&&634
p tL iX ^ L ) p J U lS A k . J
NOTES:
Rev. (3/04)
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
July 14 2011 8:56 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
Please take notice that the undersigned will bring on for hearing a motion for:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
Motion
Nature of Hearing: In Limine
9:00 AM
WORKING COPIES SHALL BE DELIVERED TO THE COURT PURSUANT TO PCLR 7 (a) (7)
PARTY SETTING HEARING SHALL CONFIRM BY NOON TWO COURT DAYS PRIOR TO HEARING
Submitted by:
DATED:
Signed:
NAME:
TIMOTHY M. GREENE
Phone:
(253) 770-0808
WSBA#:
For:
17499
1 of
e - f il e :
IN COUNTY CLERI
PIERCE COUNTY, W
July 14 2011 9
KEVIN SIC
COUNTY CL
NO: 10-3-0C
2
3
4
5
6
7
In re : th e m a rria g e o f
8
NO.
J E N N IF E R K A Y S H IP M A N
9
P e titio n e r,
an d
10
11
1 0 -3-00961-1
P E T IT IO N E R S M O T IO N
I N L IM IN E T O E X C L U D E C E R T A IN
T E S T IM O N Y R E : P A R E N T IN G
J A S O N W IL L IA M S H IP M A N
R e sp o n d e n t.
12
13
14
te s tim o n y o f th e p a te rn a l g ra n d m o th e r o f th e ch ild re n , B e c k y R a m b o , re g a rd in g p a r e n ts
15
16
17
18
19
20
21
22
1 f 2
2
3
10
11
D a te d : Ju ly 14, 2011_________________
R e sp e c tfu lly su b m itted ,
G R EEN E & LLOY D, PLLC
12
13
/s / T IM O T H Y M . G R E E N E
T im o th y M . G re en e, W S B A # 1 7 4 9 9
A tto rn e y fo r P e titio n e r
Je n n ife r K a y S h ip m a n
14
15
16
17
18
19
20
21
22
2 of 2
E-FILE
IN COUNTY CLEI
PIERCE COUNTY,
July 15 2011
KEVIN ST
COUNTY C
NO: 10-3-C
3
4
5
6
11
12
NO. 10-3-00961-1
13
The parties agree that the children of the parties, Hunter and Tyler, will not be testifying.
14
The parties agree that the paternal grandmother, Becky Rambo, will not be testifying.
15
Petitioners motion regarding the testimony of the above parties, set for hearing on July 22, 2011,
16
is stricken.
17
18
OYD, PLLC
19
20
21
22
07-19-11
r-ii r r \
* JUL 18 2011 PM
:RCE COUNTY WASHINGTON
KEVIN ^O C K^junty Clerk
In re:
No. 10-3-00961-1
Respondents
Domestic Relations
Pre-Trial Information
Form
Petitioner /Wife/Mother
Respondent/Husband/Father
Respondents
Domestic Relations
Pre-Trial Information
f^
tl-v
tali
r. ~ 'A
I
_L
3BS x2 3
DEPENDENT CHILDREN:
Per Cent Res. Time
This Marriage
Resp.
Name:
Age:
Since
Tyler
16
Yes
no
80
20
8/24/10
Hunter
10
Yes
no
80
20
8/24/10
CHILD SUPPORT
L
NET INCOME
Petitioner
$4, J46.17
Respondent
$1868.10
SUPPORT
$460.96
The Respondent objects to modification of the Petitioners finacial declaration. The order that was filed
on June 30, 2011 is correct. The respondent has not filed for a motion at the time of trial,
So the Respondent furthers his objection to any modification.
Respondent's
Domestic Relations
Pre-Tnai Information
^ .; ? I. t; j a
x m *2 x -x j e o i ,-?r7
The respondent claims that the 2009 tax return was used to pay community debt. The respondent gave
half of what was left to the petitioner.
Property Devision
The petitioner has other unlisted community property as follows.
Jewelry $20,000.00
Pool Table $1500.00
Antique Furniture - nick nacks $ 15,000.00
3 Dogs $3,500.00
15 guns $15,000.00
Pepsi Macine $1,000.00
Household Furniture $10,000.00
Dishes Small Aplfiances $2,000.00
Large Appliances $3,000.00
3 Plasma Televisions $2,500.00
Tools $5,000.00
Video Games $3,000.00
Computer $3,000.00
Camera Equipment $5,000.00
Stereo System $1,000.00
CCTV Securtity System $5,000.00
Race Equipment $10,000
Total: $105,500.00
Respondents
Domestic Relations
Pre-Tnal Information
Debt Devision
All commutiy debt was paid by the respondent with 2009 tax return. The respondent object to any other
debt obligation as it was obtained by the petitioner outside of the marriage.
Se
ason Shipman
Respondents
Domestic Relations
Pre-Trial Information
I
10-3-00961-1
36786820
FNDCLR
07-19-11
|C/l^
4-es
J) I?,
/0
No.
Petitioner,
and
A W p tvitu A
Respondent.
Name*
U r a *t
3 M
R ,/-'
Financial Declaration
[ ] Petitioner
^ [R e s p o n d e n t
(FNDCLR)
fy
~7
Date of Birth'
$_3 5 <5
$
$
n$
[ ] unknown
Occupation
22
23
1-e^.W/
(1)
I 2^
No
Where do you work Employers name and address must be listed on the
Confidential Information Form
a otj i 3 3
j~^ _l j j-'. rr *
f
\
i
b If no
(2)
(1)
(2)
(3)
cXo /(
Name
$ a o 7 .s tz -
Business Income
Other Income
-e
f.
g*
s2,o 7 5 ^
Income Taxes
FICA/Self-employment Taxes
c.
s 3Y
f.
s IXXo
[>*JfilifaM
y^gi*1wy*yn
7 V 'i:~ )y T 'E i ."
V
\
34
i 4 4 *. 3
Miscellaneous Income
a
$ _________
$
$
$
c
lin e s
4 a th ro u g h 3 4 b )
$
$
.t / S e e
3.5
36
If the income of either party is disputed, state monthly income you believe is correct and explain below ;
Cash on hand
4.2
On deposit in banks
4.3
4.4
5.1
Housing
..&
$ /3?r
Taxes
&
Total Housing
5.2
13
Utilities
Heat (gas
&
oil)
Electricity
Financial Declaration (hNDCLR) - Page 3 of 6
WPF DRPSCU 01 1550 (6/2006) - R C W 26 18 220(1)
(0 o , 0^-
3 - o o X -3 4
Telephone
$
$
$
$
Cable
Other
Total Utilities
5.3
fc>
persons
So
/ fc>Q
j rj& -
5.4
Children
Day Care/Babysitting
Clothing
Tuition (if any)
Other child-related expenses
Total Expenses. Children
5.5
$
M $
$ &
0
$
$h o #
T ransportation
Vehicle payments or leases
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
4''g o
JC n
A o o **'
Parking
Other transportation expenses
Total Transportation
5.6
5.7
5.8
Miscellaneous Expenses
Life insurance (if not deducted from income)
Other ______________________________________________
Other ______________________________________________
Total Miscellaneous Expenses
$ I S I S
5.9
5 .1 0
Creditor
Descnption
of Debt
Balance
^
Month of
JjfLast Payment
1 ? ____ _
uh J1 j f
if
f
5.11
Creditor
(W < e k /
Sill* <A-
/ . . / A ______
c*
Balance
________ p o o
Month of
Last Payment
a o if
_________iL ______
900
Amount of
M onthly
Payment
$
f oc> ^
$ lo p *
_______________ _
______________
________
________________ _
_________________
__________ __________
$_______
_______________ ___ _
___________________
___________ ___________
$ ________
_________________ __
____________________
_________________
__________ __________ $_______
_________________ ________________________ $
________
s______
%
i-j. J&Lft-Js
A 4
. ^
^.OX
a
JL
'\
-3
rinc
JGO
The cost o f this process sh all be allocated between the parties as follows.
[]
[]
JVo p etitio n er d *S
% respondent
based on each p a r ty s proportional share o f income from line 6 o f the child support
worksheets
as determined in th e dispute resolution process
The dispute resolution p ro cess shall be commenced by notifying the other party by [ ] written
request [ ] certified mail [ ] other*
In the dispute resolution p ro cess
(a)
(b)
(c)
(d)
(e)
[]
[]
5.12
$ 3 Z lF
6.2
6.3
64
65
Other
s 756$'
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and correct.
The follow ing financial records are being provided to the other party and filed separately with the court.
Financial records pertaining to myself.
dividual [ ] Partnership or Corporate Income Tax returns for the years
including all W-2s and schedules;
[ ] Pay stubs for the dates o f
[ j Other
Do not attach these financial records to the financial declaration. These financial
records should be served on the other party and filed with the court separately
using the seated 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 G R
22 (C)(2).
10-3-00961-1
36796824
07-19-11
PPP
IN c o u n t y t i l o
O FFICE
No. / O - 3 . 0 O f W - /
e.
o r -f-t. *
1^
Petitioner,
and
Respondent.
Parenting Plan
{4 Proposed (PPP)
[ ] Temporary (PPT)
[ ] Final Order (PP)
[]
[]
^
the final parenting plan signed by the court pursuant to a decree o f dissolution, legal
separation, or declaration concerning validity signed by the court on this date or
d a te d ___________________________ .
the final parenting plan signed by the court pursuant to an order signed by the court on
this date or d a te d ____________________________ , w hich m odifies a previous parenting
plan or custody decree.
a tem porary parenting plan signed by the court
proposed by (nam e) T T /a s o n w'.II.'am.
Mn r
Age
iG
'T J ? j e s
^ k, P r * * \A
10
^
[]
2.2
[]
.1 ~1~i- -LO
3.1
[]
every w eek [ ] every other week [ ] the first and third week o f the month
the second and fourth week o f the month [ ] other:
3.2
every w eek [ ] eveiy other week [ ] the first and third week o f the month
the second and fourth week o f the month [ ] other:
School Schedule
Upon enrollm ent in school, the child(ren) shall reside with the [ J petitioner
M respondent, except for the following days and times when the child(ren) will reside with or be
w ith the other parent'
from (day and tim e)
[]
[]
eveiy w e e k ^ every other week [ ] the first and third week o f the month
the second and fourth week o f the month [ ] other:
3 &Q
every w eek [ ] every other week [ ] the first and third week o f the month
the second and fourth week o f the month [ ] other
& 'Q
[]
3.3
The school schedule w ill start when each child begins [ ] kindergarten [ ] first grade
[ ] other.
I
ah.
3.4
^
fW
)r I i 11
oM
/W
&V4_<a
3.5
. *3)
Sum m er Schedule
Upon completion o f the school year, the child(ren) shall reside with tine [ ] petitioner
respondent, except for the following days and times when the child(ren) will reside with or be
with the other parent:
Same as school y ea r schedule.
O ther
k<ilf
7" W
& >ry
of
Waif 3.6
w /f W
{a
yioj-hes
Second
3 0 0 i'i
r~
\\
3.7
With Respondent
(Specify Year
Odd/Even/Every)
6 OP
prr \/" cl
oO P
o D D
t2 \f <tv\
to V P
(n O D
o O P
o D P ____________
n DP
ft D P
oOP
&se>A
______________
/ W W R M ________
__
o O D _____________
O O P _________
oO O
____Q P fi__________
F or purposes o f this parenting plan, a holiday shall begin and end as follows (set forth
tim es):
vnoasnlhf ,
o\r <
{
H olidays which fall on a Friday or a M onday shall include Saturday and Sunday.
[]
3.8
Other:
W tfY h A o -Y
ps
P t\(
B
l- fu rj T c /"
f]
f t *)
>\t^ W */'
^ X
B v
O ther
e ^ y e -V
o P f > _______________
____ o D j 2 . _______________
3.9
Does not apply b ecau se 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 o rd e r o f priority, with 1 being given the highest priority
3
[]
3.10
Other:
Restrictions
[]
3.11
7 holidays (3.7)
~7 special occasions (3 8)
1? vacation with parents (3 6)
w in te r vacation (3.3)
sch o o l breaks (3 4)
sum m er schedule (3 5)
There are lim iting factors in paragraph 2.2, but there are no restrictions on the
[ ] petitioners [ ] respondents residential time with the children for the following
reasons:
)A^n
f
The_
,
Iff
Jy
vp
fo
r'ect ev/^
3.12
Designation of Custodian
The children named in this parenting plan are scheduled to reside the majority o f the time with
the [ ] p e t i t io n e r ^ respondent. This parent is designated the custodian of the child(ren) solely
for purposes o f 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
Otherr
3.14
S ^ i-
b-e.
This is a sum m ary 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 o f the time plans to move, that person shall
give notice to every person entitled to court ordered time with the child
If the m ove is outside the childs school district, the relocating person must give notice by
personal service or by m ail 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 m ust give notice within 5 days after learning o f the move. The
notice m ust contain the inform ation required in RCW 26 09.440 See also form DRPSCU
07 0500, (N otice o f Intended Relocation o f A Child).
If the m ove is within the sam e 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 m odification under RCW 26.09 260
Notice m ay be delayed for 21 days if the relocating person is entering a domestic violence shelter
or is m oving to avoid a clear, immediate and unreasonable risk to health and safety
If inform ation is protected under a court order or the address confidential it}' program, it may be
withheld from the notice.
A relocating person may ask the court to waive any notice requirem ents that may put the health
and safety o f 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 sendee of the notice of intended relocation, the
relocation will be permitted and the proposed revised residential schedule may be
confirmed.
A person entitled to tim e w ith 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 m andatory pattern form WPF DRPSCU 07 0700,
(Objection to R elocation/Petition for Modification of Custody Decree/Parenting Plan/Residential
Schedule). The objection m ust be served on all persons entitled to tim e with the child.
The relocating person sh all 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 o f timely service of the
objection, the relocating p erso n shall not move the child before the hearing unless there is a
clear, immediate and unreasonable risk to the health or safety o f a person or a child.
Day-to-Day D ecisions
Each parent shall make decisions regarding the day-to-day care and control o f each child while
the child is residing w ith th at parent. Regardless o f the allocation o f decision making in this
parenting plan, either parent m ay make emergency decisions affecting the health or safety o f the
children.
4.2
Major Decisions
M ajor decisions regarding each child shall be m ade as follows:
Education decisions
Non-em ergency health care
Religious upbringing
[]
[]
U
[]
[]
[3
[]
[]
[]
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
[]
[3
[]
[]
[]
[]
[]
[]
[]
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
K
A
X
[]
[]
[]
[]
[]
[]
joint
joint
joint
joint
joint
joint
joint
joint
joint
4.3
Does not apply b ecause there are no limiting factors in paragraphs 2.1 and 2.2 above
Sole decision m aking shall be ordered to the [ ] petitioner [ ] respondent for the
following reasons:
[]
[]
[]
(d)
[]
There are lim iting factors in paragraph 2.2, but there are no restrictions on mutual
decision making fo r the following reasons:
V. Dispute Resolution
The p u rp o s e o f this d ispute re s o lu tio n p ro ce ss is to resolve disagreem ents about carrying out
this p a re n tin g p la n This d is p u te re solu tion p ro c e s s may, an d u n d e r som e lo cal c o u rt rules o r
the p ro v is io n s o f th is p la n m u s t be u se d before filin g a petition to m o d ify the plan o r a m otion for
contem pt fo r fa ilin g to fo llo w th e p la n
[]
D isputes between the parties, other than child support disputes, shall be submitted to (list person
or agency)
counseling by
*_/
Levite'S
& ^^
^ ^
[]
[]
arbitration by
________________________________________
[]
Petitioner
at
w/y
ispondent
Dated*_____________________________________
_________________________
Judge/Commissioner
Presented by:
Print Name
Print Name
7^26^2815
1 4 4 8 ?
1
2
3
4
5
6
IN THE SUPERIOR COURT OF WASHINGTON
IN AND FOR THE COUNTY OF PIERCE
8
9
10
)
)
)
)
)
^
,
11
and
12
13
14
15
F ILE D
IN COUNTY CLERKS OFFICE
A.H.
JUL 2 2 2011
PiaflGU6SMTY
16
17
RESPONDENT/HUSBAND/FATHER:
18
19
20
Age: 37
21
22
23
24
25
26
Petitioners
Domestic Relations
Pre-Trial Information
Form 1
6 / 2 4 3 J.1
14
1
2
DEPENDENT CHILDREN.
Name:
Age:
Tyler
16
yes
Hunter
10
yes
Pet.
Resp.
no
80
20
08/24/10
no
80
20
08/24/10
Since
6
7
8
9
CHILD SUPPORT
10
11
NET INCOME
12
13
Petitioner
$ 4,146.17
14
Respondent
$ 1,868.10
SUPPORT
$ 460.96 *
15
16
17
18
19
20
21
22
*The child support of $ 460.96, which was entered as a revised temporary child support order on
June 21 and June 30, 2011 (June 21 being the date the child support was set by Commissioner
and June 30 being the date the order was filed), is based on respondents calculation of
petitioners net income of $ 4,636.22, instead of our calculation of $ 4,146.17. Petitioner did
not challenge this calculation, because she did not timely file her revised financial declaration,
but obtained language in the Commissioners order that she could move for a correction of
the child support order at the time of trial, based on the revised financial declaration. We are
accordingly presenting a settlement offer which includes a proposed corrected support figure
that we propose to be effective August 1, 2011, without retroactive effect. The child support
figure that we are proposing is $ 546.29, and is supported by the attached proposed
child support worksheets and attached financial declaration.
23
Petitioners
Domestic Relations
Pre-Trial Information
Form 2
7 r'ZffSZ&ll
3 .4 4 8 7
Odd years to the mother and even years to the fathei or, as an alternative to the fathers
reluctance to pay for the childrens daycare and extracurricular expenses, the mother
4
maybe willing to assume those expenses, but take the tax exemption every year.
5
6
7
8
9
10
parent, and the mother wishes to keep it that way. The father recently petitioned to temporarily
11
12
eliminate, the child care expenses, under the right of first refusal concept, until he obtains
13
employment from his union hall or elsewhere, because he is available during the day to care for
14
the children, having been laid off at the beginning of May. Mother is opposed to this because the
15
16
father is now cohabiting with a girlfriend who has an admitted record of domestic violence
(burglary and malicious mischief) against her former boyfriend. This issue was reserved at the
17
June 21 hearing on temporary orders for trial. Father has failed to pay daycare expenses, despite
18
19
the presentation of daycare payment check carbon copies by the mother to the father via certified
20
mail. Mother and her attorney are reviewing the mailing address for father that mother used
21
22
23
Petitioners
Domestic Relations
Pre-Trial Information
Form 3
7 A 2 ^ 2 S :U .
1 -4 4 8 7
1
2
3
Mother also objects to the language of the August 24, 2010 temporary order in this matter, under
which the father pays a proportional share of the costs of the boys organized sports activities, if
the parties agree in writing. In practice, the father has resisted sharing these costs Mother
5
wishes the language to be mandatory that the father pay a proportional share of the costs of the
boys organized sports activities and extracurricular activities that they may be involved in
On the other hand, as stated above, mother may be willing to waive expenses for the children if
the father agrees to waive income tax exemption for the children
10
11
12
13
14
15
16
4. Child support currently being paid by father is $ 460.96/month, retroactive to May 1,2011.
(June 30, 2011 second temporary child support order).*
*The first child support order was entered on August 24, 2010 with a starting date of
September 1,2010. That order was based on fathers net income of $ 3,240.48, and
resulted in a transfer payment of $ 780.02. The second order was entered on account
of fathers unemployment as of May 1, 2011.
17
5. Summary of proposed residential arrangements for children: The present parenting plan of
18
19
visitation for father is visitation 5:00 p.m. Friday to Monday morning every other weekend
20
and Wednesday evening from 5:00 p.m. to 8.00 p.m. every week Five weeks of summer
21
vacation starting when school is out Miscellaneous holidays and special occasions.
22
23
24
25
26
Petitioners
Domestic Relations
Pre-Trial Information
Form 4
S i
? * # s i i 1M n%? UtS
Mothei is concerned with this arrangement because of recent revelation that the fathers
significant other (cohabitating girlfriend) has a criminal record of domestic violence in which she
was convicted of burglary and malicious mischief, given that there is a shotgun and at least one
other weapon in the fathers home. The father also has not m the past respectfully responded to
5
6
7
the mothers expression of hei concerns. At the very least, the mother would want leports
compliance by the girlfriend with the requirements of her sentence.
ATTACHMENTS:
10
o
12
13
11
14
15
PETITIONER INCOME:
16
Employer
Length
Gross Income
Net Income
$ 5,845.38/mo
$ 4,214.68/mo.
17
18
Franciscan Health
2 /2 mo.
19
20
21
22
RESPONDENT INCOME:
Employer
Length
Gross Income *
Net Income *
Unemployed
2 V2 months
$ 2,075.67/mo.
$ 1,868.10/mo.
23
24
25
*When employed, fathers gross income was $ 4, 299.00 a month, and his net income was
$ 3,240.48. Since father is dispatched to work from a union hall, we anticipate that he
will be returning to work at an income comparable to the income he had in his previous
employment.
26
Petitioners
Domestic Relations
Pre-Trial Information
Form 5
7^26^2811
14487
3
4
PROPERTY DIVISION:
5
The community home was foreclosed upon, and there was no deficiency judgment
1991 Ford F-150 and 1986 Toyota 4-Runner and earned $ 6,100 from those deals.
10
Husband says he received $ 2,200, not S 6,100 for the vehicles, and used the money to buy a
11
12
2002 Toyota Truck. The husband never filed a Financial Declaration, so it is unclear what
13
vehicles he has (he has also kept a motorcycle), and what his payments, if any, are on them The
14
15
16
The wife also claims that the husband took the $ 12,281 2009 community tax return and spent the
17
money, giving her only $ 790.45 out of it, when she was entitled to $ 6,140 of it. The husband
18
claims he spent the money on paying down three credit cards, a personal loan from a friend,
19
a house payment, and two months worth of power bills. (Please see Debt Division below).
20
21
22
The wife withdrew her retirement money about five years ago when she was laid off as
23
24
She currently has $ ______________ in retirement monies in her account. It is unknown, how
25
much, if any, funds the husband has in his retirement plans because the husband never filed a
26
Financial Declaration.
Petitioners
Domestic Relations
Pre-Trial Information
Form 6
7/
2 h s 2
1i
144B7
IB B
1
2
Because the father never filed a Financial Declaration, it is unknown how much income his
significant other earns and whether that should be a factoi in settling this dissolution
3
4
DEBT DIVISION*
5
The wife wishes that the husband agree to pay half of the unpaid community related bills that
accrued before the husband left the home. These bills are as follows.
Verizon cell:
Cable:
10
Water.
11
12
Garbage:
13
House phone*
14
Auto insurance:
15
16
The credit cards on which the husband claimed he partially paid the outstanding balances with
the communitys 2009 tax return were a Frontier credit card, a Chase credit card, and a
17
Home Depot credit card, with balances of $ 8,960.73, $ 6,885.62, and $ 6,737.80 respectively, as
18
19
of the entry of the Temporary Order on August 24, 2010. The father presumably is assuming
20
payment of these community debts, as the Temporary Order stated that each party was to be
21
responsible for their own debts after the date of August 24, 2010. The Mothers debts are Red
22
Canoe Bank (financing for her Cadillac Escalade), her $ 8,000 Sallie Mae student loan, and her
Verizon cell phone, as well as attorneys fees.
Petitioners
Domestic Relations
Pre-Trial Information
Form 7
7 S Z t-y 2& 1 1
1 .4 -4 IS 7*
1
2
CONCLUSION
Despite the fact that the husband nevei filed a Financial Declaration, because of the fact that the
4
parties have a relatively simple asset and liability situation, resolution of this matter should be
5
6'
8
9
Much of the issues in this matter relate to the execution of the Parenting Plan, regarding
time and location of exchanges, situational bargaining between the parties over going off the
10
Parenting Plan for emergencies, holidays, special occasions. There is still much anger between
11
12
the parties and they have yet to get involved in court ordered co-parenting counseling.
13
14
15
16
17
18
19
20
21
22
Petitioners
Domestic Relations
Pre-Trial Information
Form 8
10-3-00961-1
36820479
PIF
4 4 B?
07-25-11
)
)
)
)
)
^
4. Child support: The modification the mother suggests is related to the parenting plan in terms
of joint decision-making regarding where the children go to school. This has been a hotly
contested area, and the mother was found in contempt in Februrary, 2011, over the issue of
where the children go to school. The mother points out that although the father wants the right
of first refusal to lower what he deems are unnecessary day-care expenses while he is
unemployed, the only reason why the younger boy, Hunter, is in daycare is because of the school
which Jason insists he go to, which is Woodland Elementary (all the schools named are within
the same school district). Woodland Elementary is the school that Hunter attended before the
mother moved out of the community home, leaving it vacant (it was subsequently foreclosed
upon), and into her present residence.
Petitioners Supplemental
Domestic Relations
Pre-Trial Information
Form 1
2 .3 .&1
j. 4 4 3 3* 2 fee
From where mother presently lives, Hunter would attend Wildwood Elementary, according to
school district policy. The mother accordingly proposes, to save daycare expenses, that she be
4
5
The father owes the mother his proportion of daycare expenses for the following dates, pursuant
to the August 24, 2010 temporary order: October 2010, November 2010, December 2010,
January 2011, February 2011, March 2011, April 2011, May 2011, and June 2011. The father is
ordered to pay a proportional amount of his earnings for the daycare expenses for Hunter.
10
The father also did not pay daycare expenses for June, 2010, although he was not in violation of
n
12
an order for not doing so. The reason why the father would arguably not be found in contempt for
13
violating the August 24 Order is that the mother may not have had the fathers mailing address
14
correct. However, the father was aware that the children were in daycare, so he bears some
15
16
17
background check done on fathers significant other Melissa. Presumably this means a JIS
20
check. Mother also wants a copy of the police report taken on the incident leading to Melissas
21
conviction for burglary and malicious mischief. Mother is concerned that there has been no
22
evidence presented that Melissa underwent any anger management counseling after her
23
conviction. Mother also wants information on Jasons guns, as she is concerned about their
24
25
involvement in any domestic violence situation (at this point, potentially involving Melissa).
26
Petitioners Supplemental
Domestic Relations
Pre-Trial Information
Form 2
ZB i X
The mother wants the make, model, and serial number of the guns and proof they are in his
mothers home, as he has stated The mother is concerned that the father bought 9 year old
Hunter a gun (the mother had disapproved of this purchase) and the father has yet to enroll
6
7
Mother is also concerned that Melissa has a 16-17 year old boy that has been suspended from
school for truancy/insubordination, and has impregnated his girlfriend. She is concerned about
his potential influence on Tyler, the parties 16 year old boy, who has delinquency issues of his
10
own . At this point, again, the mother wants communication from the father, perhaps what steps
11
12
13
the father and Melissa are taking to educate this boy on responsibility, as the mother is doing in
working with Tyler.
14
15
16
There are no detailed specifications for visitation exchanges in the parenting plan. At the present
time, the exchanges are taking place at the parents house for the father. This has proven
17
inconvenient for the paternal grandfather, as the mother picks up the children at 8:00 p.m., and
18
19
the paternal grandfathers bedtime is shortly after 8:00 p.m. Accordingly, if the mother is a few
20
minutes late, which unfortunately happens on occasion, as she attends an evening support group,
21
it upsets the paternal grandfather, and creates tension between the parties. The mother proposes
22
an exchange point to be written into the parenting plan, and one that would be a commercial
23
business parking lot. She suggests Sharis on Meridian, which is next to Top Foods.
Petitioners Supplemental
Domestic Relations
Pre-Trial Information
Form 3
S a fi
The mother also would like to tweak the parenting plan as far as holiday visitation exchanges.
Holiday visitation is from 8 a.m. to 10 p.m. Often the mother, being a nurse, has to work on
holidays. She has to be at work at 7 a.m. In the past, the father has threatened to call the police if
the mother did not adhere to the plan, which has forced her to take family crisis time off of
5
6
7
work. For the Fourth of July, the mother suggests that the visitation be extended on that day to
midnight, in order that the children can enjoy the fireworks and the holiday with one parent.
8
9
PROPERTY DIVISION:
10
RetirementHusband and wife both cashed out their retirement fund once during the marriage.
11
12
At the time of separation, wife had around $ 2,000 in retirement, and husband had around
13
$ 21,000. The wife proposes a 50/50 split of the retirement funds, which would probably be
14
accomplished most easily by a Qualified Domestic Relations Order giving the wife $ 9,500 of
15
16
17
Vehicles: The 4-runner for the husband was purchased with funds from the cash-out of the wifes
18
19
retirement fund for $ 4,000. The husband then sold it for $ 4,500 cash. He also sold the Ford F-
20
150 for $ 600, and kept the money. The wife wants $ 2,550 from the husband.
21
22
23
24
25
26
Petitioners Supplemental
Domestic Relations
Pre-Trial Information
Form 4
7 '
2 {)''7 , 8
i4 4 B 7
Miscellaneous Personal Property: The wife notes that the husband took the bulk of big-ticket
community property items when he moved out, primarily a 23 enclosed trailer purchased for
$ 4,000, a 10 enclosed trailer purchased for $ 2,000 (see Frenchys loan under Debt Division), a
mountain bike purchased for $ 1,700, a hot tub purchased for $ 4,106, a bow flex purchased for
5
$ 1,800, 2 race cars, 5 go karts, an engine tool (aka cherry picker) purchased for $ 800, a
video camera purchased for $ 800, guns, stainless steel bbg, GPS, numerous tools, and hunting
and camping gear. The wife notes that the husband accrued considerable airline mileage on his
credit cards, and although those miles are probably not transferable, she notes this is a
10
community benefit which he retains exclusively.
11
12
13
Items Personal to Wife: The husband took all of the photo albums, which includes pictures of
14
wife's family including pictures of the parties children. The wife wants all pictures of her family
15
16
17
18
19
The husband took the wifes grandfathers pocket watch which dates from the late 1800s-early
1900s. He also took the wifes wedding ring.
20
21
22
23
24
25
26
Petitioners Supplemental
Domestic Relations
Pre-Trial Information
Form 5
7 / 2 6 /2 8 1 1
44B
DEBT DIVISION:
Credit Cards: The wife wishes to correct the balances stated in her Petitioners Pre-Trial
Domestic Relations Information Fonn for the three credit cards that the husband said that he paid
off, the Frontier, Chase, and Home Depot credit cards. The actual balances, according the wife,
5
were between $ 1,000 and $ 3,000 on each card, not the amounts stated.
8
9
Frenchys Personal Loan to Husband: This money was used to buy the 10 enclosed trailer
that is now in the possession of the husband.
10
11
12
IRS garnishment: The IRS took $ 2,376.40 out of the wifes tax refund this year (since she
13
filed first) for a mistake made on the communitys 2008 tax return. The husband owes the wife
14
15
16
Wifes Saliie Mae student loan repayment: The loan, with a current balance of $ 8,000,
17
18
19
enabled the wife to earn a nurses salary, which benefited the marital community for several
years. The wife is asking that the husband to pay back $ 4,000 of that loan.
20
21
22
23
24
25
26
Petitioners Supplemental
Domestic Relations
Pre-Trial Information
Form 6
8 ^ 1 ^ 2 8 1 -1
10-3-00961-1
36855444
14S7S
CFR
Cause No 10-3-00961-1
Dissolution with Children
Plaintiff/Petitioner Counsel:
Defendant/Respondent Counsel:
ROBERT D LLOYD
253-770-0808
Additional Counsel (Name and phone number)
Daniel N Cook
253-581-0660
Self-Represented* Petitioner/Respondent?
1
2.
_days
(unknown) Date
7.
Priority Status?
Any consideration for giving this case priority?
10
Readiness remarks
(No)
(No)
days?
Judge/JA
Reassignment
at
5S243
, 20
Trial/Motion to Continue / Case Settled / Parties FTA / Unable to Assign / Form Incomplete
fading of the Record / Formal Proof / Motion for Default / No Settlement Conference Held
All parties DID / DID NOT comply with Rule
PRIORITY SETTING IS / IS NOT recommende
Days.
]2cDays [
ftC 4 < o
Calen
]3
ii
Self-Represented Petitioner/Respondent?
1
2
4.
days
(unknown) Date___
5.
6.
Priority Status?
Any consideration for giving this case priority?______________________________
10
Readiness remarks______
days?
(No)
(jY e s fo (No)
Reassignment
e$Wor/Trial to
se is reassigne
q L Ij >day c
I parties are to report immediately Yc^he above
Return to department for:
Trial / Motion to Continue / Case Settled / Parties FTA / Unable to Assign / Form Incomplete
Reading of the Record / Formal Proof / Motion for Default / No Settlement Conference Held
All parties DID / DID NOT comply with R ule/0
PRIORITY SETTING IS / IS NOT recommende^jSi
Days.
Cale
[3) by waiting
trilled for: [
^1 properly excused
*y 'I
]2 Days [
]3
& /iszers
.1.
Cause Number
10-3-00961-1
Petitioner(s)
vs
Page 1 of 3
ROBERT D LLOYD
TIMOTHY M GREENE
SHIPMAN, TYLER
SHIPMAN, HUNTER
S 2 r-
vs
JASON WILLIAM SHIPMAN
Page 2 of 3
Judge/Commissioner
RONALD E CULPEPPER
MINUTES OF PROCEEDING
Judicial Assistant/Clerk ANGELA EDWARDS
Court Reporter KARLA JOHNSON
Start Date/Time: 07/27/11 1:52 PM
July 27, 2011 02:49 PM Court reconvenes. PET WIT Jennifer Shipman retakes the stand,
* *
vs
JASON WILLIAM SHIPMAN
Page: 3 of 3
Judge/Commissioner
RONALD E CULPEPPER
8 ^ 1 ^ 2 8 1 1 1 ^ 5 2 5 SS024.8
1 0 -3 -0 0 9 6 1 -1
36Br>5468
CME
07-29-11
Cause Number
Petitioners)
10-3-00961-1
vs
Page 1 of 3
ROBERT D LLOYD
TIMOTHY M GREENE
SHIPMAN, TYLER
SHIPMAN. HUNTER
Outcome Date
B ^ j U J2 I l
14S7S
vs.
JASON WILLIAM SHIPMAN
Page 2 of 3
Judge/Commissioner
RONALD E CULPEPPER
________________________________MINUTES OF PROCEEDING_______________________
Judicial Assistant/Clerk ANGELA EDWARDS
Court Reporter KARLA JOHNSON
Start Date/Time: 07/26/11 10:31 AM
late development and how to proceed. 10:58 AM Due to new issue that has arisen (that
apparently original trial department did not have knowledge of) court finds this matter is not
ready for trial and a GAL should be appointed. Court reviews respondent's petition filed
7/18/11. 11:01 AM Respondent addresses court re possible visitation suggestions in order
to resolve this case today. 11.02 AM Atty Greene objects to any parenting plan issues
being decided today as his client is not present. 11.07 AM Court will recess this trial until
tomorrow at 9:30 a.m. whether petitioner is here or not.
End Date/Time: 07/26/11 11:09 AM
vs
JASON WILLIAM SHIPMAN
Page 3 of 3
Judge/Commissioner.
RONALD E CULPEPPER
z s .ti
10-3-00961-1
36855470
TRMM
ssiB ss-a
0 7 -2 9 -1 1
2
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF PIERCE
7
8
)
)
)
)
)
)
)
)
)
9
10
JENNIFER SHIPMAN,
Petitioner,
11
And,
12
JASON SHIPMAN,
____________ Respondent,
13
I. INTRODUCTION
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Petitioner is 37 years of age, and respondent is 38 years of age. The parties separated after 16
years of marriage, the date of marriage being April 24, 1994, and the date of separation being
February 27, 2010. Petitioner is a nurse, and has been so employed for 10 years; until recently
respondent was employed as an installation and maintenance technician and had been so
employed for seven years (respondent was laid off on May 1, 2011, but hopefully his active
union hall membership will enable him to find another job shortly). When respondent was
employed, the parties had comparatively equal incomes, with petitioner slightly ahead
(respondent had been earning 41.14% of the total income, and petitioner had been earning
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The parties have two boys, Tyler, who is 16 years of age and will be turning 17 years of age next
month, and Hunter, who is 10 years of age. Petitioner has been the primary residential parent
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Petitioner lives in the southern part of Puyallup, and respondent lives in South Hill. The parties
live (by undersigned counsels estimate) between 2 Vi miles to 3 miles from each other.
Both parties vacated the community home, the respondent having vacated first, at the time of the
parties separation on February 27, 2010, and the petitioner having vacated in the beginning of
October, 2010. Both parties moved to a location within 2 Vi to 3 miles of the community home,
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which had been close to the boundary line between Puyallup and South Hill. The house was
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foreclosed upon in April, 2011 without any deficiency judgment. There was little, if any, equity
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The parties separated by the respondent moving out of the community home to a temporary
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residence, and then informing petitioner that he had moved, on February 27, 2010.
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Petitioner filed and served her petition, financial declaration and proposed child support
worksheets, and proposed parenting plan on March 15, 2010. She was represented by
undersigned counsel at that time, and has been so represented ever since. No proposal for the
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Respondent filed his response on March 31, 2010. He indicated that he would prefer mediation
for property division instead of a court proceeding , that the child support worksheet should be
modified to fathers actual income, and that child support covers all expenses to support the
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children including daycare. His only objection to the parenting plan proposed by petitioner is
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The parties initially attempted an amicable dissolution without court process, but by summer the
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parties decided to resort to the court process. Respondent retained counsel and the parties
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were in court for a hearing on a temporary order on August 24, 2010. Respondent indicated that
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he generally agreefd] with the proposed [parenting] plan, but wanted more time with the boys
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in the summer. His primary dispute with petitioner was over division of property and petitioner
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A temporary parenting plan was entered which gave respondent additional time in the summer
with the boys and some additional time on his regularly scheduled visitation. A temporary child
support order was also entered. The petitioner was also ordered to make the monthly mortgage
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Petitioner, however, was unable to make the house payments and petitioner further was unable to
stop mold growing in the family home. She moved out to her present location, and continued to
try to sell the home (as apparently did respondent). Neither party was successful, and the house
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was foreclosed on in April, 2011. Petitioner moved within the same school district, but the boys
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were now in different schools as a result. Petitioner was found in contempt for this (although she
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and undersigned counsel maintained that they had notified respondent and respondents counsel
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about the move), and petitioner was ordered to put the boys back in the schools that they were in
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Respondent was laid off on May 1, and moved to modify the child support schedule accordingly.
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His attorney withdrew shortly thereafter. Petitioner did not oppose this move, and a modification
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was granted, retroactive to May 1, at a June 21 hearing. However, petitioner did oppose the
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respondents request that he be given a right of first refusal to supervise the boys in lieu of
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daycare, since he was unemployed. Petitioner opposed that request, for reasons that she will
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$4S
/r.
The court on June 21 reserved the right of first refusal issue for trial. It also reserved a permanent
decision on the child support issue, for the period starting August 1, until trial (see below).
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Respondent, on July 18, filed for the first time, a proposed parenting plan making him the
III. ISSUES
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The parties have different proposals for parenting plan, child support, and division of property
and liabilities.
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Child support: Petitioner filed a modified financial declaration with sealed financial documents,
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which reflects her slightly lower income at present, on June 15. This document was not filed in
12
time for the June 21 hearing, and, according to the proposed child support worksheets which
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were served on respondent at the settlement conference, the correct child support should be
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$ 546.29, due to a slight reduction in hours, rather than the $ 460.96 that respondent is presently
15
paying.
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Petitioner also wants reimbursement for daycare expenses that the respondent has not paid for the
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months of September 2010, part of February 2011, March 2011, April 2011, May 2011, and
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June, 2011. Daycare is $ 200/month and respondent was ordered in the child support orders to
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Respondent also has not paid any contribution for extraordinary health care expenses,
extracurricular activity expenses, and court costs (for Tyler) for the boys, despite the petitioners
request. (It is true that the August 24, 2010 temporary order states that respondent is only to pay
for extracurricular activities that he agrees to in writing; petitioner, however, wants this provision
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Petitioner will propose, as an alternative to the respondent paying any expenses, besides basic
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daycare and his unions health insurance, that petitioner pay 100% of daycare, extracurricular
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activity expenses, and extraordinary health expenses, provided that she is awarded the sole
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Petitioner is opposed to the right of first refusal provision for several reasons, which in
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summary are: concern about respondents girlfriend, who has a recent domestic violence burglary
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on her record, from supervising Hunter every day; the complications in daily visitation
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exchanges, morning and afternoon, for the limited amount of daily time Hunter is in daycare;
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and the fact that Hunter would not need daycare if he is allowed to attend the neighborhood
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school he is assigned to, rather than the school he was ordered to attend in the contempt motion.
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Parenting plan: Petitioner wishes to make only slight modifications in the August 24 temporary
parenting plan, which makes her the primary residential parent and gives respondent visitation
every other weekend through Monday morning, every Wednesday evening, and extra time on
school breaks, selected holidays and special occasions, and five weeks every summer (petitioner
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Petitioner notes that respondent is moving for a change in primary residential parent, five days
before trial without asserting limiting factors and without having had a guardian ad litem
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That respondent provide full disclosure regarding his girlfriends domestic violence
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burglary conviction, including a copy of the police report; that his girlfriend attend an
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anger management course, and that respondent keep petitioner informed on how he
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and Melissa are dealing with the truancy issues and other issues of her teenage boy,
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(ii)
That respondent disclose the make, model, and serial number of all guns in his
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possession, and proof that he is storing them at his mothers home. That
21
respondent enroll Hunter in a gun safety course, since respondent had bought Hunter
22
a gun.
S ' t-'Z B lk
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55 8250
(iii)
That a location for visitation exchanges be specified in the parenting plan, and
that the location be a restaurant in an accessible location, so that the boys dont have
to wait outside.
(iv)
That visitation on holidays start at 6:30 a.m., rather than the present 8:00 a.m., since
petitioner, as a nurse, often works holidays and has to be at work at 7:00 a.m.
(Respondent would be given the option to start visitation at 8:00 a.m. on holidays
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(v)
That 4th of July visitation be extended until midnight, so that the boys can
enjoy the fireworks without interruption.
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Property division:
Personal propertyrespondent took most of the expensive big ticket items, and
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petitioner is aware that some of these items were sold. Proceeds from sold items
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2009 tax returnrespondent gave petitioner only $ 790.45 from the $ 12,281 in
tax refund, and petitioner wants the proceeds or a judgment for $ 5350.
This demand may be modified if respondent can satisfactorily demonstrate
Petitioners Trial Memorandum
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RetirementThe parties had both cashed out their retirement once, and spent
the funds for community needs. Petitioner now has only $ 2,000 in retirement
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Debt division: There are some debt division issues still not resolved.
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out of petitioners tax refund this year for mistakes in the communitys
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2008 tax return. Respondent owes the petitioner half of the money for
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Sallie Mae student loan repayment: $ 5, 159 now owing. This loan paid
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When respondent left the house, he left behind bills for cell phone (Verizon), cable, water,
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garbage, home phone, and auto insurance that petitioner paid. Respondent should
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145?
10-3-00961-1
368554/4
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Case No 10-3-00961-1
WITNESS RECORD
vs
JASON WILLIAM SHIPMAN,
____________ Respondent(s)
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NAME
JENNIFER K. SHIPMAN
Petitioner
JASON W. SHIPMAN
Respondent
RELATIONSHIP TO CASE
DATE
PETITIONER WITNESS
07/27/11
RESPONDENT WITNESS
07/27/11
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WITNESS RECORD -1 of 1
10-3-00961-1
7/27/2011
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IN THE SUPERIOR COURT OF WASHINGTON, COUNTY OF PIERCE
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Cause No 10-3-00961-1
EXHIBIT RECORD
vs
JASON WILLIAM SHIPMAN,
Respondent(s)
T-L
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P
Description
No.
D
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Off
V AH
*).&. I)
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'
Obj
Admitted
Agreed
Denied
Illustrative
Published
Redacted
Reserved
Withdrawn
Date
Admitted
07/27/11
Admitted
07/27/11
Recd
by
Clerks
Office
V[/
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EXHIBIT RECORD
10-3'00961-1
-1 of 2
7/27/2011
Cause No 10-3-00961-1
It is hereby stipulated that at such time as the Judgment in the above entitled action shall
become final, or upon Judgment becoming final after Appeal, or upon the filing of a Dismissal, or upon
filing a Satisfaction of Judgment, the County Clerk may return all exhibits offered and received in
evidepdejin the above entitled action to the party introducing said exhibits
Judgment Entered,
Appeal Filed
Remittitur Filed
Dismissal Filed
Satisfaction Filed
RECEIPT FOR EXHIBITS
Petitioner(s)
D a te ____________
Respondent(s) s Exhibit(s)
No
___________________
___________________
D a te____________
Attorney for
Respondent(s)
vs
Page 1 of 2
ROBERT D LLOYD
TIMOTHY M GREENE
SHIPMAN, TYLER
SHIPMAN, HUNTER
Us 1 ^ 2 0 1 3 .
bSt?2f-
vs
JASON WILLIAM SHIPMAN
Page 2 of 2
Judge/Commissioner
RONALD E CULPEPPER
________________________________MINUTES OF PROCEEDING_______________________
Judicial Assistant/Clerk ANGELA EDWARDS
Court Reporter KARLA JOHNSON
Start Date/Time: 07/28/11 11:29 AM
14S69
B/ S 2 3 1 1
23SS4
Cause Number: 1 0 -3 -0 0 9 6 1 -1
Petitioner(s)
vs.
page 1 of 2
ROBERT D. LLOYD
Daniel N Cook
SHIPMAN, TYLER
SHIPMAN. HUNTER
Resolution:
Ixcalcivil.pbl.ctjcivilJoumal_report_cover
vs.
JASON WILLIAM SHIPMAN
Page: 2 of 2
Judge/Commissioner:
RONALD E. CULPEPPER
MINUTES OF PROCEEDING
Court ReportenKARLA JOHNSON
Judicial Assistant/Clerk: ANGELA EDWARDS
Start Date/Time: 08/04/11 9:03 AM
stand. 09:09 AM Further argument re child support. Parenting Plan; FOF/COL; Decree of
Disso signed.
09:14 AM Order of Child Support not entered today. Matter reset to allow Mr. Shipman to
present an alternative. This issue reset to Tuesday, 8/9 at 9am.
End Date/Time: 08/04/11 9:15 AM
Parenting Plan:
Final Order (PP)
Parenting Plan
Final Order (PP)
Age
Tyler Shipman
16
Hunter Shipman
10
1 4 5 6 .9
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2.1
2.2
3.1
School Schedule
Upon enrollment in school, the child(ren) shall reside with the petitioner,
except for the following days and times when the child(ren) will reside with or be with the other
parent:
from 5:00 p.m. Friday to Monday mornings at the beginning of the school day every other week
every Wednesday from 5 p.m. to 8 p.m.
Parenting Plan
Final Order (PP)
2 3 BB 9 3
3.3
The winter vacation shall be split evenly between the parents, with the father having the first
half of the vacation in even-numbered years and the mother having the first half in odd numbered
years.
3.4
Same as 3.3
3.5
Summer Schedule
Upon completion of the school year, the children shall reside with the mother, except for the
following days and times when the children shall reside with or be with the other parent:
Father shall have the first five weeks residential time during the summer break.
3.6
The residential schedule for the child(ren) for the holidays listed below is as follows:
Parenting Plan
Final Order (PP)
With Petitioner
(Specify Year
Odd/Even/Everv)
With Respondent
(Specify Year
Odd/Even/Everv)
odd
even
odd
even
odd
even
odd
odd
odd
even
even
odd
even
odd
even
odd
even
odd
even
even
even
odd
odd
even
For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times):A holiday begins at 8:00 a.m. and ends at 10:00 p.m. unless it is fathers
holiday and mothers workday, on which day the holiday begins at 6:30 a.m. and ends at
10 p.m. The 10 p.m. end to the holiday does not apply to the Fourth of July.
Law Offices of G reene & Lloyd, PLLC
Street: 4115 S. M eridian, Ste. B
M ailing: P.O. Box 731063
Puyallup, W ashington 98373
Ph: (253) 770-0808, Fax (253) 770-0259
146 b
3 ^ 5 /2 8 1 1
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Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
3.8
The residential schedule for the children) for the following special occasions (for example,
birthdays) is as follows:
With Petitioner
With Respondent
(Specify Year
(Specify Year
Odd/Even/Every)
Odd/Even/Everv)
every
Mothers Day____
Fathers Day_____
every_________________
____
Mothers birthday
every.
Fathers birthday
Childrens birthdays
even__________________
odd
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For purposes of this parenting plan, a special occasion shall begin at 8:00 a.m. and end at
10:00 p.m., unless it is fathers special occasion and mothers workday, on which days
the special occasion begins at 6:30 a.m.
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3.9
13
If the residential schedule, Paragraphs 3.1-3.8, result in a conflict where the children are
scheduled to be with both parents at the same time, the conflict shall be resolved with priority
given as follows, with 1 being the highest priority.
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6.
5.
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3.
2.
1.
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school schedule
winter vacation
.school breaks
summer schedule
holidays
special occasions
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3.10
Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
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Parenting Plan
Final Order (PP)
146S?
3.11
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Transportation Arrangements
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(ren), between parents shall be as follows:
Receiving parent shall provide transportation to the exchange point.
The exchange point is the paternal grandparents home, unless the parties mutually agree
to a different exchange point.
3.12
Designation of Custodian
The children named in this parenting plan are scheduled to reside the majority of the time with
the [ ] petitioner [ ] respondent. This parent is designated the custodian of the child(ren) 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
a. It is the responsibility of the parent scheduled to have the children to arrange suitable
alternative care if necessary and to pay for the needed care.
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 apprised of his or her current residence address and residence
telephone number.
d. Both parents shall have unlimited access to the childrens school, daycare, and medical
records. Neither parent may revoke this provision by telling the providers to disobey this
court order.
e. Telephone Access
The children shall have reasonable telephone privileges with the parent with whom the
children are not then residing, without interference of the residential parent.
Parenting Plan
Final Order (PP)
I4fcfe9
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3.14
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.
Parenting Plan
Final Order (PP)
14669
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238182
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.
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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.
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.
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4.1
Each parent shall make decisions regarding the day-to-day care and control of each child while
the child is residing with that parent. Regardless of the allocation of decision making in this
parenting plan, either parent may make emergency decisions affecting the health or safety of the
children.
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Day-to-Day Decisions
4.2
Major Decisions
joint
joint
joint
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Parenting Plan
Final Order (PP)
4.3
V. Dispute Resolution
The purpose of this dispute resolution process is to resolve disagreements about carrying out
this parenting plan. This dispute resolution process may, and under some local court rules or
the provisions of this plan must be used before filing a petition to modify the plan or a motion for
contempt for failing to follow the plan.
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,
The cost of this process shall be allocated between the parties as follows:
based on each partys proportional share of income from line 6 of the child support
worksheets.
The dispute resolution process shall be commenced by notifying the other party by
certified mail/retum receipt.
In the dispute resolution process:
(a)
(b)
(c)
(d)
(e)
3.4SS 9
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'2339184
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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 under the plan are
not affected.
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Dated: _
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RONALD E. CULPEPPER
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or Lawyer/WSBA No.
Print Name
DEPT. 17
IN OPF*, r *'"R T
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Parenting Plan
Final Order (PP)
2/4.SS5?
10-3-00961-1
36896565
FNFCL
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06-05-11
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No. 10-3-00961-1
Petitioner,
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and
JASON WILLIAM SHIPMAN
Respondent.
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Petitioner.
Petitioners Lawyer.
Respondent pro se.
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Residency of Petitioner
The Petitioner
is a resident of the state of Washington.
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Findings of Fact and Conclusions of Law
(Marriage) (FNFCL)
2.2
The respondent
appeared, responded or joined in the petition.
2.3
2.4
The parties were married on April 24, 1994 at North Bend, Washington.
2.5
Status of Marriage
The marriage is irretrievably broken and at least 90 days have elapsed since
the date the petition was filed and since the date the summons was served or
the respondent joined.
2.7
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2.8
Community Property
2
The parties have the following real or personal community property:
3
The community home that had been located at 9306 116th St. E.
had been foreclosed upon in April, 2011, and is no longer property
of the marital community.
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2.9
Separate Property
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Findings of Fact and Conclusions o f Law
(Marriage) (FNFCL)
1
2.10
Community Liabilities
2
The parties have incurred com m unity liabilities and the parties
have divided these liabilities by agreement.:
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4
5
6
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O ther: The husband owes the wife equitable reimbursement for the following:
a) $ 1,000 for the purchase of the ten foot trailer that the husband has in his
possession.
b) $ 500 for daycare expenses for Hunter.
c) $ 143.75 reimbursement for Tylers lost eyeglasses.
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2.11
The husband has incurred separate liabilities, for which he will be solely
responsible.
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The wife has incurred the following separate liabilities, for which she will
be solely responsible.
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Separate Liabilities
2.12
14
Maintenance
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2.13
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2.14
Protection Order
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Does not apply.
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2.15
20
There is no award of fees or costs.
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2.16
22
Pregnancy
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Findings or Fact and Conclusions of Law
(Marriage) (FNFCL)
2.17
Dependent Children
The children listed below are dependent upon either or both spouses.
Name of
Child
2.18
Mothers
Name
Age
Fathers
Name
Tyler
16
Hunter
10
Jennifer Shipman
Jason Shipman
This court has jurisdiction over the children for the reasons set forth below.
This state is the home state of the children because:
The children lived in Washington with a parent or a person
acting as a parent for at least six consecutive months
immediately preceding the commencement of this proceeding.
2.19
Parenting Plan
The parenting plan signed by the court on this date is approved and
incorporated as part of these findings.
Other: The basic structure of the parenting plan was ordered by
a court commissioners temporary order after hearing on August 24, 2010,
and this plan has been slightly modified on specific issues raised by the
parties in the July 27, 2011 trial on this matter.
s*
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2.20
Child Support
2
There are children in need of support and child support should be set pursuan;
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.
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2.21
Other
The wife is the sole recipient of the IRS tax exemption for the children.
This condition is in consideration of the wife being solely responsible for
health insurance, uncovered health expenses, and extracurricular expenses
for the children as discussed in the Order of Child Support and the Final
Parenting Plan. The wife is still entitled to credits for these expenses in
Calculating her child support on the Child Support Worksheets.
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III.
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The court makes the following conclusions of law from the foregoing findings of fact:
3.1
3.2
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Jurisdiction
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Conclusions of Law
Granting a Decree
Pregnancy
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Findings of Fact and Conclusions of Law
(Marriage) (FNFCL)
14669
3.4
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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 approve
provision for 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
5
6
7
S /5 /'2 0 i i
3.5
Protection Order
9
Does not apply.
10
3.7
11
Does not apply.
12
13
14
3.8
Other
Dated;
15
Approved for entry:
Notice'ljf p/esentation waived:
16
17
18
19
20
/P S " & S ?
/
Dat
Date
S" 3^7/
Print or Typ e Name
21
22
23
Findings of Fact and Conclusions o f Law
(Marriage) (FNFCL)
10-3-00961-1
3689B569
DCD
08-05-11
3
4
5
6
No. 10-3-00961-1
Petitioner,
10
11
and
JASON WILLIAM SHIPMAN
Respondent.
12
13
I. Judgment/Order Summaries
1.1 Restraining Order Summary:
20
21
22
End o f Summaries
23
Decree of Dissolution
(DCD)
II. Basis
Findings of Fact and Conclusions of Law have been entered in this case.
III. Decree
It Is Decreed that;
3.1
The husband is awarded as his separate property the following property (list real estate*
furniture, vehicles, pensions, insurance, bank accounts, etc.):
All property currently in his possession, with the exception of specific items listed under
property to be awarded the wife.
Pepsi machine
Pool table
Other: The community home that had been located at 9306 116thSt. E. had been foreclosed
upon in April, 2011 and is no longer the property of the marital community.
If the wife does not have possession of the Pepsi machine or the pool table, she is to
disclose the whereabouts of these items and she is ordered to return these items,
whether or not they are in the possession of third parties. However, if the wife
does not have possession of the Pepsi machine or pool table and does not know
of their whereabouts, she is to provide an explanation.
3.3
The wife is awarded as her separate property the following property (list real estate,
furniture, vehicles, pensions, insurance, bank accounts, etc.):
All property currently in her possession, with the exception of specific items listed under
property to be awarded the husband
Wedding ring of wife
Heirloom pocket watch once owned by wifes grandfather
Originals of photographs in which wife or her family (excluding the children) are in picture and
husband not in picture and copies of all other photographs, except photographs of husband or his
family not including children (husband possesses photographs at time decree entered).
Decree of Dissolution
(PCD)
1
Other; The husband represents that he does not have the wedding ring and the heirloom pocket watch.
He is to return these items to the wife if he finds them.
2
3
4
3.4
All community liabilities that he has been paying since the separation of the parties.
7
Other; He is obligated to reimburse the wife for the following items;
8
10
12
13
3.5
14
15
AH community liabilities that he has been paying since the separation of the parties.
16
Unless otherwise provided herein, the wife shall pay all liabilities incurred by her since the date of
separation.
17
3.6
18
19
20
[]
Each party shall hold the other party harmless from any collection action relating to
separate or community liabilities set forth above, including reasonable attorney's fees and
costs incurred in defending against any attempts to collect an obligation of the other party.
Other:
21
22
23
Decree of Dissolution
14-669
3.7
2 6 9 ^ 1 1; ..r
Maintenance
3.8
3.9
Protection Order
Parenting Plan
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.
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.
3.13
Name Changes
Other: The wife is the sole recipient of the IRS tax exemption for the children. This
condition is in consideration of the wife being solely responsible for health insurance,
uncovered health expenses and extracurricular expenses for the children as discussed
in the Order of Child Support and the Final Parenting Plan. The wife is still entitled
to credits for these expenses in calculating her child support on the Child Support
Worksheets.
Decree of Dissolution
(DCD)
1
2
3
4
5
6
Dated:
uoner
7
8
9
/7 V ^
loner or Lawyer/WSBA No.
10
II
12
'RONALD E. CULPEPPER
n
Print or Type Name
G rd M , A 3 - / 4
~ ~ S <X'> <en')
Date
ja
Date
13
14
15
16
17
18
19
20
21
22
23
Decree of Dissolution
(DCD)
P / 1 1 / ? Q i 4
M "! o r
vs.
Page 1 of 2
ROBERT D LLOYD
Daniel N Cook
SHIPMAN, TYLER
SHIPMAN, HUNTER
Ixcalcivtlpbl d_civiljoumal_report_cover
vs
Page 2 of 2
Judge/Commtssioner
RONALD E CULPEPPER
________________________________MINUTES OF PROCEEDING_______________________
Judicial Assistant/Clerk ANGELA EDWARDS
Court Reporter KARLA JOHNSON
Start Date/Time: 08/09/11 9:16 AM
Respondent
support until Mr. Shipman returns to work. Mr. Shipman asserts he's overpaid approx $638.
No action on the overpayment today.
KEVIN STOCK
10-3-00961-1
38328505
04-12-1
LTDEX
FILED
rirc :
IN COUNTY CLERK'S OrFICE
APR 1 2 2012
p.m.
Sincerely,
Kevin Stock, Clerk
Pierce County Superior Court
Michael Kapfhammer
Deputy Clerk, Evidence Section
798-7717
**************************************************************************************
Uv? 1 8 3 7 5
4^ i8/*2812
538288
38367143
04-18-12
NTDE
PIERCE COUNTY,WASHINGTON
ffIVtN STOCK. Countyffwk
JE N N IF E R K A Y SH IPM AN ,
Plaintiff,
vs.
JA S O N WILLIAM SHIPMAN,
Defendant.
)
>
)
)
)
>
)
)
>
>
>
i
Receipt of Exhibits
(EXRECT)
If- I t .
re s p o n s e w as re c e iv e d fro m D e fe n d a n t/R e s p o n d e n t
KEVIN STOCK
Please come in and withdraw the exhibits or authorize the County Clerk to
destroy them. Return this letter with an "X" in the appropriate square
signifying your intentions.
E x h ib its W iii B e D e s t r o y e d On M A Y 18, 2 0 1 2
If Y o u D o N o t R e s p o n d .
Sincerely,
Kevin Stock, Clerk
Pierce County Superior Court
Bf
Michael Kapfhammer
Deputy Clerk, Evidence Section
798-7717
*************,#c*****,**'*,**'*****"*,*************'*******,*,****'*,**********,********************
'y.^^ec
N:\WORDDOCS\linx forms\vaul1\destroy exhibits civil 2 attorney^Otfc
12/2002
.. recycledjiH:n3r
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
May 10 2012 2:27 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
NO. 10-3-00961-1
NOTICE OF INTENT TO WITHDRAW
PAGE 1 OF 2
ntiwdsup-0002.pdf
10-3-00961-1
The last known name and address of the parties I have been representing are listed below:
JENNIFER KAY SHIPMAN
2323 7TH STREET SE #B203
PUYALLUP, WA 98374
CERTIFICATE OF SERVICE
I certify under penalty of perjury under the laws of the State of Washington that the foregoing is
true and correct: That on May 10, 2012, I mailed a copy of this document to the attorney(s) of
record and/or parties at their respective addresses of record.
PAGE 2 OF 2
ntiwdsup-0002.pdf
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
No. 10-3-00961-1
COUNTY CLERK
Petitioner(s)
Vs.
Track Assignment:
Assignment Department:
Docket Code:
Modification of Custody
ORLA
ORSCS
7/5/2012
Notice of Adequate Cause & Note for Comm Cal filed w/Petition or no later than
Confirmation of Service
7/19/2012
8/30/2012
8/30/2012
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 RONALD E. CULPEPPER
8/30/2012
11/1/2012
8/30/2012
11/22/2012
12/6/2012
12/20/2012
Week of 1/31/2013
2/7/2013
Discovery Cutoff
Exchange of Witness and Exhibit Lists and Documentary Exhibits
2/21/2013
3/7/2013 9:00
Trial
U n le s s o t h e r w i s e i n s t r u c t e d , A L L A t t o r n e y s / P a r t i e s s h a ll r e p o r t to t h e t r i a l c o u r t a t 9 :0 0 A M o n
th e d a te o f tria l.
NOTICE TO PLAINTIFF/PETITIONER
If the case has been filed, the plaintiff shall serve a copy of the Case Schedule on the defendant(s) with the summons and complaint/
petition: Provided that in those cases where service is by publication the plaintiff shall serve the Case Schedule within five (5) court days
of service of the defendant's first response/appearance. If the case has not been filed, but an initial pleading is served, the Case Schedule
shall be served within five (5) court days of filing. See PCLR 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.
Dated: June 28, 2012
rJUN 28 2012
p .m
R.-pt. Fate
06/2ET9I2
Aect. Date
06/28/2012
No. 10-3-00961-1
JENNIFER KAY LUND
(fka Jennifer Shipman)
Petitioner,
and
JASON WILLIAM SHIPMAN
Summons(Modification/
Adjustment of Custody
Decree/Parenting Plan/
Residential Schedule)
(SM)
Respondent.
To:
JASON W. SHIPMAN
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 o f your written response on the
person signing this summons and by filing the original with the clerk o f 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 of
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 of appearance on the undersigned person, you are entitled to notice before
an order o f default or a decree may be entered.
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.
Temporary residential placement or custody is not being sought
u&e
08:53 AH
$56.00
6^29/*
12 17 9 2 2 6
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.
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:
http://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
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.
One method of serving a copy of 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 4.1 o f the state of Washington.
t-J s /w J /M
k.
Jeijjwfer K. Lund
Petitioner
Jennifer K. Lund
2323 - 7th Street SE, Apt. B-203
Puyallup, WA 98374
10-3-00961-1
38773269
06-28-12
SPTMDC
INCOUNTYFd
an.
i c s OFFICE
8 8 2012 m
No. 10-3-00961-1
Petitioner,
and
JASON WILLIAM SHIPMAN
Respondent.
1.1
JENNIFER K. LUND,
1.2
JASON W. SHIPMAN
Last known residence
1.3
Dependent Children
Tyler Shipman, age 17
Hunter Shipman, age 11
Jennifer K. Lund
2323 - 7th Street SE, Apt B-203
Puyallup, WA 98374
(253) 256-4255
II. Basis
2.1
2.2
Adequate Cause
There is adequate cause for hearing the petition for modification.
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.
2.4
2.5
Jennifer K. Lund
2323 - 7thStreet SE, Apt B-203
Puyallup, WA 98374
(253)256-4255
2.6
Parents Name
Jason W Shipman, Father
Jason W. Shipman, Father
Parents Name
Jennifer K. Lund, M other
Jennifer K. Lund, M other
During the last five years, the children have lived in no place other than the state o f W ashington and
with no person other than the requesting party or the other party
Claims to custody or visitation'
The requesting party does not know o f any person other than the other party who has
physical custody of, or claims to have custody or visitation rights to, the children
Involvement in any other proceeding concerning the children:
The requesting party has not been involved in any other proceeding regarding the children.
Other legal proceedings concerning the children
The requesting party does not know of, any other legal proceedings concerning the
children.
2.7
2.8
2.9
2.10
Jennifer K. Lund
2323 - 7thStreet SE, Apt. B-203
Puyallup, WA 98374
(253) 256-4255
-b-'2 9 / e i 2
1.7*7.2.
not change the residence the children are scheduled to reside in the majority o f the time
and'
is based on a change o f residence o f the parent with whom the child does not reside
a majority o f the time or an involuntary change in work schedule by a party which
makes the residential schedule in the parenting plan impractical to follow.
2.11
2.12
Dispute resolution
Decision making.
Transportation arrangements.
Other:
There should be a specific provision restricting the 11-year-old child from
traveling out o f state alone.
2.13
The father has relocated and/or is in the process o f relocating to Yelm He has visitation through
M onday a.m. when the children go to school. He must awake the children at 4:00 a.m. to make the
extra l hour to l X
A hours extra travel time to drop the children o ff at school.
This makes the plan impractical to follow.
Also, the father plans on sending our 11 -year-old son to Florida, alone, via airplane to visit the
paternal grandfather who has a history o f domestic violence, alcoholism and other issues
It is unreasonable for a parent to not travel and/or supervise this time.
Joint decision making should be modified because o f the new distance o f the parents and the father
has failed to perform the parenting function o f exercising appropriate judgm ent with the children
(given this latest traveling scenario).
Jennifer K. Lund
2323 - 7lhStreet SE, Apt B-203
Puyallup, WA 98374
(253)256-4255
6^29^2312
2.14
17922 fese
Protection Order
Does not apply.
2.15
B. Factual basis:
O ther factual basis: my own personal knowledge
2.15
B Factual basis
O ther factual basis: my own personal knowledge.
I declare under penalty o f perjury under the laws o f the state o f W ashington that the foregoing is true and
correct.
Signed at Puyallup, W ashington on June 27, 2012.
Jennifer K. Lund
2323 - 7thStreet SE. Apt B-203
Puyallup, WA 98374
(253) 256-4255
6 /2 9 A 2 B I2 17922 &SS
*
9
[]
Joinder
[]
[]
I dem and notice o f all further proceedings in this m atter. Further notice should be sent to
the following address (you m ay list an address that is not your residential address where
you agree to accept legal docum ents).
Any time this address changes while this action is pending, you m ust notify the opposing parties
in w riting and file an updated Confidential Inform ation Form (W PF DRPSCU 09 0200) with the
court clerk.
Date
Signature
Print Name
Jennifer K. Lund
2323 - 7lhStreetSE, Apt B-203
Puyallup. WA 98374
(253) 256-4255
317'^- 2 6 B B 1
e i2
IN c o u n ty ^ H R ics o ffic e
am
JUN 2 8 2012
pm .
State of W A
O th e r__________________ . (C S W P )
Father
$ 3400
$0
$ 0
$0
$0
$0
$ 3400
Mother
$ 3000
$0
$0
$0
$0
$0
$ 3000
$ 0
$
$
$
$
$
o
o
o
0
0
$
$
$
$
$
0
0
0
0
3000
$ o
$ 0
$
$
$
$
$
$
$
o
0
0
0
0
0
3400
$ 6400
$ 1584
0.531
0.469
6 / 2 9 / 2 9 J. 2
1 7 S'
$ 0
$0
$ 0
$ 0
$ 0
$0
$ 841
$ 743
$ 743
$ 841
$ 1164
Part III: Health Care, Day Care, and Special Child Rearing Expenses (See Instructions, Page 8)
10. Health Care Expenses
Father
Mother
$ 293
a. Monthly Health Insurance Premiums Paid for Child(ren)
$0
b. Uninsured Monthly Health Care Expenses Paid for Child(ren)
$ 0
$ 0
c. Total Monthly Health Care Expenses (line 10a plus line 10b)
$ 293
$ 0
d. Combined Monthly Health Care Expenses
$ 293
(add father's and mother's totals from line 10c)
11. Day Care and Special Expenses
$0
$ 0
a. Day Care Expenses
b. Education Expenses
$ 0
$0
c. Long Distance Transportation Expenses
$ 0
$0
$
0
d. Other Special Expenses (describe)
$0
$0
$ 0
$ 0
$ 0
$ 0
$0
e. Total Day Care and Special Expenses
$ 0
$0
(add lines 11a through 11 d)
12. Combined Monthly Total Day Care and Special Expenses (add
$ 0
father's and mother's day care and special expenses from line 11e)
13. Total Health Care, Day Care, and Special Expenses (line 10d plus .
$ 293
line 12)
14. Each Parent's Obligation for Health Care, Day Care, and Special
$ 156
$ 137
Expenses (multiply each number on line 6 by line 13)
Part IV: Gross Child Support Obligation
15. Gross Child Support Obligation (line 9 plus line 14)
$ 997
$ 880
Part V: Child Support Credits (See Instructions, Page 9)
16. Child Support Credits
$ 0
a. Monthly Health Care Expenses Credit
$ 293
b. Day Care and Special Expenses Credit
$ 0
$0
WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2011 Page 2 of 5
8 tl i 7 8
$0
$ 0
$ 0
$ 0
$ 0
$0
$0
$0
$0
$0
$0
fe
Ct /'
f& eise
$ 0
$ 0
$ 0
$ 0
$0
$0
$0
$0
$0
$ 0
$0
Paid | | Yes E
No $ 0
$ 0
$ 0
Mother's
Household
$ 0
$ o
$ 0
Judicial/Reviewing Officer
Date
This worksheet has been certified by the State of Washington Administrative Office of the Courts.
Photocopying of the worksheet is permitted.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 07/2011 Page 5 of 5
fc-
10-3-00961-1
38773301
PPP
06-28-12
S^-<.26'12 IV H2. 2 7 B iS 2
O T282012
pm.
No. 10-3-00961-1
JENNIFER KAY LUND
(fka Jennifer Shipman)
Petitioner,
and
2.1
Jennifer K. Lund
2323 - 7thStreet SE, Apt B-203
Puyallup, WA 98374
(253) 256-4255
3.1
3.2
School Schedule
A fter enrollm ent in school, the child shall reside w ith the m other except for the follow ing times
the children reside with the father:
The children shall reside with the father from Friday at 5:00 p.m through Sunday at 5:00 p m.
every other weekend.
The father also shall have residential time from 5:00 p.m. through 8 00 p.m. every W ednesday.
3.3
Jennifer K. Lund
2323 - 7thStreet SE, Apt B-203
Puyallup, WA 98374
(253) 256-4255
3.5
7"
?S @ iS 4
Summer Schedule
Upon the com pletion o f the school year, the children shall reside with the mother, except for the
follow ing days and times when the children shall reside with the other parent:
The father shall have the first five weeks o f residential tim e during the sum m er break
3.6
3.7
see 3.3
Even
Odd
Even
Odd
Even
Odd
Odd
Odd
Even
Even
Odd
With Father
(Specify Y ear
O dd/Even/Everv)
see 3 3
Odd
Even
Odd
Even
Odd
Even
Even
Even
Odd
Odd
Even
A holiday shall begin at 8:00 a m. and ends at 10:00 p.m., unless it is the fathers holiday and
m others workday, on which day the holiday begins at 6:30 a.m , and ends at 10.00 p.m. the
10:00 p.m. end to the holiday does not apply to the Fourth o f July, which ends at m idnight
H olidays which fall on Friday or Monday shall include Saturday and Sunday.
3.8
Jennifer K. Lund
2323 - 7thStreet SE. Apt. B-203
Puyallup. WA 98374
(253)256-4255
S . '2 9 - ' 2 B 1 2
37922
7 8 B IB S
Even
Every
Every
Odd
Every
Special occasions shall begin at 8:00 a.m. and end at 10 00 p.m., unless it is father's special
occasion and m others workday, on which days the special occasion beings at 6:30 a.m.
3.9
3.10
Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2 2.
3.11
Transportation Arrangements
Transportation costs are included in the children Support W orksheets and/or the O rder for
children Support and should not be included here.
Transportation arrangements for the children betw een parents shall be as follows:
The delivering parent shall provide transportation to the paternal grandparents home, unless the
parties agree to a different exchange point.
3.12
Designation of Custodian
The children nam ed in this parenting plan are scheduled to reside a m ajority o f time w ith the
mother. This parent is designated the custodian o f the child(ren) solely for purposes o f all other
state and federal statutes which require a designation or determ ination o f custody This
designation shall not affect either parents rights and responsibilities under this parenting plan.
3.13
Other
a.
It is the responsibility o f the parent scheduled to have the children to arrange suitable
alternative care if necessary andto pay for the needed care
b.
Each parent shall notify the other at least 48 hours in advance if he o r she is unable to
com ply with the regular schedule.
Jennifer K. Lund
2323 - 7thStreet SE, Apt B-203
Puyallup. WA 98374
(253)256-4255
-y2 9 Z 2 B 12
i ? 9 2 '2
Each parent shall keep the other apprised of his or her current residence address and
residence telephone number.
d.
Bothe parents shall have unlimited access to the childrens school, daycare, and medical
records. Neither parent may revoke this provision by telling the providers to disobey
this court order
Telephone Access. The children shall have reasonable telephone privileges with the
parent with whom the children are not then residing, without interference of the
residential parent.
f.
g.
Gun Safety
1 Both parents shall keep household guns locked up in a location not
accessible to the children.
2. The father shall enroll Hunter in a gun safety course within 14 days and
provide proof to the mother of Hunters successful completion of the
course within 3 days of completion. If he does not do so a finding of
contempt of this provision will result in a monetary sanction of $500.
h.
Travel alone
Neither parent shall have Hunter travel by airplane, train, bus, boat or vehicle without
adult accompaniment until Hunter is 16 years old.
3.14
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 children reside 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
Parenting Plan (PPP, PPT, PP)
WPF DR 01.0400 Mandatory (6/2008)
RCW 26.26.375, 26.09.016, .181; .187; .194
Page 5 of 8
Jennifer K . Lund
2323 - 7,hStreet SE, Apt B-203
Puyallup, WA 98374
(253)256-4255
6 2 2 9 ^ 2 ft 1 2
1732-2
7 &b i h ?
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 children 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 children 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 children 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 children 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 children before the hearing unless there is a
clear, immediate and unreasonable risk to the health or safety of a person or a child.
IV. Decision Making
4.1
Each parent shall make decisions regarding the day-to-day care and control of each children
while the children are residing with that parent. Regardless of the allocation of decision making
in this parenting plan, either parent may make emergency decisions affecting the health or safety
of the children.
4.2
Major Decisions
Jennifer K. Lund
2323 - 7lhStreet SE. Apt. B-203
Puyallup, WA 98374
(253)256-4255
& -/2922B 1
Education decisions
Non-emergency health care
Sports/cIub/Extra-curricular activities
Religious upbringing
4.3
-V
?B 8lSB
Mother
Mother
Mother
Mother
Sole decision making shall be ordered to the mother for the following reasons*
One parent is opposed to mutual decision making, and such opposition is
reasonably based on the following criteria:
(a)
(b)
(c)
(d)
V. Dispute Resolution
The purpose of this dispute resolution process is to resolve disagreements about carrying out
this parenting plan. This dispute resolution process may, and under some local court rules or
the provisions of this plan must, be used before filing a petition to modify the plan or a motion
for contempt for failing to follow the plan.
Mediation with Pierce County Center for Dispute Resolution. Costs shall be shared in the same
proportion as line 6 of the Child Support Worksheets.
VI. Other Provisions
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.
Signed at Puyallup, Washington on June 27, 2012.
Jennifer K. Lund
2323 - 7thStreet SE, Apt B-203
Puyallup, WA 98374
(253) 256-4255
Warning: V iolation o f residential provisions o f this order with actual know ledge o f its term s is
punishable by contem pt o f court and may be a crim inal offense under RCW 9A 40.060(2) or
RCW 9 A.40.070(2) Violation o f this order m ay subject a violator to arrest.
When mutual decision m aking 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 o f this plan, the other parents obligations under the plan are
not affected.
D a te d :______________________________________
_________________________
Judge/Commissioner
Presented by:
Jennifer K. Lund
Petitioner
Jason W. Shipman
R espondent
Jennifer K. Lund
2323 - 7thStreet SE, Apt B-203
Puyallup, WA 98374
(253) 256-4255
h'2^/?A % rz 1 7 ^ 2
10-3-00961-1
38775246
CME
06-29-12
Cause
Petitioner(s)
Number 10-3-00961-1
vs
Page 1 of 2
Daniel N Cook
SHIPMAN, TYLER
SHIPMAN, HUNTER
fj
2 9
? .B 1 2
i?9 2 r?
vs
JASON WILLIAM SHIPMAN
Page 2 of 2
Judge/Commissioner
WENDY ELLEN ZICHT
________________________________MINUTES OF PROCEEDING___________
Judicial Assistant/Clerk Chelsea Glanz
Court Reporter Smart Court
Start Date/Time: 06/28/12 10:43 AM
E^ 2 s ^ 2 n i 2
TPROTSC
06-29-12
AM JUN 2 8 2012
PM
-DEPUTY
No. 10-3-00961-1
Ex Parte Restraining
Order/Order To Show Cause
(Parentage)
(TPROTSC/ORTSC)
Petitioner,
and
%4.1
Respondent.
Restraining Order Summary:
Restraining Order Summary is set forth below:
Name of person(s) restrained: JASON W. SHIPMAN
Name of person(s) protected: HUNTER SHIPMAN, age 11
It is ordered that JASON W, SHIPMAN appear and show cause, if any, why the restraints below should
not be continued in full force and effect pending final determination of this action and why the other
relief, if any, requested in the motion should not be granted. A hearing has been set for the following
date, time and place:
Date: July *h I____ ,2012
Place. Pierce County Superior Court
401 - Fourth Ave. N.
Kent, WA 98032
Time: 9:00 AM
Room/Department: M> f t o f a l OK (U v tft m
6 / 2 9 / 28 i 2
i 7-928
If you disagree with any part of the motion, you must respond to the motion in writing before the
hearing and by the deadline for your county. At the hearing, the court will consider W ritte n sworn
affidavits or declarations. Oral testimony may N o t be allowed. To respond you must: (1) file your
documents with the court; (2) provide a copy of those documents to the judge or commissioners
staff; (3) serve the other partys attorney with copies of your documents (or have the other party
served if that party does not have an attorney); and (4) complete your filing and service of documents
within the time period required by the local court rules in effect in your county. If you need more
information, you are advised to consult an attorney or a courthouse facilitator.
F a ilu r e to a p p e a r m a y r e s u lt in a T e m p o r a r y O r d e r b e in g e n te r e d b y th e c o u r t w h ic h
g r a n ts th e r e lie f r e q u e s t e d in th e m o tio n w ith o u t fu r th e r n o tic e .
II. Basis
A motion for a temporary restraining order without written or oral notice to Carmen S. Jackson or that
party's lawyer has been made to this court.
III. Findings
The court adopts paragraphs 2.1, 2.2, and 2.4 of the Motion/Declaration for an Ex Parte Restraining
Order and for an Order to Show Cause (Form WPF PS 04.0150) as its findings, except as follows:
[]
Further, the court finds that the nonrequesting party is absent and a) is on active duty as a National
Guard member or Reservist residing in Washington, or b) is a dependent of a National Guard
member or Reservist residing in Washington on active duty. Despite the service members or
dependents absence, failure to enter the temporary orders below would result in manifest injustice
to the other interested parties.
IV. Order
I t is O r d e r e d :
4.1
Restraining Order
V io la tio n o f a R e s tr a in in g O r d e r in P a r a g r a p h 4 .1 w ith a c t u a l n o tic e o f its te rm s is
a c r im in a l o ffe n s e u n d e r C h a p t e r 2 6 .5 0 R C W a n d w ill s u b je c t th e v io la to r to a rre s t.
R C W 2 6 .2 6 .5 9 0 .
[]
Jason W. Shipman is restrained from taking 11-year-old Hunter Shipman, or arranging for Hunter
Shipman, to go outside of the State W^hingFri |i i ifi illj tfimli i in nnttn h"
rn an
ffifpfiSnpwithout adult supervision.
The clerk of the court shall forward a copy of this order, on or before
the next judicial day, to Pierce County Sheriff which shall enter this order into any
computer-based criminal intelligence system available in this state used by law
______enforcement agencies to list outstanding warrants. (A law enforcement information
[ ]
C le r k s A c t io n .
6 7 2 9 -'2 8 i 2
1 7 9 2 8
i < * V 8 8# s 3
sheet must be completed by the party or the partys attorney and provided with this
order before this order will be entered into the law enforcement computer system.)
Service
The requesting 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.
F u ll F a ith a n d C re d it
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.
4.2
BOTH PARTIES are restrained and enjoined from removing any of the children from the state of
Washington
4.3
4.5
Expiration Date
Other
nnp chaii
thp rS ^ '
out a Valid d rive n
license, insurance jc v . appropriate child safely
gnnannr nr
o r I ij t_________
Dated June
Fetitioner/l|6sponde^Plainiiff/Defenaant
may seek-review of this order in the
Ex Parte Department, Room 105, prior to
the scheduled hearing, after giving at
least 24 hours notice to the opposing
DQrty or his/her attorney ANDupon
Presented by.
Q m a iI u
Jennifer K&und
Petitioner
FILED
IN COUNTYCLERK'S OFFICE
k .
5 w u l
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Date
AM
JUN 28 2012
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E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
June 29 2012
1
KEVIN ST
COUNTY C
NO: 10-3-0
3
4
5
6
7
8
9
10
11
In th e M a rria g e of:
J e n n ife r K a y S h ip m a n
P e titio n e r,
12
v.
13
Ja s o n W illia m S h ip m a n
14
15
R e sp o n d e n t.
)
)
)
)
C A S E N O .: 10 -3 -0 0 9 6 1 -1
)
)
N O T IC E O F A T T O R N E Y S
IN T E N T T O W IT H D R A W
)
)
)
)
16
17
18
T O : C le rk o f th e co u rt
A N D T O : Ja so n S h ip m a n , P ro Se
19
20
P L E A S E T A K E N O T IC E th a t T im o th y M . G re e n e in te n d s to w ith d ra w as a tto rn e y fo r
21
22
23
24
25
26
NOTICE OF INTENT
TO WITHDRAW
1 of 2
1
2
T h e la s t k n o w n ad d re ss o f th e p e titio n e r to w h ic h fu tu re p le a d in g s in th is m a tte r sh o u ld
b e d ire c te d is:
3
4
5
N am e
J e n n ife r K a y S h ip m a n
2 3 2 3 7th S tre e t S E # B 203
P u y a llu p W A 9 8 3 7 4
6
7
D A T E D th is
2 9 th
d ay o f J u n e , 2012.
9
10
BY:
11
12
13
14
15
16
17
18
19
20
21
22
23
/S/
BETTYANN WALTER *2
Bettyann Walter , LEGAL ASSISTANT
24
25
26
NOTICE OF INTENT
TO WITHDRAW
2 of 2
FILED
' B B S S *
j^ o iW S 1 0 -3 -0 0 9 6 1 -1
38797589
CME
07-03-12
DEWY
Petitioner(s)
vs.
Page 1 of 2
Daniel N Cook
SHIPMAN. TYLER
SHIPMAN, HUNTER
vs.
JASON WILLIAM SHIPMAN
Page 2 of 2
Judge/Commissioner:
DIANA LYNN KIESEL
E-FILED
IN COUNTY CLERK'S OFF
PIERCE COUNTY, WASHINC
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
5
6
7
10
11
NO. 10-3-00961-1
Petitioner,
12
v.
13
____________________ Respondent.
14
TO:
15
16
17
18
19
20
21
22
For purposes of further process of service, the last known address for
Respondent, which is known to be the true and correct address, is 11721 80th Ave E,
Sumner, WA 98390. Trial is currently scheduled in this case for March 7, 2013.
DATED July 5 , 2 0 1 2 .
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
DECLARATION OF MAILING
2
3
4
I, Amber Johnson, am over the age of 18, and competent to testify in the abovecaptioned case.
5
6
On July 5, 2012, I mailed true and correct copies of the above Notice of Intent to
Withdraw. The documents were mailed via first class mail, via regular mail, postage
pre-paid, to:
8
9
10
11
Jason Shipman
11721 80th Avenue ESumner, WA 98390
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
STATE OF WASHINGTON, THAT THE FOREGOING IS TRUE AND CORRECT.
12
Signed on Wednesday, July 05, 2012, at Lakewood, Washington.
13
14
/ tlllU C I
15
J U I II IO U I I
16
17
18
19
20
21
22
23
24
25
Notice of Intent to Withdraw as Attorney - Page 2 of 2
Shipman, Jennifer v Jason
S : \ C A S E S 1 \ 1 P le a d in g s W o tic e o f I n te n t to W ith d r a w .d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, \
July 31 2012 1
1
KEVIN ST
COUNTY C
2
3
4
5
6
7
8
Petitioner(s),
10
Cause No.
10-3-00961-1
Order Continuing
Adequate Cause Hearing
vs.
11
Respondent(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
23
24
25
/S/ROBYN LINDSAY
ROBYN LINDSAY
Judge/Commissioner
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
July 31 2012 10:04 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
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 Tacom a Ave S - Tacoma, W A 98402
Show Cause
Nature of Hearing:
DATED:
Signed:
NAME:
Phone:
(253) 256-4255
WSBA#:
For:
1 of 1
\c c >
i 9 6 v *? g s 1 /
'
Pro 5e
$ e.
For Respondent
For Petitioner
re :
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s s i ^e y ,
Show Cause
ROBYN LINDSAY
Clerk:
feuXfc'uLft'u
'1
10-3-00961-1
38947676
RTS
b b 1? -w*y l
20 i 2
08-0 M !
No. 10-3-00961-1
Return of Service
(Optional Use)
(RTS)
/ Declare:
1,
lam over the age o f 18 years, and I am not a party to this action.
2,
3,
[x]
[x]
[x]
[x]
other: Ex p o r { ^ resfaximwomar
9
a
ovtW
S&ttvag c a s e S cKiAu3 ^
n o k - f a - Q oranU fistofiers C A M M o r ___________________________
The date, time and place o f service were (if by mail refer to Paragraph 4 below):
Date:
Address:
__________
4.
5.
Servi ce wa s made:
VC
[]
Other:
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at (city)
__________ , 2012.
3 O f t i "? ;
Respondent.
To:
JASON W. SHIPMAN
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 >ou.
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.
Temporary residential placement or custody is not being sought.
Opposing Party I
rfli5 6 9
3Ssi?6
<s-;+
&
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 moditying-/adj Listing 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:
http ://ww w.cou rts.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 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.
One method of serving a copy of 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 4.1 of the state of Washington.
'e h
k .
lu
td
inifer K^Lund
Petitioner
File original of your response with
the clerk o f the court a t
Jennifer K. Lund
2323 - 7thStreet SE, Apt. B-203
Puyallup, WA 98374
1 (j.f.Q
0 'j/
320 i 7 7
Amy Edwards
1022-13* Street SW
Puyallup, WA 98371
(253)228-2263
196 9
6.^1.^2612
300178
We arrived in Yelm at Jason and Kase/s house at around 9:15pm. When we drove by, the white minivan
was not there, so Jennifer drove us to Jack-In-The-Box for some dinner. We returned approximately 30
minutes later. Jason and Kasey's garage was open and the white minivan was parked across the road
next to Jason's work truck. Kasey was standing outside of the garage, smoking. Jennifer and I circled the
block one time to see if Jason would join her. When we came back around, the garage was closed and
Kasey was no longer in sight.
Jennifer parked at the top of the cul-de-sac in hopes of seeing Jason come out. As we were waiting,
Kasey came out to smoke but Jason did not join her. Soon after, a Yelm Police Officer pulled up behind
us. The neighbors had called them because Jennifer and I were parked by mail boxes and they were
concerned. He asked what we were doing there and Jennifer informed him that we were trying to serve
her ex-husband with a Civil Restraining Order and other Documents. Kasey was still outside and the
officer offered to talk with her to find out if Jason was home. Kasey told the officer that he was not
there and she did not know when he would return.
The officer asked us to park somewhere else, so Jennifer and I parked in the Safeway Parking Lot. This
still provided a line of sight to the cul-de-sac where Jason's residence was and continued waiting for his
return. At 11:10pm, Jason drove his Harley Davidson into the Safeway Parking Lot and parked two rows
behind our vehicle. He glared at us while he spoke on his cell phone to someone. A few moments later,
his fiancee Kasey pulled into a stall by him and they began talking. Then Jason drove up and parked by
the passenger window, where 1was sitting. As we were trying to roll the passenger window down, Jason
said, "Well come oni Roll down the window; Roll down the fucking window!" Once I got the window
down, Jason said, "Three Stars!" I handed him the paperwork and said, "Jason Shipman, you've been
served." Jason Shipman was served at 11:19pm.
Jennifer was so upset by Jason's anger and harsh words that it took her a half of an hour to be able to
drive us back to Puyallup.
If there are any questions or concerns, I can be reached at 253-486-6309.
Thank you,
(Name Printed)
(Signature)
I9fef9
S / 1 72 y ! 2
3S*^'8
IN OPEN C O U R T
08-01-1:
V
38947677
*H
10' 5-00961
ML
3I
2012
deputy
No- JO dfflfrl /
In re:
Jw m fa S fo ip W I
Petitioner,
and
^ if At(/
^
Respondent.
_ Hearing se t (ORH)
r- erks Action Required
I. Basis
1.1
12
vi/ty j
31
2 0
Y?~
[Date].
II. Findings
Jurisdiction
This court has jurisdiction over the proceeding and the parties.
2.2
The nonmoving party was served with a copy of the petition for modification/adjustment of
custody decree/parenting plan/residential schedule, summons, a proposed parenting plan, and
child support worksheet, if any, on____
|j
____[^ate]-
2.3
9(-1. q
B ' 1 y 2** 1 2
3S01S1
The nonmoving party was served within the state of Washington and more than 20 days
have elapsed since the date of service.
The nonmoving party was served outside the state of Washington and more than 60 days
have elapsed since the date of service.
The nonmoving party was served by mail and more than 90 days have elapsed since date
of mailing.
2.4
Response
[]
2.6
adequate cause for hearing the petition has not been established,
/adequate cause for hearing the petition has been established.
ThVparties stipulate that there is adequate cause for hearing the petition.
2.6.1
2.6.2
ft is Ordered:
[]
[]
1Q ttQ fi i ^ a* -v QQH 1 Q?
[]
\MHI iScjof
M ___________
Time: _______________ ^
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Robyn A. Lindsav
COIjKT c o m m is s i o n e r
F jlU ? A ^
__________
O w n r /e r
s
Print Name
Print Name
# "* * * * < ,
Presented by:
J d fU U p A
a.m./prmT"
Lund
Date
Wy<y
>
S N A
Date
Print Name
Print Name
Date
Date
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, 1
September 19 2)
1
KEVIN ST
COUNTY C
2
3
4
5
6
7
8
Petitioner(s),
10
Cause No.
10-3-00961-1
Order Continuing
Adequate Cause Hearing
vs.
11
Respondent(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
23
24
25
/S/ROBYN LINDSAY
ROBYN LINDSAY
Judge/Commissioner
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
September 19 2012 10:56 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
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
Show Cause
Nature of Hearing: Child Support, Parenting Plans, Restraining Orders
DATED:
Signed:
NAME:
Phone:
WSBA#:
For:
1 of
Bl'Z
I S S 'J b
0 9 -2 0
1 0 -3 -0 0 9 6 1 -1
39221368
1:
SEP 1 9 2012
No. 1 0 - 3 - 0 0 9 6 1 - 1 \
DEPUTY
] Show Cause
(ADM02)
Respondent(s)
'Sg,___________________
_________P r o
For Petitioner
_____________
For Respondent
C x u A .s e
re
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Show Cause
ROBYN LINDSAY
//
rv v______________________________________________
_<RusXa*jL*>^.----
/ IN OPEN COURT
)URT OF THE STATE OF W ASHINGTON
D FOR PIERCE CO UNTY
{
______ 9 c o
FILED
CM E
6 8 1 7 8
Clerk
^ ^ " 2 1 ^ 2 0 1 .i
ih3A
e e l?
S u p e rio r C o u rt o f W a s h in g to n
C o u n ty o f
D dfflfr/ I
In re:
-ktintfff stiip/h?
Petitioner,
and
Respondent.
I s s s s s s ? 0m*L
u l e r k 's A c tio n R e q u ire d _____________
I. Basis
1.1
This court has jurisdiction over the proceeding and the parties.
2.2
21 --'2 8 i Z
2.3
1 9 6*J t s j
2.4
Response
The nonmoving party has responded.
The nonmoving party has not responded and is in default.
2.5
[]
2.6
adequate cause for hearing the petition has not been established.
Adequate cause for hearing the petition has been established.
ThVparties stipulate that there is adequate cause for hearing the petition.
2.6.2
III. Order
It is Ordered:
[]
[]
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a d j f i M tT
[]
Date:
f a t - /
tJ tfP (P f # $
fi 7r\ '^TZTFa . .
Place:
fi, /
a m./ptmr'
Room/Department:
/4 f $ o $ a f
h k S a J th
lonmovine party is in default.
The nonmoving
[]
y
rt 1 0 J
Other:
y %
s &
&
itiY
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'
/( /^ t^ \W
i^
.................. .
ated1
Robyn A. Lindsav
COURT COMMISSIONER
Lund
Print Name
Date
Print Name
lin
Date
Print Name
Date
i t f .
<
J U
fy
\ b
f lf a
'
$ 01/
Print Name
Mm*
<
iff
-fiLSD\Y
IN OPEN COURT
SEP 19 2012
lh
{J
Ord re Adequate Cause (ORRACD, ORRACG, ORH) - Page 3 of 3
WPF DRPSCU 07,0300 Mandatory (7/2007) - RCW 26 09,260, .270; 26 10 200
28533
18^322812
158092
No. 10-3-00961-1
vs.
JASON WILLIAM SHIPMAN
Respondent(s)
Court records indicate that the attorneys and/or parties listed below have failed to comply with the Case Schedule in
regard to the following items:
Certificate of Parenting Class - Petitioner's - Not Filed
Certificate of Parenting Class - Respondent's - Not Filed
TO:
Deadline:
Deadline:
08/30/12
18^3-^2812
150093
No. 10-3-00961-1
vs.
JASON WILLIAM SHIPMAN
Respondent(s)
Court records indicate that the attorneys and/or parties listed below have failed to comply with the Case Schedule in
regard to the following items:
Settlement Conference not confirmed by deadline - (See PCLR 16 & PCLSPR 94.04)
Deadline:
08/30/12
You are hereby ORDERED to appear for a hearing at 1:30 pm on Friday, 10/26/12 to comply with the Case
Schedule, or deliver a report of the same no later than the time set for the hearing.
The court may impose sanctions or terms for failure to comply with the Case Schedule. 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 3 ( j ).
DATED: 10/01/12
TO:
Superior Court Clerk for Filing
(Court File Copy)
PAGE 2 OF 2
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
October 09 2012 3:32 PM
KEVIN STOCK
COUNTY CLERK
Petitioner(s),
vs.
JASON WILLIAM SHIPMAN
Respondent(s) .
Please take notice that my address for service of court records is:
JASON WILLIAM SHIPMAN
11721 80TH AVE E
PUYALLUP, WA 98373
qy-yC'H
0
10- 3-00961-1
39388631
PCOPC
4 fi / "fy / rJ-iS^ 7
^0-^ 7 f
10-22-12
OCT 19 2012
P.M.
P1 1 W ^ |S 0N
BY
I & - 3 -
Q Q
'
< ?* / -
~~D5Pury
Cause Number
3 e -\v u v e .r
Case names:
^ \ i y w
Petitioner
3 as6 Y \
S h ip m a n
Respondent
T o A ll T h o s e T o W h o m T h i s L e t t e r M a y C o m e
T h e
In s titu te
fo r
C h ild r e n s A d v o c a c y
Is p l e a s e d to a n n o u n c e th a t:
Je n n ife r Shopman
H a s s u c c e s s fu lly c o m p le te d a F o u r H o u r w o rk s h o p
D o n t
F o r g e t
th e
K id s
A n d , h a v i n g s u c h d i s t i n c t i o n a n d p e r s p i c a c i t y in r e g a r d
to th e c o u r s e , is h e r e b y g r a n te d th is
C e r t if ic a t e o f C o m p le t io n
D a te d th is 1 6 th d a y o f M a rc h , 2 0 1 0
Instructors: S u s a n (D eG tom e, M .T .d ,
J o h n A G e n H in e s , !M .S .
T o A ll T h o s e T o W h o m T h is L e tte r M a y C o m e
F a m i l y E d u c a t i o n a s a d S r a p p o ir t S e r v i c e s
is P l e a s e d t o A n n o u n c e t h a t
1NCOUNTY^K'S OFFICE
pM .
PIERP.P a im n WASHINGTON
PIES K , County Cte^K
am
l l @
DEPJTV
M R T P a r e n tin g
a n d F a m ily V a lu e s C la s s
A n d H aving Show n Such Distinction in Regard to The Course Is H ereby Granted This
CIITDFICAT
IP H 1 T DO N
F a m ily
&
E d u c a tio n
S u p p o r t
S e rv ic e s
IQ- 3-00961-1
39394246
NTCA
A-OV?
10-22-12
u u u N T Y CLERKS OFFICE
a.m.
OCT 1 9 2012
P.M.
NO. | 0 - 3 - 0 0 3 k I -
Patitlonar,
NOTICE OF CHANGE OF
ADDRESS
and
v j a s o i lA'llwum ^ u p im a A ,
Respondent.
NOTICE IS HEREBY GIVEN that the address for the attorney and / or party
identified below is changed to the following:
NAME:
c fe n A f^ r
\L,
L -U n d _________________________
NEW ADDRESS:
3 3 3 -? ^ 6 t
P U J jd J I/J ft iV A
EFFECTIVE:
m TH IS
[ /]
[ ]
[ ]
CASE, I
9 0 3 ? 4 ________________________
lo fo (/,3 ________________________________________
Patraonsr
Respondent
Attorney fo r __________________________________ WSBA#
Dated this /3
day of O O fobdT"
. 20
288 3 8
10-3-00961 -1
39428083
RSP
1 8 ^2 9 ^2 8 1 2
/A/
10-29-12
A/&L
188182
COt
o
'CA *
0 0/>,
%
In re:
Jennifer K. Lund
Petitioner,
and
Jason W. Shipman
Respondent.
To:
I. Response
1.1
[]
[]
[]
[]
[]
[]
[]
[3
U
[]
[]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
[x ]
[x ]
[x ]
[X]
[X]
[X]
[X]
[X]
[X]
[X]
[X]
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
2M 3i
2.9
2.10
2.ll
2.31.1
2.11.2
2.11.3
2.12
2.13
2.14
2.15
2.16
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
[x]
[x]
[X]
[X]
[X]
[X]
[X]
[X]
[X]
[X]
[X]
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
[]
[]
[]
[}
[]
[]
[]
[]
[]
[]
[]
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):
Jennifer (the Petitioner) has a history of this type of behavior. Lying to the court and in fact accusing me of
things that she is doing. I have never had a problem or history of alcohol abuse or gun violence. Yet
she continues to make these accusations. She claims she didnt know 1 was working. I will include
testimony that she did. Including my son asking when I moved in with Kasey my now wife. I
inquired as to why he would ask that he stated mom says your work van is at her house every day.
She claims that pawn the kids off at my parents. This is also a lie. She claims that she didnt know
that Hunter was going with his cousin to Florida also untrue. She lied about my father, our
relationship is strong and I have been to Florida. He is a deacon in his church, in fact she was aware
that my father was coming here to take Hunter to Great Wolf Lodge and spending a few days alone
and she did not try to stop that. She spent several hours on the phone with his, stating what a bad
father I am. She tried to get him to change the date of the trip, so she could be the one to send
Hunter. She states that I should not be able to drop the kids off early on Sunday night, then she
states that I should have to drop them off on Sunday, because 1moved to Yelm. She does not want
me to drop them off early; she wants the court to make me drop him off early. I have sent her
numerous emails since she has filed this paperwork, asking if she would like me to drop Hunter off
on Sunday and she ignores my phone calls and blocks my texts. In regards to Hunter and Andy
flying alone she put Hunter and Tyler on a plane alone to visit me in San Diego. She claims these
things are not ok, yet she has done them herself. The only thing I kept from Jennifer is my wedding
date. This was at the request of the children. When I talked to them about marring Kasey the first
thing Hunter said was Does mom have to know? 1 told him yes she does. He and Tyler both
begged me not to tell her until they came to my house for the summer. I honored their request and
she still hurt them. 1have made numerous attempts to work things out with Jennifer. I have had her
found in contempt of court for thee types of things in the past. Since then I have pointed out
multiple things she is in contempt for, making medical and school decisions without me, again. 1
dont want her found in contempt of court again, as it is not in the best interest of our children. But
her trying to remove my decision making is pushing the issue. The bottom line is Jennifer is angry
and vindictive. Based on lies alone she stopped Hunter form visiting his grandfather and going to
Disney World. 1 am including Tylers school history so you can see the troubles in her home and
how he excels at mine. Tyler earned more credits in the past two years while with me for just five
weeks, than he has the entire year while with Jennifer. On the transcript, where it says CR is a
credit earned during the summer with me. The Petitioner continues to intentionally drag out court. I
sent several emails trying to schedule mediation; she waits until the last minute knowing it would
not be in time. At the last mediation we went to, the mediator apologized to me, saying Jennifer was
unreasonable and wouldnt even listen to the advice of her own attorney. I believe the only chance
mediation has is if you dismiss this case so she is motivated to work on these issues.
Resp to Pet for Mod/Adj (RSP) - Page 2 of 3
WPF DRPSCU 07.0200 Mandatory (6/2008) - R C W 26.09.260; .270; 26.10.200
2S83S
1.2
1 8 /2 9 /2 0 1 2
288184
1.3
Other
II. Requests
2.1
[]
[x ]
2.2
[]
[]
20838
13^29^2012
28S185
2.3
Protection O rder
[]
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 response.
[ ] 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.
Dated:
gnature of Non-requesti
or Lawyer/WSBA No.
Jason W. Shipman
Print or Type Name
16221 Curry Ct SE, Yelm, Wa 98597
(Address)
n :
SZSSZglZ
2B91B6
Page 1 o f 1
Sunday night
1 message
jason shipman < [email protected]>
To: Jennifer lund <[email protected]>
I have left a few messages with no reply. We need to go to mediation, or maybe even just talk. We could
probably resolve a lot by simply talking. Either w ay I have made several attempts to increase the child
support. They will not let me and send back any extra that I pay. I agree that it makes more sense to drop
hunter off on Sunday nights until we move closer. The judge said dropping him off early was ok, apparently
your attorney didnt fill you in to that point. You missed alot of things by not being in court. Most of the
things you have brought to court have already been ruled on. Please read the divorce decree. Ill just drop
him at the gate to your apartment complex like w e have done so many times in the past. I hope we can
work together in the future instead of continuing to hurt poor Hunter. Please let me know how I can help
you.
10/25/2012
Gmail - Mediation
G e ia il
28338
1 8 '3 8 - '2 8 12
2B013V
Page 1 o f 1
M e d ia tio n
1 message
jason shipman < [email protected]>
To: [email protected]
I left you another message did you get it? You need to schedule mediation. I have surgery the 12th so it
has to be before that I stated that in court just want to remind you. Looking forward to working out things in
mediation
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search=all&th=139eaa73...
10/19/2012
Gmail - Mediation 2
a t?_* jj
1 9 ^ 2 5 /2 8 1 2
z e s i a e page 1 o f 1
byCooglc
M e d ia tio n 2
1 message
jason shipman < [email protected]>
To: Jennifer lund <[email protected]>
I still haven't herd from you regarding mediation. Please try to get this scheduled. I would like to discuss
several topics with you while we are there. The medical decisions you made without me, Hunter possibly
spending more time with me when I move back to Puyallup-Then there is the issue of child support
that needs to be corrected and accommodations need to be made so the state can change it when I get
laid or when I go back to work. There is also the issue with you not allowing Tyler to have his belongings
and you keeping his senior project preventing him from graduating. I am sure there are issues you want to
discuss also. As you know, I am always willing to talk if you change your mind. I look forward to mediation
please schedule it soon as I'm sure it takes time to get an appointment and we only have three weeks until
my surgery. Have you started your 12 week parenting class yet? I found it to be wonderful. Please let me
know if I can help you get the ball rolling on this.
10/19/2012
Page 1 of 1
ID: 485858
/ ('Z '
j l f
C-
Grade: 12
Interval Values
S e m i Sem 2 YTD IP R 1 IP R 2 IP R 3 IP R 4 IP R 5 IP R 6
M em bership
90
90
180
30
20
20
31
20
20
Absence Excused
5.5
5.5
0.5
Absence Unexcused
23.5
38.5
62
7.5
5.5
13.5
8.5
7.5
S em 2
YTD
IP R 1
IP R 2
IP R 3
IP R 4
IP R 5
IP R 6
C riteria
Total Day
Periods
40
176
24
296
24
40
472
48
40
56
40
40
104
S tu d e n t
Scheduled
Periods
31
137
18
225
15
31
362
33
31
44
31
32
80
0 49
S tu d e n t
Unscheduled
Periods
39
71
110
15
12
24
0 15
P resent
Periods
_
3
. .
15
24
39
15
0 0 5
Absent
Periods
31
122
201
31
323
18
31
40
29
25
73
https://eschool.psd.local/eschoolplus/Content/Student/Att/IntervalTotals.asp
2 3
0
0 44
1 2
56
0 0
42
0 0
14
36
10/16/2012
'
iS T UDENTlNFORMATIONTj
LEGALNAME(LAST, FIRSTMIDDLE)[andothw/formalnamesused)
SHIPMAN, TYLER JASON
REPORTDATE
GRADUATIONDATE
10/16/2012
Grade Point4T0able
DISTRICT IDENTIFICATIONNUMBER
BIRTHDATE
485858
08/15/1994
PARENT(S)ZGUARDIAN(S)
LUND , JENNIFER
SHIPMAN, JASON
A
AB+
B
BC+
c
cD+
D
EOfF =
37
33
30
27
23
20
17
13
10
00
NOTUSEDING.PA______
P/N Pass/Nopass
CR/NC Credrt/NoCredit
SAJ Satisfactoiy/Unsatisfactofy
w
withdraw
SSID
7201639153
SCH O O L OF RECORD
SCHOOLNAME,ADDRESS, PHONENUMBER^
ROGERS HIGH SCHOOL
12801 86TH AVE E
PUYALLUP, WA 98373
253-841-8717
SCHOOLDISTRICTNAME
PUYALLUP SCHOOL DISTRICT
AUTHORIZEDSIGNATURE
TITLE
Page
DATE
1 of 2
STUpEN T IN FQ RMATI ON j
REPORT DATE
BIRTHDATE
485858
08/15/1994
A
AB+
s
B
BC+
C
CE>
D
E or F =
PARENT(S)/GUARDIAN(S)
4.0
37
33
30
2.7
23
20
1.7
13
10
0.0
LUND, JENNIFER
SHIPMAN, JASON
* * * * * REPORT PERIOD AND CUMULATIVE SUMMARY * * * * *
GPA
GPA
Cred Cred GPA
Grd
Earn A ttp Earn Attp
Lev Mo/Yr
PtS GPA
03.15 1.575
09 01/2009 1.50 2.00 1.50 2.00
09 06/2009 2.50 3.00 1.50 1.50
O l . 50 1,000
06.50 2.167
10 01/2010 3.00 3.00 3.00 3.00
04.00 1.333
10 06/2010 1.50 3.00 1.50 3.00
00.00 0.000
11 02/2011 1.00 3.00 0.00 2.00
02.00 1.333
11 06/2011 1.50 2.00 1.00 1.50
OO . 00 0.000
11 07/2011 3.00 3.00 0.00 0.00
00.50 0.250
12 02/2012 1.00 2.50 0.50 2.00
02.00 1.333
12 06/2012 3.00 3.00 1.50 1.50
OO . 00 0.000
12 07/2012 4.00 4.00 0.00 0.00
Cum ulative:;22.00 28.50 10.50 16.50
1 9 .65 1.191
* * * * * * * * ADDITIONAL STATE REQUIREMENTS * * * * * * * * *
Reading Standard
MET
MET
W ritin g Standard
Mathematics Standard
NOT MET
Science Standard
NOT MET
NOT MET
High School & Beyond _Plan ps
Culminating Project.C
NOT MET
*
* * * *
-k ieiTk
Hr +
k k
Ht* *
k k k k
iSCHOOL OF RECORD!
SCHOOL NAME7ADDRESS, PHONE NUMBER
10/16/2012
Grade Point Table
* * * * * * * * * * * * *
GRADUATION DATE
P/N
CR/NC
SAJ
W
Pasa/No Pass
Credlt/No Credit
Satlstactory/Unsati sfactory
Wthdrw
SSID:
7201639153
* *+ ******
C e r t i f i c a t e o f Academi c A c h i eyement J L
EARNED
* * * * * * * * * * * ENb^OF^TRANSCRIPTi-RECORD^S** * * * * * * * * *
P L Y A U t jP S C H O O L U I S I R 1 C I
AUTHORIZEDSIGNATURE
Page
TiTH
daTE
2 of 2
10-3-00961-1
39428097
DCLR
10-29-12
1KI^
f il e d
IN COUNTY CLERKS OFFICE
a m.
BY_
OCT 26 2012
rm.
YWASi
H,NClerk
5TON
(,^Cmnty
DEPUTY
In re:
Jennifer K. Lund
No. 10-3-00961-1
Petitioners),
and
Jason W. Shipman
Respondent(s)-
Decla ration of
__Stacilynn Rambow.
(Optional Use)
(DCLR)_____________
___Stacilynn Rambow________________________
Age:
____25____________________________________
/ D e c la r e :
I am writing this statement for my brother Jason Shipman. Jason is a good dad.
He is interested in his kids hobbies and enjoys spending time with them,
teaching them new things. I live with my parents and Jasons kids get dropped
off here on Wednesday and every other Friday. Jason is always early to pick
them up and has them back here before Jenifer gets here, in case she shows up
early. He never just leaves them here. Jason is a very active father. Jason does
not drink when he has his kids, and even in the time his kids are not with him,
his drinking is not excessive by any means.
Jenifer has always been difficult to deal with. She is never on time, If the kids
are with Jason and try to call her she will not answer their phone calls. She is
Declaration (DCLR) - Page 1 o f * 3
W P F D R P S C U 01.0100 (6/2006)
2SS3B
13^29^2812
288113
extremely upset that Jason has a new wife and is holding this against him. She
is trying to hurt Jason with her actions, but really she is just hurting the kids.
Her oldest son Tyler will not even talk to her because of her actions and her
lack of caring about what is best for the children. Really she just cares about
herself. She leaves Hunter home alone, letting Hunter cook on the stove and use
the oven when she is not there as well. Jenifer was part of this family but her
actions and making it impossible for even us to remain having a relationship
with her, more themjust for the kids. Jenifer used my face book page to stalk
Jason. She showed up at my welcome home BBQ to serve Jason papers. All the
nieces and nephews were here. When she realized Jason had left before she got
here, she called the police to come here. This was a traumatic experience for all
the children, all because she is upset that Jason is remarried. She made it so
Hunter could not go to Florida and spend time with his grandpa. She did this to
hurt Jason, which it did because he cares about Hunter and his feeling. And the
fact that he was not able to go with his cousin to Florida, hurt Hunter and
Andrew. She needs to stop thinking about herself when it comes to the children
and start thinking about what is best for them.
Hunter, as well as all children need a father in their life. Jason cares about his
children. He cares about spending time with them, and it is already hard for him
to only have Hunter every other weekend and one night a week. He deserves to
spend time with his children. He is an active parent and listens to them and
provides for their needs.
23338
1 3 /2 9 -/2 812
283114
1} Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
If Filed separately using a 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).
2 8 G3 y 1 8 / 2 9 0 2 3 1
s. A
10-3-00961-1
39428131
288115
10-29-12
DCLR
RM.
PIERCE COUNTY l/VASHIk
a I wCKXounty Clerk
HY----------- ----1J.------ DEPUTY
In re:
jt v s A x C t /
OCT 26 2012
A.M.
L u v \d
VL.
Petitioners),
No.
and
\ o - s
- Ooc\v - \
Declaration o f
V ) - ^ y )W V X V >
V \A 4 e .^
Respondents).
[Name]
(Optional Use)
(DCLR)
V l.
Age:
S V v\ p y v \< v n ___________
3 H _____________________________________
^ tx ^ o v x
W -
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\ aj
I Declare:
J>*KC>L
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to HU,
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1 8 ^ 2 9 -^ 2 8 1 2
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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 _
__________, [C ity]
Signature o f Declarant
U ) ft
[State] on \ P . \ g
TjQ\T_
[Date],
10-3-00961-1
39428166
DCLR
10-29-12
am .
OCT 2 6 2012
RM
deputy
In re:
Petitioners),
and
J (MkCM
Declaration of
" ^ U r
^
[Name]
(Optional Use)
(DCLR)
pW VXh
Respondents).
T s jle f
Age:
^ .
S V u f i v W A w ______________
______________________________________
J (X s <m
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Declare:
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[Date],
28838
10-3-00961-1
39428167
1 S /Z 9 S 2 B 1 2
238119
10-29-12
DCLR
vcS soFB ca
A.M.
OCT 2 6 2012
WASH/Mg
GsuntwQ,
l / [ / EPUTY
ia h c I
no.
Petitioners),
and
; o - 3 - o o q 4 , / ~
D i
Declaration o f ^
<Xir\
[Name]
(Optional Use)
(DCLR)
Respondents).
Age:
&0
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Declaration
aration (D
(DCLR)
C LR ) -- Page
Page 11 ooff 2^
7
W P F D R P S C U 0 1.010 0 (6/2006)
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28838
1 0 -3 -0 0 9 6 1 -1
39428171
DCLR
18^28^2812
288121
1 0 -2 9 -1 2
FILED
IN COUNTY CLERKS OFFICE
am
OCT 26 2012
.RM.
In re*
L tju v v d
Petitioner(s),
and
^Os^OYV
V 0 - ^ V \X p X W o .K .
Respondents).
No. 10-3-00961-1
Declaration of
____ Justin Rambow
(Optional Use)
(DCLR)____________
Justin Rambow
Age:
25
Relationship to the parties in this a ctio n : Brother o f Jason, Uncle to Tyler and Hunter
Declare:
Jason Shipman to be a good father. H e does the best he can to provide, for both Tvler and Hunter, the
things that they need to be successful and live happy healthy lives. During his visitation he spends as
much time as he can w ith them. He is at the mutual meeting spot four parents house) on time for both
drop o ff and pick up o f the bovs. at the same time I cannot sav that about their mother Jennifer. There
have been a number o f occasions th a t she has been late for both pick up and drop o ff without a tim ely
warning. She seems unw illing to com prom ise in anv situation and tries to isolate her youngest son.
Hunter, from Jason s side o f the fa m ily and ignores her oldest Tvler on a regular basis____ ___________
Declaration (D C LR ) - P age 1 of 3
W P F D R P S C U 01.0100 (6/2006)
2BS38
18^29^2812
208122
I have personally witnessed numerous times the questionable parenting calls made bv Jennifer: some o f
these decisions being as simple as ignoring the bovs when they try to contact her for permission to do
something with their Dad. Grandparents, or other members o f our immediate fam ily. The one 1 feel to be
the most detrimental would be her lack o f commitment on helping Tvler. be successful in High School.
Throughout his time in High School Tvler struggled, as many teenagers do. getting to school. From mv
perspective, while Tvler needed to take more initiative, it was her responsibility to get her son to school.
As the primary guardian she needed to be more proactive in his schooling. Over the summer Tvler was
under the care o f Jason for an extended period o f time where Jason made sure that Tvler was in a position
to get to summer school and complete his course work. While he has still not fu lly completed all
requirements to get his high school diploma under Jason s care he was able to gain all credits need to do
so.______
_____________
____
__________________________________
From the outside looking in this tug-o-war o f power between Jason and Jennifer has gone on long
enough. The divorce has been final for over a year. Jason is re-married. Jennifer is dating: at this point
we need to focus on the kids. 1 do not see what goes on at Jennifer s house: all 1 can go on is what I hear
and see from the kids. Tvler has moved out, but had many issues while still living with Jennifer including
school issues, law enforcement contact and property damage. Hunter seems to be affected with the
situation differently gaining a significant amount o f weight and becoming stand offish. Jason does the
best he can with these issues when he has the bovs. keeping them active and involved in fam ily events
(when allow ed!______________________________________ _________________________________
I do not want to discredit either as a parent. This has been a d ifficu lt situation for all parties involved and
one in which there is no easy wav. I do want to make it clear though that Jason is a very capable,
competent, and loving father; bv no means should his rights as a parent be restricted, revised, or revoked.
28S38
1 8 /2 9 /2 8 1 2
288123
M m 3 9 * ? # i 2 2 ii?
1 0 -3 -0 0 9 6 1 -1
3942B 199
1 0 -2 9 -1 2
DCLR
'v
l.
y CLERK'S OFBCE
IN COUNTY
KU
BY.------ -----------1 /
In re:
C ? e n n T -tc r ^
No. I O - ^ - O O ^ I o H
Petitioners),
and
dkscA
Declaration o f
>ecV_V >n a^PO\JL>
[Name]
(Optional Use)
(DCLR)
id
Respondents).
__ M <e. ^ ? g y y ib o u X
Name:
Age:
1s t
( y lt r fie i
/ Declare:
a r tf/jd ^ o n
n *
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H daM r
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h o c u s s___
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Declaration (DCL'R)
DCt-R) - Page 1 o f "2W P F D R P S C U 01.010 0 (6/2006)
e r - M
om
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23838
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U & ik -M U L
10-3-00961-1
39428201
10-29-12
DCLR
Petitioner's),
And Jason Shipman
Respondents).
No. 10-340961-1
Declaration of
Steven ShiDman
[Name]
(Optional Use)
(DCLR)__________________________
Steven P Shipman_________________________
6 0 ______ _______________________________
Declare:
26838
10^28^2812
2501
down here in Florida w ith mv church and 1 would never sav anything that would jeopardize the safety or
mental health and happiness o f mv grandchildren. Jason and Jenifer tried hard and, perhaps, too lone to
make their marriage work. Jason has always been a loving father. His mother, mv ex-wife, has nurtured
and raised foster and step children and Jason s exposure to those relationships has made him a better Dad
than most. His ex-wife Jennifer has not told the truth and has been vengeful not always keeping the best
interest o f Tvler and Hunter 1g and foremost. Please, for the bovs" sake at least assign a mediator. Tvler
is an adult but Hunter needs his father and would be better o ff living with his father. I have never known
mv son to be a bad father. 1 am speaking w ith the best interest o f mv grandson in mv heart. Thank you
for vour time._________ _________ ______________________________________________________
Signature o f Declarant
Declaration (D C LR ) - Page 2 of 3
W P F D R P S C U 01.010 0 (6/2006)
[C ity]
[Stale] on f r P X - I 0 - 3 0 1 {Date].
20838
10^2922012
2S012S
Declaration (D C LR ) - P ag e 3 o f 3
W P F D R P S C U 01.010 0 (6/2006)
2^838
10'3-00961-1
39428205
1 8 /2 9^28 1 2
2S8128
10-29-12
DCLR
AM OCT 26 2012
rm.
YL.
viewrv v t e c
VPetitioner(s),
and
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Respondent(s).
No.
U 3 -'3 .-0 0 v \o V -\
Declaration o f
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[Name]
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20838
18^29^2812
2 S8 13 1
ff filed separately using a 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).
10-3-00961-1
10-29-12
DCLR
39428207
..
KE
pi
BY
4 U
DEPUTY
In re:
_\evxv\.vC er
Y^.
1_\>jy \ cI
No.
\0 -3 -0 0 0 \U -l
Petitioners),
and
^O cSO W
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[Name]
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v\
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Name:
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___
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'TUASU______
-!*
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iC O u m V FC K 'S OFFICE
10-3-00961-1
3943B419
RTS
10-30-12
'jL
luv^A
No. / Q _ 3 Petitioner,
and
0 0 %
^ /
Return of Service
(Optional Use)
(RTS)
Respondent
Declare:
1.
Iam over the age o f 18 years, and I am not a party to this action.
2.
E3
[]
[]
t^
[]
n rt{
A___ -
/
4
t a / 3 0 / 7 g i ?
3.
The date, time and place o f service were ( if by mail refer to Paragraph 4 below):
Date:
/t
Address:
y/7-3.)
___________________ fa
4.
[]
[]
[]
\ ^ ~ ___Time:
- D o
'/o ilv f j
AV ~
tL _____________________
wA
_______________
6.
[]
5.
5 1 6 1 6 5
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.
Total
___ _____________________
21Sa 0
10-3-00961 -1
39479411
M TDSM
1 1 -0 6 -1 2
*4
"*
FILED
IN COUNTY CLERKS OFFICE
a .m.
NOV 0 6 2012 PM
F
Superior Court of Washington
County of
lnre: J e n n i e
NF
U vvxd
No.
Petitioners),
and^cxsov\
V ) . SK i p rncx^vv
\0 ~ 2 > -o o c \b \-l
_____________________________ Respondent(s).
^
1 11.
S>V\ i p ^ y \ f t
order dismissing this action because the moving party no longer wants the relief requested in the
^ c r r u jO jr A
W i s ______ v v q ____\ v d c r r t \ o n
[Name oF^etitk
to
P cM : b o v is x __ Ai*___ cxs.
V vK -V vX vS S W vft-tvh
Date: n . i o . i a
__^CXS>v>___ V j .__ q
Print or Type Name
21834
1 0 -3 -0 0 9 6 1 -1
39482564
ORDSM D
1 1 /7 /2 8 1 2
18885
1 1 -0 6 -1 2
Petitioners),
OcXSovy
\K) ^V \A ^)irvvcoi
i o - 3 - o o < a t o \ -1
Order of Dismissal
(Optional Use)
(ORDSM)
Respondent(s).
The court received (name o f moving party)
\AJ .
S>V\ i v^WVCA-W
s motion
for order of dismissal. Having reviewed the motion and the court file, it is hereby o r d e r e d that this
O f \ C y \ 11?
| ^3 \ /
action is dismissed.
fg T m o ^ l
J u u so if/
Dated: f ^ O V .
P t/A
b ie Q
l o , * 2_0\7_
----- -
Approved
Notice of l
to fort
ftion waived:
2 i B Bo - 11-^8^2012
8 8 8 r8
Cause Number: 1 0 -3 -0 0 9 6 1 -1
lxcalcivtl.pbl.d_civiljoumat_repori_cover
21959
1 1 ^8 /2 0 1 2
80071
vs.
JASON WILLIAM SHIPMAN
Page: 2 of 2
Judge/Commissioner:
CRAIG S. ADAMS
Respondent Jason Shipman comes before the court seeking an Order of Dismissal of the
Petition for Modification of Custody filed on June 27, 2012.
order.
JIS reviewed.
Court signs
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
April 09 2013 11:26 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
Phone:
Petitioner
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 Tacom a Ave S - Tacoma, W A 98402
Show Cause
Nature of Hearing:
Contempt
DATED:
April 9, 2013.
Signed:
NAME:
Phone:
(253) 686-3971
WSBA#:
For:
1 of
1 0 -3 -0 0 9 6 1 * 1
40317302
B&&12
04-09-13
AFRSP
V _
F ILE D
M COUNTY CLERK'S OFFICE
a*
APR 0 0 2013
pa
FIERCE COUffTY,WMttittflfflDN
KEVIN STOCK,
w
BY_________
1
Superior Court of Washington
County of
In re * \ W
o*t
^YWM^CJ-
V- - \_Wwd
No.
Petitioner(s),
and
AcKSkOW
\0 .
\ 0 -2 > - D O P \ V a \ - 1
Declaration of
JovSQYN \K) ,__SW plW lw
[Name]
(Optional Use)
(DCLR)
S W fV v U L t^
Respondent(s)
S b W p m o m ____________
AO____________________________
Age*
V\\n.vV\ni r \e \
I Declare:
O-TVW ^___v V w r x v W r
\ r \ ___ V
CLH k Y
m c h i^
W\Q\Jg A
V ^ k
3 lr *
' \\.
t* Z O V u _____________________________________________________
or
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g.^e<t\___ iTt^vxV
-\v<x\__ Vy v\e^A\e(S V\o-T____ ________________
ye^xy\VNf^___ i o ___ <3^0 -Vr> 'VWa^____cViAA__ e X c W iA y
pO\r&________
C^e^rxV eA____ i**___ ^ \ < x v \ .________________________vV v\A ^gx___ V unS______
Cfludofi___ i n ___pwTsfiAA
..-ppUcfL._______________________________________________
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NO.
in v b
P ate].
^ k x p y v w jA
2 2 9 6 6 4 ^ 9 /2 8 1 3 3 8 8 4 4
10-3-00961-1
40317303
MTSC
04-09-13
V. __ ________________
C0IWtVF,cilC8 OFFICE
e.v\v\\ * lc
1C.
No. \ 0 - 3 *
Lvxwd
. Motion/Declaration for an
Order to Show Cause re
Contempt
(MTSC)
Petitioner,
, and
f
^ Ca-v,OW
VJ . S V \
-\
rvvx^w
Respondent.
I. Motion
Finding Contempt
1.2
U-'O O M
U J c k __________________
PK
22988
[]
[]
[]
Granting Sanctions
[]
'
[]
1.4
5 8 0 IS
[]
1.3
4 ^ 9 /2 8 1 3
Other
ICTfS_______
_____________________________________
Signature of Requesting Party or Lawyer/WSBA No.
VAJ __ ^ V jip r w r \y i______
(Name)
[]
gr
\L _
Failure to comply with the provision of the child support order which directed payment of.
[]
[]
" 2 2 0 8 ^ . 4 / 9 V 2 0 13
[]
6S316
[]
[]
Other.
Failure to comply with the maintenance order which directed payment of maintenance in the
amount of $ _____________ per month as described below:
[]
dii-cAov^drio*\
[]
Other:
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct
Signedat (chy)
NeW
(state)
_
gni
of Requesting Party
___ on (date)
23BS6
4 /-1 S ./2 0 1 .3
3 BZ^>
No.
Petitioner,
Respondent.
and
<JP m
tfi/s
0 0
P f /r r f M f a /
It is Ordered:
S T '? -
Place: P / t O W P f
/3
S c tf & rd K -G ! ti0 e r-
TimP.
Time:_________
Room/Department:
>.m.
V S 72p)
If you fail to appear in person and defend at these proceedings the court may grant all of the relief
requested and/or issue a bench warrant for your arrest without further notice to you.
If imprisonment is requested in the motion and you cannot afford an attorney, you may request the court
to appoint an attorney to represent you.
Other:
Dated:
4 * * 2 /2 0 3 .3 2 3 0 3 3 3 4 0 0 7 :3
INCOUNTY?tlf?K'S OFFICE
40332219
RTS
04-11-13
A.M.
APR 11 2013
P.M.
KISFm
VyASHINGTON
KEVIN STOCK, County Clerk
BY--------------- ^ ___ DEPUTY
No. 1 0 - 3 . - OCPi\o\-\
Petitioner,
and
VO* ^>V\\ipYYV0kj\
Return of Service
(Optional Use)
(RTS)
Respondent.
/ Declare:
1.
lam over the age of 18 years, and I am not a party to this action.
2.
4 3 1 2 3 2 3 1 3 /Z IS 1 9
3.
The date, time and place of service were (if by mail refer to Paragraph 4 below):
Date:
A p Y l\
Address:
4.
[]
[]
[]
____________ __ a.m./(ffi)
fWe. t UAO\
'P u Mo U u p
6.
Time:
5.
Z4.&B7S
Other:
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at (city) SeXwv______________ , (state) LQTft
_____ ** ___________________________
Signature
_ on (date) ApvU
__ K . XL. S.V\j.pwvx v\
Print or Type Name
OOVI
______
Fees:
Service
________________________
Mileage
_______________________
Total
______ -________________
(Tape Return Receipt here, if service was by mail.)
File the original Return of Service with the clerk. Provide a copy to the law enforcement agency where
protected person resides if the documents served include a restraining order signed by the court.
Return of Service (RTS) - Page 2 o f 2
W P F D R PSC U 01.0250 (6/2010) - C R 4(g), R C W 4.28.080(15)
23133
422.2 2 2 S 1 3 5 E 8 A 3 3
INCOUNTYClI rK'SOFFICE
AM. APR 1 9 2013
BY_
ine=ur>Y
c fi
No. VO - 3 - 0 0 < A \o l ~r\
VL. L u n d
Petitioners),
and
^(XSOW
RM
V).
Respondents).
Declaration of
\\o&Qn__V J- ^>Vu/7ir\a.A
[Name]
(Optional Use)
(PCLR)
______________
AoSfrm __ \M
vy p t y x j i__________________
Age:
4 0 _____________________________________
W v -A y * * ^
dT
VlO Y^g-f
I Declare:
\1
V1 v x w
Y"O^XVA\t\g
y\ ov^
s^v\A
A e *v tv fe g
N/\oAAv\v\ .
<.W
<=xpm A
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rrv*\ v\rA vca ^ wyvA >W
s>e>lgjr n \ ___t ^ v m A ls
tta u i_____
_A \u __ AW -__ e^KrWxwr^___XocnAftcvtv.___
Vd v v\rsV__ Vsr W awa/i___Vvim
Ov\
A n r A ___UY^?
\
vrvis^cd___ vxSvWWwi__ V*^r/vu*___2*W______
SVvfiU'i
lAp
Ad ^vtw i___f tu * k * r __ c$R.___ Q y\__ ________\~V*~
AW srk w \t
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\V\cWAvrfV".__ g-YW>A Vs__ OLMvA
3
-------------- :
-----f f \r haA __AW ____\nm A um _
Declaration (DCLR) - Page f o f *2~
WPF DRPSCU 01.0100 (6/2006)
'pftW i
o v iA __ A W vt
.2 3 1 8 3
4^2222813
^38134
r
\\
_ rV W
- W r * tr
vnsljicV
aA~
d tA r*oA
vwvC^giA
\r* \p
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T ^ u ft
An
Ab___wgA V>po>/\yvj r t w ^ ^ M y
c iy u A
c A W r^ ______\ vooo\d
^\\\ori___ A^n
-Htvm S
u v jl
ira tM c fn , i ---------^ W v \ , U b o a *
s a m s vYvvfo
la p
AS**>i
N eA w \
[City]
V xlcx
[State]on
Afl&tvy
NkK
Print or Type Name
[Date],
^Vx^vrwfl^iA
Do not attachfin an cial records, personal health care records or confidential reports to this declaration. Such
records should be served on the otherparty andfiled with the court using one o fthese cover sheets:
1) Sealed FinancialSource Documents (W PFDRPSCU09.0220)fo rfin an cial records
2) Sealed PersonalHealth Care Records (W PFDRPSCU09.0260)fo r health records
3) Sealed ConfidentialReport (W PFDRPSCU09.276)fo r confidentialreports. I f file d separately using a txrver
sheet, die records w ill be sealed to prated yourprivacy- Although they *uff he available to a llparties in the
case, their attorneys, courtpersonnel and certain state agencies and boards.) See GR 22(C)(2).
2318B
Yes
Homeland Security:
IBR Disposition:
Forensics:
Case Report Status:
Resolved
None Required
Approved
5 8 8 1 VS
Page 1 of 4
In c id e n t N o. 1 0 0 0 9 6 3 4 .1
P u y a llu p P o lic e In c id e n t
R e p o rt
PDA: |
4 ^ 2 2 /2 8 1 3
subject }
Case Management j
Disposition: :
Reporting By/Date: !
I
Reviewed By/Date: |
o o
2 51
<3
ii
Related Cases:
Case Report Number
1 Agency
1 Puyallup
10009511
Police
Non-Electronic Attachments
Attachment Type
ORP - Order for
Location Address:
City, State, Zip:
Contact Location:
Recovery Location:
CB/Grid/RD:
Occurred From:
Protection (copy)
Additional Distribution
PPD - DV Advocate
1
l
Location Name: j
Cross Street j
>
!
I
Count
j
Puyallup - South
1 1/17/2010 17:43:00 Wednesday
Notes:
- - Other Distribution: *
Additional Distribution: j ppD -DV Advocate
Validation Processing ;'jDistribution Date:
County Pros. Atty-; *
Juvenfle f -j Other i ; -CPS > !Supervisor
City Pros. Atty- . s MffitaryM^ j DSHS 1 , PreTrial > ; --- ----..
- : jBy: : For Law Enforcement Use Only - No Secondary Dissem ination Allowed
Printed: November 3 0 ,2 0 1 0 -3:22 PM
Call Source:
PhoneReport
Insurance Letter
Records has the authority to ensure correct agency, CB/Grid/RD, and Distrid/Sector are incorporated
m the report.
2 3 ie
1^
P u y a llu p P o lic e I n c id e n t R e p o r t
4 /2 2 ^ 2 8 X 3
S 8 3 5 .9 6
Page 2 of 4
In c id e n t N o. 1 0 0 0 9 6 3 4 .1
t
t
Domestic Violence:
Completed:
CnminaJ Activity:
*
Location Type:
Total No. of Units
Entered:
Apartment
Gang Related: j
Crime Against j
No
!
Type of Security: j
| Evidence Collected: |
Juvenfle:
Hate/Bias:
No
None (No Bias)
Using:
Tools:
None
Entrance
Compromised:
Entry Method:
Suspect Description:
Suspect Actions:
Nates:
1 fi^ e: \ 38
Se* j Male i
s 5*11" * Weight f 775
s Hair Color j
j 8811 133nrfStCtE
I County:
i Puyallup, WA 98373
P Country:
*_
j Nonresident
! OccupationfGrade:
s s N
Driver License No: i
Race:
White
i
;
) Unknown
|
Driver License ] Washington
State:
Attire: j
SMT: j
Entity Type: petitioner
(pap er/o rd er
|
|
| S^tement Obtained: j
! service only)
Ethnicity:
Eye Color
Phone:
Business Phone:
Other Phone:
EmptoyertSchoot
Place Of Birth:
Driver License
Country:
Complexion:
Facial Hair
Facial Shape:
1 Unknown
| Blue
; 253-686-3971
j
]
i Unknown
|
United States of
America
Entity Notes: |
PDA:
Aliases:
For Law Enforcem ent Use O nly - No Secondary Dissem ination Allowed
231S3
I Age:
36
| Occupation/Gtade. j
Eye Color i
j
j
Phone: |
Business Phone, j
Other Phone: ;
Nurse
~ ~ T ....
Driver License ! Washington
State: j
Respondent
(p ap er/o rd er
service only)
Blue
253-606-3039
253-985-1711
Emptoyer/schooi: i
Place Of Both: }
s t Clair Hospital
Driver License j
Courtry: i
Complexion: j
Facial Hair. [
United States of
America
Entity Type
Page 3 of 4
B h**** i Non-Hispanic
! County: \
i Country: ;
;
|
BBBV97
I n c id e n t N o. 10009634.1
P u y a llu p P o lic e I n c id e n t R e p o r t
DOB:
4 ^ 2 2 / 2 S 13
Reporting j
Statement Obtained: j
Facial Shape: j
i
Entity Notes: j
Investigative Information
Means:
I
|
\
Vehicle Activity: j
Motive: !
!
1
l
Synopsis: {
On November 17,2010 Acting Sergeant J. Pihl #265 gave me the listed paperwork to serve on
Jennifer Shipman. I noted there was a case number assigned but there was no personnel number denoting
who had received the order initially. I checked RMS and observed that no general report had been
completed. I confirmed with records staff that a copy of the original had been created for the case file. I
attempted to contact Jennifer Shipman at her apartment located at 2323 7th St SE #B203 at approximately
0905hrs. There was no answer at the door. I called Jennifer and left a voice mail requesting a call.
Later this date Jennifer called and advised she was meeting her husband, Jason Shipman, for a child
exchange at 1700hrs at Best Buy. She stated that if I could not meet her there she would be available at her
apartment approximately 15 minutes later I advised her I needed to contact her in person but did not
describe the paperwork I had for her.
I later received a call from Jason Shipman asking why the paperwork had not been served last night
I advised him I did not know. I told him I had spoken to Jennifer earlier this date and would be attempting
service tonight shortly after the child exchange. Jason asked if it were possible to arrive at the exchange and
serve her. I stated it would depend on our availability at the time.
I arrived at the exchange site prior to 1700 hrs. Jennifer did not respond. She sent her brother,
Darren Lund, with the children*1instead. He said she was attempting to reach the Family Justice Center
before it dosed. I tried calling [Jennifer she did not answer her cell phone. I asked Mr. Lund to call and
Jennifer answered. I asked where she was currently located. I was hoping to gauge how long it would take
her to return to her home. Jennifer was vague and would not directly answer the question until I redirected
her specifically asking her "exact location at that moment* three times. She stated she was on Court C in
Tacoma but was returning to Puyallup. 1responded to Bradley Park Apartments and waited. When Jennifer
arrived f served her with the temporary order and notice of hearing. I advised City Comm. The record was
updated in WACIC. See attached note.
I would like to note the three prior contacts this department has had with this couple in as many days.
On November 10,2010 Officer Culp #304 took a report of DV Assault from Jason Shipman. The incident
occurred during a child exchange. Jennifer admitted she had hit Jason but stated it was only to get him to let
go of her window. He stated that she had reached out of the window to strike him.
2313e
P u y a llu p P o lic e I n c id e n t R e p o r t
!
4 /2 2 ^ 2 ^ 1 3
5BS13S
Page 4 of 4
In c id e n t N o . 100 0 9 6 3 4 .1
On November 11,2010 Officer Bourbon and I were requested by Jennifer to perform a civil standby
while she and her husband exchanged their two children at Best Buy. The children are aged 9 and 16 years
old. We maintained a visual on the couple from a distance. The exchange was completed without incident I
called Jennifer later and suggested she seek other options for their exchange. I explained there was
insufficient staffing for our police department to attend each of their exchanges. Jennifer stated that she had
wanted to drop the boys off at Jason's mother's home but that Jason would not let her. This required her to
take a day off from work. I suggested she contact her attorney to work on an option they could agree upon
without tiie need for law enforcement interaction. Jennifer stated her attorney was not very good. 1provided
her with information regarding the Judson Family Justice Center and suggested she check their website, call
them, or talk to them in person.
On November 12, 20101 responded to again perform a civil standby at the Best Buy for the couple at
Jennifers request Jason's mother responded for the exchange. She related that she would welcome the
children being brought to her home. Jennifer stated that this was not written in the Parenting Plan and she
felt she should follow it exactly or Jason would hold her accountable in some way. This did net make any
sense since she wanted the exchange through the grandmother on the prior day.
There is no further information at this time. This report will be forwarded to the DV Advocate for
information.
Reviewed By;
Reviewed Date: 1
l
i
23133
4222^2813
S231SS
P ie r c e C o u n ty C e n te r f o r D is p u te R e s o lu tio n
738 Broadway, Suite 400
Tacoma, WA 98402
2 53 .57 2 .36 5 7
Fax: 2 5 3 .5 7 2 .3 5 7 9
S e ttle m e n t A g re e m e n t
W e , J e n n if e r L u n d
and
3 .2 SCHO O L SCHEDULE. Upon en ro llm en t in the school, the ch ild (re n ) will
reside w ith th e p e titioner, except fo r th e following days and tim es w hen then
c h ild (re n ) will reside with or be with th e o th er parent: from 5 :0 0 pm Friday
to S un day night a t 8 :0 0 pm and ev ery W ednesday from 5 p.m . to 8 p .m .
Should th e fa th e r relocate into th e Puyallup School D istrict, th e schedule will
re v e rt to th e Parenting Plan dated A ugust 4 , 2 0 1 1 .
3 .7 SCHEDULE fo r HOLIDAYS
Th e 1 0 :0 0 pm end to the Holiday does not apply to th e Fourth o f July. The
Fourth o f July holiday ends on July 5th a t 8 p .m .
2 3 IB B
4 '/ 2 2 / 2 8 1 3
S20288
P ie r c e C o u n ty C e n te r f o r D is p u te R e s o lu tio n
738 Broadway, Suite 400
Tacoma, WA 98402
253 .57 2 .36 5 7
Fax: 253.57 2 .35 7 9
2 3 '8 3
4 S 2 2 S 2 & 13 5232B 1
Page 1 o f 2
byCkX^lc
(n o s u b je c t)
2 messages
Jennifer Lund < mjent5@hotmail com>
To Jason Shipman <[email protected]>
Mr Jason Shipman,
11721 -80th Ave E
Puyallup, WA 98373
(253)686-3971
Mr Shipman,
This is to inform you that Hunter has a dental appointment on Tuesday, April 9th, 2013 with his regular
dentist for his routine cleaning. I was also finally able to get Hunter an appointment with a pediatric
gastroenterologist He has an appointment with Dr Daniel Lustig on Tuesday, Apnl 16th, 2013 at 1 15pm.
(402 - 15th Ave SE, Puyallup). Back on Wednesday, February 13, 2013 you had told me that you would
send me a copy of your health insurance card for Hunter. I still have not received foe card. It would make
things easier dealing with Hunters medical appointments if I had a copy of the card, could you please send
it soon*?
Thank you,
Jennifer Lund
2 3 2 3 -7th Street SE, U101
Puyallup, WA 98374
(253)904-8608
As per our divorce settlement you are responsible for all medical costs including medical insurance. I
provide it out of love for Hunter. I have ordered the cards they have not come yet l had a talk with Hunters
doctor He explained the stress of the lack of communication and general stress of being stuck in foe
middle is what makes him sick. There is nothing wrong with him physically Hunter and I talked about it He
explained how he gets upset because how mad you get about what he eats at my house I explained to
him foe doctor told me nothing he eats at my house will make him sick. If it was a food issue dinner Fnday
would make him sick before he went home. I also told him if it was not the food you would be mad at me for
something else. Once he understood you are always going to be mad at me regardless of what he eats all
the stomach problems were gone He has not had any issues since we found out foe truth. Look at the
stunt you pulled this weekend. You knew I was planning on picking him up this weekend. You also knew I
was wiling to let you keep him. I sent you a text. Everyone herd me say ill see you Fnday on Wednesday
night. Yet you didnt show up I think its funny all this started when you stopped him from going to Flonda
by lying about my father. He has not been sick for a long time. I have bent over backward to be nice to you.
I started going to Greg and Amy I started meeting you at Fred Meyers all in hopes you would act like a
mature adult that cares about whafs best for her son rather than how to being vindictive and just plain
mean. Your lies and actions are physically making your son sick. Due to the fact that you blocked my
phone and refuse to communicate we are going to have to revert to the parenting plan and the written
https://mail.google.com/mail/?ui=2&ik=8bfal 3ada4&view=pt&search==inbox&th^l3dc7a...
4/18/2013
2 3 IB S
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agreement of mediation. I will no longer meet you at Fred Meyer or Greg and Amy's. Hopefully some day
we can get along enough to try these things again. Until then we need to follow the legal documents. I have
tried to contact you regarding a conversation we had Sunday. Hunter tells me he sleeps on the couch
because your room mate sleeps in his bed. His stuff is in the hallway? This is concerning to say the least.
Please call me so we can discuss these matters and talk about settling our differences for the sake of
Hunter.
[Quoted text hidden]
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search-inbox&th=13dc7a...
4/18/2013
Gmail - Visitation
Geiail
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B 28> 233
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byCiOOgle-
V is ita tio n
1 message
jason shipman < [email protected]>
To. Jennifer <mjen15@hotmail com>
You're not here. You're cellphone is blocked. You're home number is blocked Do i have to involve
authorities and the courts again? This is only hurting Hunter If i haven't herd from you by 5:30 i will have
no choice.
4/18/2013
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4 -3 -1 3 v is ita tio n .
1 message*I
jason shipman < outlawOOl 5@gmail com>
To: Jennifer <mjen15@hotmail com>
I just got off the phone with Hunter He informed me you are at a coworkers house. He said you haven't
been to Greg and Amy's and you refuse to bnng him here. I have notified the Puyallup police and Pierce
Co. Sheriff of the situation.
23130
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4 /2 2 /* 2 8 i3
5202&S
Page 1 of 1
byCooglc*
4 -5 -2 0 1 3 p ic k u p
1 message
jason shipman < [email protected]>
To1Jennifer <mjen15@hotmail com>
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search=all&th=13ddccl8f...
4/18/2013
2 3 1 3 8 * 4 V 2 2 2 2 '0 1 3
5 2 B2BS
G aail
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byCoogle
V is ita tio n o n 4 -1 0 -1 3
2 messages
jason shipman < outlawOOl [email protected]>
To: Jennifer [email protected]>
Hunter says he is still at home? Are you going to bring him to the designed exchange area? What's going
on? Simple communication would be nice, If you're going to be late just let us know please. We have only
been late once and I made you aware of it.
Its almost six o'clock and you're not here. As you can see from the papers you where served today im not
going to tolerate this. Are you coming or not I need to feed my kids. Not letting Hunter talk to me is also a
violation of the parenting plan.
[Quoted text hidden]
4/18/2013
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4 /2 2 /2 B 1 3
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byGoOgtc
h u n t e r s e x c h a n g e 4 -1 4 -2 0 1 3
1 message
jason shipman < [email protected]>
To Jennifer <[email protected]>
It was brought to my attention that you didn't pickup Hunter on 4-14-2013. My sister had to take him to
school with no backpack or school supplies You continue to violate section 3 11 of the parenting plan, t
have provided a copy. It clearly states the exchange is to take place at the paternal grand parents unless
we mutually agree otherwise I do not agree to meet you elsewhere due to you not showing up or being
extremely late with no communication I expect you to start going to the proper designated location
pH jason pp.pdf
I a 352K
https://mail.google.com/mail/?ui=2&ik=8blal3ada4&vicw=pt&search=all&th^l3ela383d
4/18/2013
23 IS & 4 S Z Z S 2 & 1 3
SZ&ZBB
Page 1 o f 1
4 -1 7 -2 0 1 3 v is ita tio n
1 message
jason shipman < outlawOOl 5@gmaii com>
To Jennifer <[email protected]>
I don't understand why you continue to do this. You know your hurting Hunter he wants to see me. You
know that your supposed to drop off and pick up Hunter from moms like we have done for several years
You have the ability to bring him to moms house. Your choosing not to comply with the parenting plan I
know your planning on going to court and saying you don't feel safe there. We both know that's a lie. There
is no danger at my moms you tried using that lie in court twice before when we decided on the third party
exchange location. Even if that was true you have had several years to change it Three different Judges
have told you to stop doing this stuff. Follow the parenting plan and think about whafs best for the kids.
You where told to act like an adult and communicate One judge even ordered you to go to counseling with
me witch you refused and never did. You didn't show on 4-17-2013 Making me miss my visitation When I
onginally filed the Order to show cause I had not missed any time Now I have missed several
visits, therefore I will be asking for make up time.
23324
4 /3 8 /2 8 1 3
18834
IN COUNTYHrK'S office
am.
PliM W n W N
BY-
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S u p e r io r C o u rt o f W a s h in g to n
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Petitioners),
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I declare under penalty of peijury under the laws of the state of Washington that the foregoing is true and
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Signed at d A U j& J Iu p _____ , [City]
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1 declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
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Signed at
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Print or Type Name
Do not attach financial records, personal health care records or confidential
reports to this declaration. Such records should be served on the other party and
filed with the court using one o f these cover sheets:
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
If filed separately using a cover sheet, the records w ill 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) .
Declaration (DCLR) - P a g S z of }j
WPF DRPSCU 01.0100 (6 /2 0 0 6 p
23324
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Declaration (DCLR) - P a g e \ of 11
WPF DRPSCU 01.0100 (6/2006)
2 3 3 2 4
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, [City]
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___[State] on
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[Date].
U w d
Print or Type Name
Do not attach financial records, personal health care records or confidential
reports to this declaration. Such records should be served on the other party and
filed with the court using one o f these cover sheets:
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
If filed separately using a cover sheet, the records w ill 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).
tp
Declaration (DCLR) - Page ^
WPF DRPSCU 01.0100 (6/2006)
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58841
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at
[City]
_____
ature ofDeclarant
fr
[Date].
[State] on
( jm
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1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
If filed separately using a 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) .
Declaration (DCLR) - P a a e ^ o f / [
WPF DRPSCU 01.0100 (6/2006)
4 /3 8 /2 0 1 3
53342
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- i * o o ' i o
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S f it i'it j
BV_____________ DEPUTY
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Superior Court of Washington
County of Pt02.CE*
Inre:*4f)^ J T ^ U T J ^ S , 0 p
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and
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Declaration of
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10-3-00961-1
40438423
DCLR
04-30-13
__________ .06PUTY
<Jassn
No./D 3-0O 4W -I
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Respondent(s).
B u r n n tu r )
[Name]
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___________
R d jtjlie l R . B u r n h a m
Name:
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Relationship to the parties in this action: '& ie n J 4 f i & f k h s r
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10-3-00961-1
AM
04-30-13
40438425
APR 29 2013
p.m.
5T0N
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Petitioner/Plaintiff,
Vs.
Jd sw
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t o - s lu p m n
(DocumentTitle)
Dated this
day of IRpiljll
2007 documentcoversheetdoc
20
4 - '3 0 r '2 0 1 3
Darren M Lund
580S 0
To Whom It My Concern:
This letter is written on behalf of Jennifer K Lund (mother), by her brother Darren M Lund in regards to a visitation issue
with Jason W Shipman (father).
On April 3rd, 2013 at about 5:45pm, I was approached by Jennifer and asked if I would consider taking Hunter Shipman to
Jason's mother's home for his visitation drop off. She informed me that for many months prior, (per a court appointed
mediation in December), Jennifer and Jason had been meeting at a neutral non-family location and due to unknown reasons,
Jason suddenly reverted to meeting back at his mothers home.
Jennifer then expressed to me that due to intimidation issue from Jason's brother, Ted Shipman, violent issues from her
son Tyler Shipman and being verbally told she was not welcome at Jason's mother's home, she felt she should not appear
there. She then asked if I would mind taking Hunter to Jason's mother's home, and I agreed.
We left my home, across from the Daffodil Bowling Alley just before 6pm. On the way. I stopped at a roadside mailbox to
mail one letter for my wife. Hunter and I were at Jason's mother's home within about 5 minutes. After dropping Hunter off, I
returned home and was back by roughly 6:15pm.
Sine
Darren M Lund
^HO
J.
in countyfcl1rk*s office
10-3-00961-1
04-30-13
PIERCI
KEVINSTOCK,
by._____
PM.
___________nePUTY
77?^-
in re:-
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APR 29 2013
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On the evening of July 1 2012, \, Deborah R. Bergman, accompanied Jennifer Lund to the home of Jason
Shipman and his parents, Pete and Becky Rambow, residing at 1172180th Ave E in Puyallup, Washington
98373. We arrived around 6:45pm. As I was rounding the back of the house, where I heard children and
adults playing baseball, I made eye contact with Jason Shipman. His sister, jStaci, said, "Sorry, Jason, they
caught up to you." I looked down to keep from tripping on loose gravel. When I looked up, Jason had
disappeared around to the front of the house. Jennifer saw him enter the residence through the front
door. Jason's sister, Sierra, toid me, "Sorry Jason's not here." I asked, "Oh.Lthat wasn't just Jason I saw?"
Sierra replied, "Ub, well this is private property, so you need to get off and leave." Their niece,
Samantha, then added, "Yeah, you are trespassing on private property, so get the hell off!" Staci then
jumped in and said, "Sorry, you need to leave now) This is private property and you are trespassing and
you need to leave." i said, 'Thank you, have a nice day/' and i returned to [Jennifer's vehicle.
As I was relaying what was said to Jennifer, Jason's fiancee drove away in a white minivan. Jason
followed soon after in his mother's vehicle. Jennifer called the Puyallup Police Department's nonemergent number to see if they could provide us with the civil restraining jorder and other documents or
serve him a civil stand-by. The dispatcher informed Jennifer that Puyallup P.D. does not service that area
and that she would need to call the Pierce County Sherriff s Department. While she was on the phone,
Jason's brother, Theodore Shipman approached the driver's side window and said to Jennifer, "Sorry, it's
not going to happen today. You need to get off our property." Theodore pointed to 117th St and said,
"Go park over there. You can't park here." Jennifer replied, "I am on the phone with the Sheriffs
Department," while rolling up her window. Jennifer was parked on the easement of 80thAve the entire
time. She technically was never on Pete and Becky's property. Jennifer did move to appease Theodore.
f
Kasey came back while Jennifer and 1were waiting for an officer from the Pierce County Sherriff s
Department to arrive. Deputy Christian (Badge#477) and Deputy Burke (546) arrived just before 7:15 pm.
The Deputies informed Jennifer and i that they no longer get involved with serving civil restraining
orders, but would be happy to talk with Kasey to get this matter resolved! After talking with Kasey for a
bit, the deputies returned to Jennifer's vehicle and informed us that Kasey did not want to, and did not
have to accept the court papers containing the restraining order and other documents on Jason's behalf.
Deputy Christian then went to his vehicle and returned to us with a number for the Pierce County CMI
Department. He tofd us that the Pierce County Civil Department may be able to help with tfie serving of
papers.
We left Pete and Becky Rambow's residence at about 7:45pm and drove to the Hand! Corner on 112th.
We sat there waiting for Jason to drive by until about 8:10pm. While driving down 112th on our way back
to my vehicle, we passed Jason and he flipped his middle finger at us as he drove by. We traded vehicles
and arrived back at the Rambow's residence around 8:25pm. The minivan was gone. We drove to the
gas station and filled up. We left Puyallup at approximately 8:52pm.
23324
4^30^2013
8 8 b3
We arrived in Yetm at Jason and Kase/s house at around 9:15pm. When we drove by, the white minivan
was not there, so Jennifer drove us to Jack-In-The-Box for some dinner. We returned approximately 30
minutes later. Jason and Kasey's garage was open and the white minivan was parked across the road
next to Jason's work truck. Kasey was standing outside of the garage, smoking. Jennifer and ( circled the
block one time to see if Jason would join her. When we came back around, the garage was dosed and
Kasey was no longer in sight.
Jennifer parked at the top of the cul-de-sac in hopes of seeing Jason come out. As we were waiting,
Kasey came out to smoke but Jason did not join her. Soon after, a Yelm Police Officer pulled up behind
us. The neighbors had called them because Jennifer and t were parked by mail boxes and they were
concerned. He asked what we were doing there and Jennifer informed him that we were trying to serve'
her ex-husband with a Civil Restraining Order and other Documents. Kasey was still outside and the
officer offered to talk with her to find out if Jason was home. Kasey told the officer that he was not
there and she did not know when he would return.
The officer asked us to park somewhere else, so Jennifer and 1 parked in the Safeway Parking Lot. This
stiil provided a line of sight to the cul-de-sac where Jason's residence was and continued watting for his
return. At 11:10pm, Jason drove his Hariey Davidson into the Safeway Parking Lot and parked two rows
behind our vehicle. He glared at us while he spoke on his cell phone to someone. A few moments later,
his fiancee Kasey pulled into a stall by him and they began talking. Then Jason drove up and parked by
the passenger window, where I was sitting. As we were trying to roil the passenger window down, Jason
said, "Weif come on I Rolf down the window; Roll down the fucking window^ Once I got the window
down, Jason said, Three StarsTI handed him die paperwork and said, "Jason Shipman, you've been
served." Jason Shipman was served at 11:19pm.
Jennifer was so upset by Jason's anger and harsh words that it took her a half of an hour to be able to
drive us back to Puyallup.
If there are any questions or concerns, I can be reached at 253-486-6309.
Thank you,
(Name Printed)
(Signature)
413/ U J
b o tib ti
40438452
CPEM
am.
04-30-13
APR 29 2013
d e n fitte r k .
Petitioner/Plaintiff,
Vs.
) No. ID ~ 5 ~ Q 0 ^(d I - I
d o sttin 10-
!j& W
j j
Respondent/Defendant.
Dated this
day of JQ$Uj
2007 document,coversheel,doc
20 P ,
t,
K
do sm
? < J e n m k r/ W
( S fiL p m a s )
23324
4/7^13
4 ^ 3 3 /2 8 1 3
B88S1
j M r. Jason W. Shipman
f 11721-80th Ave E
Puyallup, WA 98374
(253)686-3971
outlaw0015f5)gmail.com
M r. Jason Shipman,
1wanted to inform you that Hunter has an appointm ent this Thursday (11/29/12) morning
i fo r an abdominal ultrasound at Medical Imaging Northwest at Good Sam. His pep does not
do them . This procedure is simple, noninvasive and w ill only take a couple of minutes. It's
the same as when a pregnant woman has an ultrasound of her unborn baby. You can google
fo r more inform ation if you need it. Hunter has been having complaints of abdominal pain,
diarrhea, nausea w ith occational vom itting. The doctor just wants to make sure his
gallbladder is ok, that is why she ordered the abdominal ultrasound. Hunter needs to be on
a fat free diet 24 hours prior to the ultrasound. Since he is with you Wednesday (11/28/12)
evening, please do not feed him a fatty meal. If you do so it could alter the results of the
ultrasound. If you do not want Hunter to have this procedure please le t me know so that I
can cancel the appointm ent. If there is any abnormal result I w ill let you know, otherwise if
you do not hear from me the results were normal.
On August 4,2011 per the decree of dissolution you were ordered to pay me a principal
Judgement amout of $1,643.75. It has been 151/2 months and I have not received any
money from you in regards to this debt, t have been gracious in giving you tim e to come up
w ith the money so now I would greatly appreciate the amout to be paid in full w ith in 30
days. A creditor would have sent you to collections and/or garnished your wages months
ago. If I do not receive the money you owe to me w ith in 30 days then I w ill pursue other
options in collecting the money. Your attention to this m atter is appreciated. If it's easier
h^7/bay156.rnai!.!i\e.conVrat/PrintMessages.3spx?cpds=85f1dO29-39O1-1l02-b64f-OO215acf7ri5O,rn8dsSafB=true&Fo<deflD=OOOOOCX)O-OOOO-OOOO-OOOO-OOO . 1/2
23324
42313
4 /3 8 /2 8 1 3
SS3&2
for you, you can send me a check in the mail. I have recently moved. My address is the
same, the only thing that changed is my apartment number. Im now in U101.
Signed,
Jennifer Lund
2323 - 7th Street SE, Apt U101
Puyallup, WA 98374
(253)245-4255
rnienl5@ hotm ail.com
23324
ijjjjiw iiiiiii
10-3-00961-1
III
CPEM
53Sb3
M /fllllJM
40438463
4 /3 0 ,-2 8 1 3
04-30-13
APR 29 2013
pa
f f l 5
by________
p M.
f f
-D eputy
fru x /n c ta e ; d f1
d n n d e r K Shbpnuw
Petitioner/Plaintiff,
Vs.
! No. ID -d rD W b H
c i m ? iD .d u fM m
Respondent/Defendant.
Dated this
day of
1007 document,covctshect.doc
ll
2oZ3_
23324
4/29/13
4 /3 tJ /zeid
tjotjti-i
M ove to Puyallup
From. Jason shipman ([email protected]) This sender Is in your contact list.
Sent: Sun 4/28/13 6:43 PM
To: Jennifer ([email protected])
We have finally moved to Puyallup as per our previous discussions. 3.14 o f the parenting plan doesn't
apply because Hunter resides w ith you the m ajority of the tim e. We have discussed me moving back as
soon as could. Our new adress is 1242180th ave. Hunter is not prepared to go to school tomorrow.
Therefore his Sunday overnights shall start next visit. I w ill have him at the designated exchange point at
8:00 per the parenti ng plan.
httpsJ4)ay156.mail.live.corrVmaii/PrintMessages asptf?cptds=3a52cf73-b06e-11e2-9503-00215ad846a4,m&isSafe=1rue&FoIdertD=00000000-0000-0000-0000-00. .
1/1
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
May 01 2013 10:23 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
Phone:
Petitioner
Please take notice that an issue of law in this case will be heard on the date and time shown below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
Show Cause
Nature of Hearing: Contempt
Calendar: Show Cause/Family Law
May 1, 2013.
Signed:
NAME:
Phone:
WSBA#:
For:
1 of
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C t t u x t . . ______________________________________________________
Show Cause
KEVIN GRUNDLE
) o - i0 4 ./n
Clerk
C \ JU L 1 J J_
7
Courtroom number 100
Calendar C1- SHOW CAUSE/FAMILY LAW
23361
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? mmissoners
INOPENCOURT
3-00961-
40453667
ORCNT
MAY 0 1 2013
05-02-13
P IE R C E C O U N T Y , C le rk
vBy__ j y OEPUTY
NW- LuntJ
In Re:
U ^ m -fe r
Petitioner/Plaintiff
no.
\m /}
I f)
and
) a s o M
< h > p M 4 /l
RespondentyDefendant
ORCNT
THIS MATTER having come on regularty for hearing, and the Court having found that the
Petftioner/Respondent fs a t substantial risk of Incarceration, ft Is now therefore,
ORDERED, ADJUDGED am i DECREED, that this maty js hereby continued to:
- n > t l m v | M l W O f f , O l 3 _____________ , a t M 9 :0 0 AM 1:30 PM In
such Room as posted,' Pierce County dourthouse, County-Cfty Bufkfln( 930 Tacoma Avenue South,
Tacoma, WA 98402 . This m atter is continued to allow the Petftioner/Respondent to obtain
representation through the Department of Assigned Counsel, but only In the event the
Petftioner/Respondent financially qualifies for said representation. To apply for legal representation
you must contact the following office w ithin 4 days o r YOU WILL BE DEEMED TO HAVE WAIVED
YOUR RIGHT TO COUNSEL:
P retrial S ervices:
M flV
.day of
ner
KEVIN RUNDLE
ffa o TEH ,
Respondent
5 /2 1 /2 0 1 3
10-3-00961-1
AFRSP
40661843
05-21-13
a.m.
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[Date].
10-3-00961-1
40561044
05-21-13
DCLR
filed
MAY2.1 2013
a.m.
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WASHINGTON
KEVINSTOCK, County Clerk
aI
DEPUTY
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10-3-00961-1
40561861
DCLR
05-21-13
FI LED
MAY 21 2013
p.m,
PIERCE COUNTY,WASHINGTON
K B V IN s g ^ C ^
Petitioners),
and
Declaration of
W - S V\xY?ywo^\
[Name]
(Optional Use)
(DCLR)
___________
Respondents).
^ T y L e y ___ ^
V ______________________
Age:
S Q V ^_____
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Print or Type Name
E-FILED
IN COUNTY CLERI
PIERCE COUNTY, W
May 28 2013 8
KEVIN STi
COUNTY C
NO: 10-3-00
2
3
4
5
6
7
8
9
JENNIFER SHIPMAN,
Petitioner
10
11
and
12
JASON SHIPMAN,
13
14
15
)
)
)
)
)
)
)
)
)
Respondent.
)
_______________)
I, Jennifer Shipman (Lund), declare under penalty of perjury under the laws of the State
16
of Washington, that the following is true and correct to the best of my knowledge and belief:
17
I am over eighteen (18) years of age. I am competent to testify regarding facts set forth
18
19
20
21
Wednesday and Friday at around 5:00 p.m. I pick him up from the same location at around 8:00
22
p.m. every Wednesday and Sunday. Jason and I agreed in December 2012 during our mediation
23
that our visitation exchange would move from his mothers home to Greg and Amy Edwardss
24
home. That agreement was made verbally because Jason refused to include it in our written
25
26
1
2
3
mediation agreement. Although unwritten, I was able to file proof of that agreement with the
court in the form of a declaration from Mrs. Edwards indicating that she received a call from me
while we were in mediation on December 8th, 2012, and our visitation exchange has taken place
at her home since December 9th. We have met there regularly to pick up and drop off Hunter,
although when we mutually agree to meet elsewhere (such as a store closer to Jasons home), we
have done visitation exchanges elsewhere. I have not agreed to go back to his mothers home,
8
9
10
From my prospective, the location of our pick ups and drop offs needed to change
because there had been too many hostile interactions at Jasons mothers house. Tyler, our older
son, is living there. In September 2012 when I was there to drop off Hunter, Tyler became angry
11
and hit my car. In addition, Jasons family has indicated to me that I am not welcome at the
12
home as indicated in Deborah Bergmans declaration regarding serving Jason Shipman with an
13
14
15
16
17
ex parte restraining order in July 2012. I do not feel comfortable, safe, or wanted at Jasons
mothers house, and I do not think it is a good place for the visitation exchange for Hunters
sake.
Although we had agreed to an exchange at Mr. and Mrs. Edwards home, Jason on his
18
own has apparently decided to change the exchange location back to his mothers home. I
19
believe he has made this decision maliciously, and it certainly was not agreed upon by both
20
parties. After Spring Break 2012, Jason started changing where he would decide to show up for
21
22
the exchange. Occasionally he would meet me at the Edwards as agreed, and occasionally he
would go to his mothers home, act surprised that I wasnt there, and threaten to shorten or limit
23
my visitation time if I didnt agree to his mothers home as the exchange location at that
24
moment.
25
26
1
2
3
Spring break began on Friday, March 29. Under our parenting plan, I had blunter the first
Yz, and Easter (March 31). As has been our practice for the last few years, I assumed Spring
Break included the weekend before and after. Because I thought it was my visitation time, I
allowed Hunter to spend the night of the 29th at a friends. Apparently, Jason disagreed with my
assessment of the weekend schedule. He arrived at the Edwards home at around 5:00 p.m., and
was furious to find that Hunter wasnt there. Jason had his wife, Kasey, retrieve Hunter from
Hunters friends home that night. Since Easter was my holiday, I expected to pick up Hunter at
8
9
10
the Edwards Sunday morning. Jason refused to bring him to the Edwards, and forced me to get
Hunter at Jasons mothers home. I took Hunter to the Edwards on Wednesday evening, April
3rd, but Jason didnt come. He demanded that I take Hunter to his mothers home. I could tell
11
that Jason was escalating and was afraid to put myself in an uncomfortable and potentially
12
dangerous situation. Not wanting to deny Hunter time with his dad, I asked my brother, Darren
13
14
15
16
Lund, to take Hunter for me. He did, and has written a declaration documenting the trip. When
Jason wrote those emails on April 3rd, he knew I was at the Edwards home waiting for him.
In keeping with Jasons assessment that Spring Break didnt include the weekends, 1
17
expected to pick up Hunter from the Edwards Friday night, April 5th. I was at the Edwards
18
home at 4:50 p.m., ahead of schedule. Jason texted at 4:54 p.m. saying he would be late, so I
19
wasnt concerned when he hadnt arrived by 5:30 p.m.. Then Jason sent a text at 5:38 p.m.
20
saying that if I wasnt at his mothers home by 6:00, he was going to keep Hunter for the entire
21
22
23
served me at my home. Although they were both there, they didnt take Hunter with them. He
24
was outside with me. Even if they didnt see Hunter, they could have asked where he was and if
25
26
he could go with them. I took Hunter to the Edwards home as soon as Jason and Kasey left
1
2
3
4
because I assumed that was where they were headed. I sent a text at 6:31 p.m., are u coming to
get Hunter? They never showed up.
I went to the Edwards early on Sunday, April 14th, but no one brought Hunter. Hunter
sent me a text after 8:00 p.m. to let me know he was at his grandmas home and his dad had left.
No one was willing to bring Hunter to the Edwards, and I didnt have anyone to go with me.
Jasons family was willing to take him to school the next day, so I allowed him to spend the
night. I reminded Hunter to pack a lunch for the field trip the next day.
10
On Wednesday, April 17th, I sent a text to Jason at 2:08 p.m. to let him know that Hunter
would be at Amys house early and could be picked up any time after 4:00 p.m. Jason did not
11
show up. Instead he sent a text back at 3:20 p.m., you are in violation of the parenting plan.
12
On Friday, April 26th, our visitation exchange took place as normal at the Edwards
13
home. Sunday, April 28th, I went to the Edwards home to pick up Hunter. Again, I received a
14
15
16
text from Hunter saying that he was at his grandmas house. My brother agreed to retrieve him.
On Wednesday, May 1st I went to the Edwards house with Hunter. Jason never came.
17
On Wednesday, May 8th, I had just had surgery and was unable to drive. Mrs. Edwards came to
18
my home to get Hunter and take him to her house to wait for Jason. I texted Jason at 1:05 p.m.
19
to let him know that he could get Hunter early from the Edwards home. Jason never came,
20
although his text back to me confirms that he received my message in plenty of time.
21
22
23
On Friday. May 10th, our visitation exchange took place as normal at the Edwards home.
By then, Jason was living in Puyallup, so Hunter spent the night Sunday night. There was no
exchange on Sunday - Jason made sure Hunter got to school, and then Hunter just came home
24
1
2
Sunday, May 12th was Mothers Day - my designated day per the parenting plan. I
arrived at the Edwards home to get Hunter at 7:45 a.m. At 8:15 a.m., Hunter sent a text stating
that he was at his grandmas house. At 8:20 a.m., Jason sent a text stating that he hadnt heard
from me so he was going to keep Hunter for the rest of the day (even though Mothers Day is
clearly my day). I took a friend with me to Jasons mothers home and retrieved Hunter.
Wednesday, May 15th Hunter and I arrived at the Edwards home on time for the
visitation exchange. Hunter complained, whats the point? He said his father was in Florida
8
9
10
anyway, and wouldnt be able to pick him up. Attached please see Facebook postings from both
Jason and his wife, Kasey, confirming that Jason was in Florida that day.
On Wednesday, May 22nd and Friday, May 24th, our visitation exchanges took place as
11
normal at the Edwards home.
12
The text messages I ve attached show that Jason and I have both been late to visitation
13
14
15
16
attached to this declaration dated May 11, 2013, in a single email Jason both threatened to send
17
me to jail and then stated, i just want us to get along. Over the last few months, visitation
18
exchanges have become much more stressful than they already had been for Hunter. I hope that
19
the court will discourage Jasons erratic and abusive behavior, and deny his motion.
20
21
22
23
24
25
26
9 0 13
Feb 2 7, 2013, 10:40 A M
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him to class? Are
picking hum up there?
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gate to you're apartment?
What's the plan?
M a r 13, 2013, 4:10 PM
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Jennifer,
<You neglected to bring Hunter to visitation on Wednesday
the 8th. I will be asking for a makeup day for that. Also I was
very disturbed to read your deposition.You show no
remorse for the past mistakes.You continue to try and argue
you're side of the things you where found in contempt for.
At this point I think jail is the only thing thats going to
convince you to follow the parenting plan.Therefore i will
be asking the court to sentence you as such. Jen i just want
to get along. Compromise and communicate so Hunter can
have a happy childhood. Please tell me what I can do to get
us pastthis.The more I try to be nice and accommodate you
the more you do things to try and hurt me. Unfortunately
the only one you hurt is poor Hunter.
I will have our son at the designated drop off location, per
our working parenting plan at 8 am Sunday morning.
Mothers Day.
r A M
L [/
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H r V r L A d in ^ u L f c h a n j L -
Show Cause
MARYE DICKE
l o a l f v / n .
Clerk
Q 0 -t 0 >
i d
S' A A
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
June 03 2013 9:22 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
NO. 10-3-00961-1
NOTICE OF APPEARANCE
ntaprsup-0001.pdf
10-3-00961-1
40637504
QFtSC
06-04-13
IN COUNTYFcti*K 'S
office
Oerk
.OEPU
no
Petitioner,
and
lO 'V O M rM
Respondent
3.8
23834
2.6
68848
[]
[]
[]
[}
[]
[3
[]
2.7
6 /4 ^ 2 8 1 3
[]
[]
[]
[)
the residential (visitation) provisions of the parenting plan and had the ability to
comply with the parenting plan, and is currently unwilling to comply. The
noncompliance with the residential provisions [ ] was [ ] was not in bad faith
decision making provisions of the parenting plan and had the ability to comply
with the parenting plan, and is currently unwilling to comply
dispute resolution provisions o f the parenting plan and had the ability to comply
with the parenting plan, and is currently unwilling to comply
Other
3834
6 /^ 2 8 1 3
60841
2.1
2.2
N ature o f O rd er
The order is related to [ ] child support [ ] medical support [ j child care, educational expenses,
transportation expenses, or other special expenses [ ] spousal maintenance flQjarenting plan
(custody/visitalion) [ ] a restraining order.
2.3
H o w the O rd er w a s V iolated
[]
2.4
hJbfadM O M t
<zfo A p rr(M ^
X I A jh d iM u L / V V ? C d f j } U L fU J^
j^ c J h jP i/V '^ e w - d i
2.5
fA
n o r
<ai
tn r r &
(Name)
comply withffthe order as follows.
(Name)
to comply $ith the order as foilowH.
23834
2.8
6 /4 -^ 2 0 1 3
68042
[]
It is Ordered:
3.1
Contem pt Ruling
(Name) A
3.2
Im prisonment
[]
3.3
[]
[]
O ther
3.4
[]
3.5
[]
[]
[]
[]
3.9
3.8
60843
3.7
6^4^2813
3.6
23834
23834
n
LJ
3.10
(Name)
______ __________________ : :---- shall have judgment against
(name)
tn
amount $ _________ ______ *or
attorney fees and $
___________- ^or costs
Other
T K l
0 { jJ J L
M k v f e c h & rn . 0*
Q rrA s D < ^
-K tu b
68844
Review Date
[]
3.11
6^4^2813
W *
w m t
at (time)
/O l't r i.f o q t x h A r c ^
Q n rrJ
of
19^
e^ M f V M 4 i
fiv e , V * * f* * $ .
(hunter dfcf
unM
n f lr .S W y r^ K c
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Tt^eir
Sum m ary of RCW 26.09.430 - .480, Regarding Relocation of a Child f t u f w t h * u > ri|
This is a summary only. For the full text, please see RCW 26.09 430 through 26.09.480
o J r t W - v if r t t n .
If the person with whom the child resides a majority of the time plans to move, that personshall. . , t
give notice to every person entitled to court ordered time with the child.
d u x u t n V t t w w t A j 'v
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 o f the move. The
notice must contain the information required in RCW 26 09 440. See also form DRJPSCU Q |v
*
CAjk
07.0500, (Notice o f Intended Relocation of A Child)
OJ/iAf^TTUUl .
d l< 7 C
rM J b r
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
H
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 umeasonable 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 o f a person or a child at risk.
Failure to give the required notice may be grounds for sanctions, including contempt
I f no o b je c tio n is file d w ith in 3 0 days a f t e r s ervice o f the n o tic e o f in te n d e d re lo c a tio n , th e
re lo c a tio n w ill be p e r m itte d a n d th e proposed revised re s id e n tia l s ch ed u le m a y be
c o n firm e d .
A person entitled to time with a child under a court order can file an objection to the child's
relocation whether or not he or she received proper notice
23834
8 /4 /2 8 1 3
68845
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 safely of a person or a child.
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 off
(2) or
9A 40.070(2). Violation of this order may subject a violat
Dated
O
Presented by:
U s T J jj.
Signature of Party or L^wy<'er/WSBA No
'KfcthnVy,. P r
INCOUNTY.,
ERKS OFFICE
e - f il e :
IN COUNTY CLEF
PIERCE COUNTY, W
June 06 201
KEVIN ST
COUNTY C
NO: 10-3-0
1
2
3
4
5
7
8
9
Petitioner,
10
and
11
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15
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Respondent.
12
13
No. 10-3-00961-1
1. RELIEF REQUESTED
COMES NOW the Respondent JASON SHIPMAN by and through his attorney
DANIEL N. COOK of FAUBION, REEDER, FRALEY & COOK, P.S., and moves the
Court for revision of those provisions of COMMISSIONER MARY E. DICKEs Order on
Show Cause re Contempt entered on May 28, 2013, set forth below:
Page 2, Paragraph 2.1, which provides that Jennifer Shipman did comply with
the court order.
Page 2, Paragraph 2.3, which provides that The order was not violated.
Page 2, Paragraph 2.5, which provides that Jennifer Shipman has the present
willingness to comply with the order.
MOTION FOR REVISION - Page 1 of 6
Lund, Jennifer and Shipman, Jason
S:\CASES1\Shipm an, Jason\D R A FTS \P LE A D IN G S \2013\M otion fo rR e visio n .d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
2
3
apply.
Page 4, Paragraph 3.1, which provides that Jennifer Shipman is not in contempt
4
5
of court.
Page 4, Paragraph 3.3, which provides that Additional Residential Time Does
6
7
not apply
Page 5, Paragraph 3.8, which provides that Conditions for Purging Contempt
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apply.
Page 6, Paragraph 3.11, which provides that: The Court orders that visit
exchanges will now take place on the corner in front of Jason Shipmans mothers home
at 11721 80th Avenue E., Puyallup.
Hunter at the street outside.
visitation exchange times. Justin Shipman can also meet Hunter outside.
2. STATEMENT OF FACTS
The facts are set forth in the submissions for the original hearing. In addition, a
verbatim transcript of the hearing on May 28, 2013, as prepared by Notary Public
Patricia Wood is filed in this case and submitted with this motion.
21
22
23
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
3. EVIDENCE RELIED ON
1
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The evidence relied on is set forth in the submissions for the original hearing. In
addition, a verbatim transcript of the hearing on May 28, 2013, as prepared by Notary
Public Patricia Wood is filed in this case and submitted with this motion..
4. AUTHORITY
The legal authority relied on for bringing this Motion for Revision is set forth in
RCW 2.24.050, PCLR 7(a)(11) and the Superior Court Civil Rules for the State of
Washington. This motion is timely filed within 10 days of entry of the order from which
the motion arises.
A revision before a judge of a court commissioners ruling is a matter of right. The
revision of the commissioners ruling is de novo on the record, requiring the judge to
review the entire case and determine its own facts, rather than to review a
commissioners order to determine its reasonableness. State v Ramer, 2004 WL
438964 (Wash., Mar 11, 2004); State v. Wicker, 105 Wn. App. 428, 433, 20 P.3d 1007
(2001); In re Marriage of Balcom, 101 Wn. App. 56, 1 P.3d 1174 (2000); In re Marriage
of Moody, 137 Wn.2d 979, 976 P.2d 1240 (1999).
De novo means afresh, anew and hearing de novo means trying matter
anew the same as if it had not been heard before and as if no decision had been
previously rendered. Blacks Law Dictionary, Sixth Ed., West Publishing Co., 1990.
The revision courts power of review is essentially unlimited. In re Dependency
of B.S.S., 56 Wn.App. 169, 171, 782 P.2d 1100 (1989); In re Welfare of McGee, 36
Wn.App. 660, 679 P.2d 933 (1984). The revision court has full jurisdiction over the
case and is authorized to determine its own facts based on the record before the
MOTION FOR REVISION - Page 3 of 6
Lund, Jennifer and Shipman, Jason
S:\CASES1\Shipm an, Jason\D R A FTS \P LE A D IN G S \2013\M otion forR e visio n .d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
2004).
This traditional standard of review was called into question by a 2003 Division
2
3
4
5
6
Supreme
Court,
however,
has
subsequently
rejected
the
Lown
interpretation:
On revision, the superior court reviews both the commissioners
findings of fact and conclusions of law de novo based upon the
evidence and issues presented to the commissioner. [FN9]
7
8
9
10
State v Ramer, 2004 WL 438964 (Wn. Sup. Ct., Mar 11, 2004). Thus, the Washington
11
Supreme Court has ended any dispute about the standard of reviewit is de novo.
12
De novo review also applies to findings based on oral testimony, as well as those
13
based on written testimony. See State v. Charlie, 62 Wn. App. 729, 730, 815 P.2d 819
14
(1991) (oral testimony taken; holding superior court erred by limiting review of findings
15
of fact); In re Welfare of Smith, 8 Wn. App. 285, 286, 505 P.2d 1295 (1973) (same);
16
State ex ref Biddingerv. Griffiths, 137 Wash. 448, 242 P.2 969 (1926) (same).
17
de n o vo
18
19
conclusion that the parenting plan should be modified without any legal basis to
20
do so.
21
motion for clarification before the court, and even if there were there is no ambiguity to
22
23
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
be resolved.
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responsibilities of the parties as it relates to the parenting plan and as such was a
modification of the parenting plan, without meeting the statutory requirements for
modification of the parenting plan.
RCW 26.09.260 sets for very detailed and specific requirements for modification
of parenting plans, including a finding that there has been a substantial change in
circumstance since entry of the last parenting plan.
parenting plan generally relate to the transportation arrangements, which is a nonresidential aspect of the parenting plan and RCW 26.09.260(10) specifically requires a
substantial change in circumstances and a finding that the change is in the best interest
of the child before a change can be made. No findings related to a substantial change
or the best interest of the child were made. Furthermore, because there was no open
Petition to Modify the moving party in the contempt action did not have a full and fair
opportunity to prepare and defend a parenting plan modification action.
RCW
26.09.270 sets forth a threshold requirement that a finding of adequate cause be made
before any modification of a parenting plan may be granted and requires affidavits and
notice of the request for a change.
followed and none of the requisite findings to support a modification were made.
Indeed, there is not even an open Petition for Modification. For all of these reasons the
modification of the parenting plan was improper.
The Commissioner declined to make a finding of contempt and instead
improperly changed the exchange requirements of the parenting plan.
There is no
findings made by the Commissioner to explain why the Mothers failure to follow the
MOTION FOR REVISION - Page 5 of 6
Lund, Jennifer and Shipman, Jason
S:\CASES1\Shipm an, Jason\D R A FTS \P LE A D IN G S \2013\M otion fo r Revision.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
parenting plan was not contempt. The court simply indicates that it was not contempt
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FAUBION, REEDER,
FRALEY & COOK, P.S.
5920100th Street SW, Suite 25
Lakew ood, W A 98499
2 5 3 -5 8 1 -0 6 6 0
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
June 06 2013 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
T r a n s c r ip t o f P r o c e e d in g s
R e:
S h ip m a n v . S h ip m a n
P age 1 o f 25
COMMISSIONER:
. . . swear or affirm to tell the truth and nothing but the truth?
FEMALE:
Yes.
MALE:
Thank you.
COMMISSIONER:
PRICE:
7
8
LUND:
Jennifer Lund.
PRICE:
Is Ms., Ms. Lund now but Shipman per the court record.
10
SHIPMAN:
11
COMMISSIONER:
12
PRICE:
13
COMMISSIONER:
(Unintelligible).
14
PRICE:
15
completely my error that it didnt get to the court, um, I realized my mistake
16
yesterday and ran out there and had her sign it and it has been filed. I left a
17
copy for Mr. Shipman, um, on his doorstep, it looks like he did receive it, I
18
19
20
COMMISSIONER:
21
PRICE:
22
COMMISSIONER:
. . . (unintelligible).
T r a n s c r i p t o f P r o c e e d in g s
R e:
S h ip m a n v . S h ip m a n
P age 2 o f 25
SHIPMAN:
Its, its repetitive from what she already said, I have no problem with it.
COMMISSIONER:
SHIPMAN:
Nope.
COMMISSIONER:
Okay.
SHIPMAN:
Not at all.
COMMISSIONER:
All right.
PRICE:
Okay.
COMMISSIONER:
Thank you, so Mr. Shipman just indicate what youre here for
(unintelligible) here for?
9
10
SHIPMAN:
Um .. . weve had issues with the drop off location for my son .. . shes
11
been to Court several times to try to change i t . . . its the best place, um, this
12
13
(unintelligible). . . this is one of the times she tried to change i t . .. she, ah,
14
15
PRICE:
Your Honor.
16
SHIPMAN:
. . . ex parte . . .
17
PRICE:
18
COMMISSIONER:
It has (unintelligible). . .
19
SHIPMAN:
Its in there.
20
COMMISSIONER:
Youre limited so . . .
21
(Unintelligible)
22
COMMISSIONER:
Transcript of Proceedings
Re: Shipman v. Shipman
Page 3 of 25
SHIPMAN:
Ah, I believe it was in my first statement. . . wed gone to Court, its, she
complained about me missing Pierce County on one of the forms.
2
3
COMMISSIONER:
Yeah, th at. . .
SHIPMAN:
Then I talked about her filing . .. Court like three times I can, came here
with King County documents so Im not sure why . . . me missing one lines
COMMISSIONER:
Well (unintelligible) all I can say is you need to . . . stay in the, the confines
of what you (unintelligible).
8
SHIPMAN:
I was just trying to show that weve gone over this issue numerous times . . .
10
COMMISSIONER:
So . . .
11
SHIPMAN:
. . . in Court.
12
COMMISSIONER:
13
SHIPMAN:
Shes not showing up at the designated, ah . . . drop off location, shes tried
14
15
judges have heard her argument and said, no, this is the location, this is
16
where its going to be, um, I have bent over backwards to try to
17
accommodate her so a few times I did agree to meet here there then she
18
wanted me to meet her in a parking lot, um, she provided some emails here
19
where shes chopped out parts of the conversation that include me sitting in
20
a parking lot for hours on end waiting for her when she is supposedly just a
21
few minutes down the street, ah, in the meantime these are school nights, at
22
least at my parents home, which is a very safe place for everyone, ah,
Transcript of Proceedings
Re: Shipman v. Shipman
Page 4 of 25
Hunter can, you know, thats where we agreed, um, she alleges that there is a
police report indication where theres some unsafety, that is an argument that
she had with our oldest son, whose now eighteen, she showed up there not
for a visitation exchange cause my parents have, because of the issues with
her and her animosity towards anyone and everyone that talks to me
rule, during the time that Jennifer drops . . . Hunter off, nobody is to be
outside, everybody comes in, they sit in there and they wait for her . . . I
dont, I try not to be there until hes there, I have . .. changed my residence
10
11
12
PRICE:
13
SHIPMAN:
more .. .
14
PRICE:
15
SHIPMAN:
Shes ju s t. . .
16
PRICE:
. . . (unintelligible). . .
17
SHIPMAN:
18
PRICE:
. . . documents (unintelligible).
19
COMMISSIONER:
(Unintelligible). . .
20
SHIPMAN:
21
COMMISSIONER:
22
PRICE:
U m .. .
Transcript of Proceedings
Re: Shioman v. Shipman
Page 5 of 25
COMMISSIONER:
PRICE:
Thank you, Your Honor and much of what, ah, is in . . . Ms. Lunds
her visitation and I dont know if your Court, if the Court remembers seeing
these, there are . . . new ones from May that werent included in her previous
Declaration.
SHIPMAN:
time . .. you can see where she just wrote it o u t.. . and its very inaccurate.
8
9
COMMISSIONER:
10
11
SHIPMAN:
I do.
12
COMMISSIONER:
. . . if you . . .
13
SHIPMAN:
hi...
14
COMMISSIONER:
15
SHIPMAN:
And I did.
16
COMMISSIONER:
. . . to this reply.
17
PRICE:
18
COMMISSIONER:
Well I . ..
19
PRICE:
20
SHIPMAN:
Yeah, its . . .
21
PRICE:
22
SHIPMAN:
Its inaccurate.
T r a n s c r ip t o f P r o c e e d in g s
Re:
S h ip m a n v . S h ip m a n
P age 6 of 25
COMMISSIONER:
Well thats your opinion, you certainly can make that argument. ..
SHIPMAN:
Okay.
COMMISSIONER:
SHIPMAN:
COMMISSIONER:
Okay, go ahead.
PRICE:
Okay.
COMMISSIONER:
PRICE:
Thank you, Your Honor . . . um . . . Ms. Lund documented days when she
arrived at the Edwards home, thats where in mediation, um, Ms. Lund and
10
11
SHIPMAN:
(Unintelligible)
12
PRICE:
T hat. . .
13
COMMISSIONER:
14
SHIPMAN:
Im sorry.
15
COMMISSIONER:
.. . finish.
16
PRICE:
And, and this is documented in a declaration that was filed some time ago,
17
um, by Mrs. Edwards . . . that there was a phone call from the mediation in
18
December, um, Ms. Lund asked could we use your home as a place where
19
20
um, and has and indicated in her declaration that thats been taking place
21
regularly, now Ms. Lund agrees that its not always been at the Edwards,
22
that theres been other times when theyve agreed to other places and theres
Transcript of Proceedings
Re: Shipman v. Shipman
Page 7 of 25
text mes, messages that indicate that theres been an agreement to other
places and thats not a violation of the parenting plan because it clearly
states, unless otherwise agreed by the parties, um, but at that mediation, the
parties did agree that the regular . . . exchange location would be at the
Edwards.
COMMISSIONER:
7
8
PRICE:
No.
COMMISSIONER:
. .. (unintelligible).
10
PRICE:
No, Your Honor, according to the declaration that was just filed, um . . .
11
COMMISSIONER:
Okay, so . . .
12
PRICE:
. . . Ms. Lund wrote . .. that was not put in writing because Mr. Shipman
13
14
h a s.. .
15
(Unintelligible)
16
PRICE:
17
when the exchange didnt take place at the Edwards. And Mr. Shipmans
18
argument is that theres no other place thats safe for Hunter and that he has
19
to sit in a parking lot but hes able to sit in the Edwards home . . . um . . .
20
this is a, a mutual family friend . . . ah, a place where Ms. Lund feels safe,
21
um, and . . . I know that the Court hasnt had an opportunity to read the
22
declaration but, um, this . . . worked until April when there was a
T r a n s c r ip t o f P r o c e e d in g s
R e:
S h ip m a n v . S h ip m a n
P age 8 o f 25
disagreement about. . . visitation during spring break, Ms. Lund gave into
what Mr. Shipman wanted for spring break, he wanted, um . . . the first
she did, that wasnt her understanding from their past practices, in the past
theyd had visitations from the first weekend through the middle of Spring
Break and then . . . the other half of Spring Break included the . . . last
weekend, um . . . but when she realized that that was not his understanding
she said, oh, well hes at a friends house . . . Mr. Shipmans wife went and
10
retrieved . . . um . . . Hunter from the friends house and took him over night
11
12
COMMISSIONER:
Okay.
13
PRICE:
. . . . and since . . .
14
COMMISSIONER:
(Unintelligible).
15
PRICE:
. . . then . . .
16
COMMISSIONER:
I mean although this is for contempt. . . I mean the, main, main goal is to
17
have this worked out for the future .. . Mr. Edwards didnt, I mean Mr. . . .
18
Shipman denies that, um, that the Edwards was a location that was agreed
19
upon even though apparently hes said . . . he on occasion has agreed to it.
20
PRICE:
W hen.. .
21
COMMISSIONER:
Transcript of Proceedings
Re: Shipman v. Shipman
Page 9 of 25
PRICE:
Well, Your Honor, Ms. Lund simply doesnt feel safe . . . at this home, you
saw from the Declaration, um, from Debra, what was the last name?
2
3
LUND:
Bergman (spelling?).
PRICE:
Bergman about the challenges that she encountered when she tried to serve
Mr. Shipman .. . there and the family was relatively hostile to her . . . um . . .
but other family members who are there, um, and its just not healthy for
Hunter to continuously see that animosity . . . um, she . . . prefers, um, the
Edwards home because theres not that animosity and he is safe there if one
10
parent wants to drop him off and leave . .. and have the other parent come
11
12
SHIPMAN:
Weve argued this in Court several times . . . she cannot prove any of the
things shes . . . the incident shes discussing . . . she w ent. . .
13
14
COMMISSIONER:
15
SHIPMAN:
Mr. . . .
. .. there on her own, made an arrangement to meet my son, who shes been
in Court with . . . with police involvement, they . . .
16
17
COMMISSIONER:
(Unintelligible) . . .
18
SHIPMAN:
. . . have an issue . ..
19
COMMISSIONER:
20
SHIPMAN:
My . . .
21
COMMISSIONER:
T r a n s c r ip t o f P r o c e e d in g s
R e:
S h ip m a n v . S h ip m a n
P a g e 10 o f 2 5
SHIPMAN:
I just moved . . . to be close to this drop off location . . . the last time I
she, everything shes done . . . has been very vindictive . . . Ive sent her an
email saying . . . on April 1st, Ive provided it to you, that I did not agree to
in Court numerous . ..
COMMISSIONER:
So where . . .
SHIPMAN:
. . . times.
COMMISSIONER:
SHIPMAN:
My parents home is absolutely a safe place for her . . . nobody goes out
10
11
12
COMMISSIONER:
How far . ..
13
SHIPMAN:
. . . need to go in.
14
COMMISSIONER:
15
SHIPMAN:
The Edwards, the other issue with the Edwards home is its not only is it not
16
a mutual place, this is a friend of hers, thats very hostile towards me, but
17
they are very . . . they have a huge family with a ton of kids . .. and they
18
arent home, the police have said . . . numerous times, you need a third
19
party . ..
20
PRICE:
Your Honor.
21
SHIPMAN:
. . . exchange.
22
PRICE:
I have no documents . . .
T r a n s c r ip t o f P r o c e e d in g s
R e:
S h i p m a n v . S h ip m a n
P a g e 11 o f 2 5
SHIPMAN:
This is not a .. .
PRICE:
. . . (unintelligible).
SHIPMAN:
.. . third .. .
COMMISSIONER:
5
6
SHIPMAN:
Theres a . . .
COMMISSIONER:
this.
10
SHIPMAN:
Exactly.
11
(Unintelligible)
12
COMMISSIONER:
13
SHIPMAN:
14
15
COMMISSIONER:
Okay.
16
SHIPMAN:
. . . love to have my mother come in and discuss that. . . if you look in those
police reports, she has offered her home up, her home is absolutely safe.
17
18
COMMISSIONER:
Okay.
19
SHIPMAN:
But thats .. .
20
COMMISSIONER:
21
SHIPMAN:
22
COMMISSIONER:
(Unintelligible).
Transcript of Proceedings
Re: Shipman v. Shipman
Page 12 of 25
SHIPMAN:
COMMISSIONER:
Ju st. ..
SHIPMAN:
. . . for her.
COMMISSIONER:
SHIPMAN:
And the . . .
COMMISSIONER:
.. . (unintelligible).. .
SHIPMAN:
. . . last time we . . .
COMMISSIONER:
. .. McDonalds .. .
SHIPMAN:
.. . had a . . . .
10
COMMISSIONER:
11
SHIPMAN:
I cant speak . . .
12
COMMISSIONER:
. .. (unintelligible).
13
SHIPMAN:
14
COMMISSIONER:
15
PRICE:
16
SHIPMAN:
Ah, shes a t . . .
17
PRICE:
18
SHIPMAN:
. . . school.
19
PRICE:
20
21
COMMISSIONER:
22
SHIPMAN:
Shes a (unintelligible).
Transcript of Proceedings
Re: Shipman v. Shipman
Page 13 of 25
COMMISSIONER:
(Unintelligible)
ENDS 10:32:32
FEMALE:
(Unintelligible)
FEMALE:
(Unintelligible)
SHIPMAN:
Yes, I got a hold of her, um . . . and shes always been willing to help any
10
way she can, she has suggested possibly Hunter being dropped off on the
11
comer by her home, so he can just walk across the street . . . I have her
12
13
COMMISSIONER:
14
FEMALE:
Twelve.
15
FEMALE:
Twelve.
16
SHIPMAN:
17
COMMISSIONER:
(Unintelligible)
18
PRICE:
Do you have an objection to, the concern I guess that we would have is what
if for some unknown reason there wasnt anybody home?
19
20
SHIPMAN:
Hunter has a key to the home, I have two brothers and sisters that live there
21
. .. my father is a City, ah, employee, hes home, theres a, thats the reason
22
both busy, they make sure Sierra or Justin, theres always somebody there
for Hunter and he knows how to get into the home . . . in addition, I just
moved a block and a half away . . . its, its . . . this, weve argued this in
COMMISSIONER:
going to work for Hunter cause this is, you know, obviously the parties are
SHIPMAN:
And thats why I agreed to try Greg and Amys . . . and tried the parking lot,
Ive tried .. . everything I can to get along and, and Ive .. .
9
10
COMMISSIONER:
(Unintelligible)
11
SHIPMAN:
12
COMMISSIONER:
13
PRICE:
Um, Your Honor, Ms. Lunds concern would be, um, if no ones allowed to
14
come outside, how could she be sure when shes dropping him off that there
15
is someone there . . . to care for him, shes not entirely comfortable with him
16
17
SHIPMAN:
(Unintelligible) he . ..
18
PRICE:
. . . could perhaps . . .
19
SHIPMAN:
.. . comes (unintelligible).
20
PRICE:
21
COMMISSIONER:
22
SHIPMAN:
He comes . . .
T r a n s c r ip t o f P r o c e e d in g s
R e:
S h ip m a n v . S h ip m a n
P a g e 15 o f 2 5
COMMISSIONER:
. .. (unintelligible).
SHIPMAN:
COMMISSIONER:
SHIPMAN:
. . . empty house with a house with a key, I will make sure he has a key to
the house.
5
6
COMMISSIONER:
Well how about your mom comes out and just meets them . . .
(unintelligible).
7
8
SHIPMAN:
Thats fine.
COMMISSIONER:
At the comer.
10
SHIPMAN:
Absolutely.
11
PRICE:
12
COMMISSIONER:
13
SHIPMAN:
14
PRICE:
112th and. . .
15
SHIPMAN:
. . . moms house.
16
PRICE:
.. . 80th?
17
SHIPMAN:
18
PRICE:
Im n o t.. .
19
SHIPMAN:
20
FEMALE:
21
SHIPMAN:
And again, you can call my mom and discuss it with her if youd . . .
22
COMMISSIONER:
I cant . . .
. . . 116th, I want to say, its right outside of her home . . . across the street.
T r a n s c r ip t o f P r o c e e d in g s
Re:
S h ip m a n v . S h ip m a n
P a g e 16 o f 2 5
SHIPMAN:
. . . like.
COMMISSIONER:
SHIPMAN:
Oh, Im sorry.
COMMISSIONER:
Well Im gonna order that, I mean . . . we got to work this out and
SHIPMAN:
COMMISSIONER:
(Unintelligible).
SHIPMAN:
10
mom but shes a special ed. teacher . . . um, she deals with kids with autism
11
12
13
14
be there to meet.
15
PRICE:
And Your Honor, Ms. Lund has, um, one last concern . . . um, that I believe
16
we could deal with, um . . . her son, Tyler, has been aggressive in the past
17
and is often at the grandmas house . .. um, hes filed a declaration saying he
18
doesnt live there, if Tyler could not be there at the regular pick up and drop
19
off times then that could hopefully avoid the, he did hit her car, came out
20
angry and . ..
21
LUND:
And th at. . .
22
PRICE:
. . . was . . .
T r a n s c r ip t o f P r o c e e d in g s
R e:
S h ip m a n v . S h ip m a n
P a g e 17 o f 2 5
LUND:
. .. was at the . . .
PRICE:
LUND:
. .. corner.
PRICE:
At the . . .
LUND:
(Unintelligible) house.
PRICE:
.. . comer . ..
SHIPMAN:
She alleged.
PRICE:
. .. previously.
COMMISSIONER:
Okay regardless . . .
10
PRICE:
So . . .
11
COMMISSIONER:
. . . Tyler n o t. . .
12
SHIPMAN:
Tyler. . .
13
COMMISSIONER:
. . . be there.
14
SHIPMAN:
. .. wont be there.
15
PRICE:
Okay.
16
SHIPMAN:
17
the house, Tyler wont be there, Ill just make sure hes not there. Thats no
18
problem. Hes . . .
19
PRICE:
Okay.
20
SHIPMAN:
. . . moved out and hes got his own job and stuff now.
21
COMMISSIONER:
Okay, so Tyler . . .
22
SHIPMAN:
Transcript of Proceedings
Re: Shipman v. Shipman
Page 18 of 25
COMMISSIONER:
. .. wont (unintelligible).
SHIPMAN:
.. . anyway.
PRICE:
Okay.
COMMISSIONER:
5
6
PRICE:
Okay.
SHIPMAN:
And then also, um . . . would it be possible to get makeup time for all of the
days that I missed?
8
9
COMMISSIONER:
No, I just want to, basically try to change this so it works .. . well in the
future.
10
11
SHIPMAN:
Okay and . . . if theres issues with her not showing up and . .. and . . .
12
COMMISSIONER:
(Unintelligible).. .
13
SHIPMAN:
. . . ah, me n o t. . .
14
COMMISSIONER:
. . . (unintelligible).
15
SHIPMAN:
16
COMMISSIONER:
17
SHIPMAN:
Just do it again?
18
COMMISSIONER:
Yeah.
19
(Unintelligible)
20
SHIPMAN:
Okay.
21
UNKNOWN:
22
SHIPMAN:
Oh, my . . .
T r a n s c r ip t o f P r o c e e d in g s
R e:
S h i p m a n v . S h ip m a n
P a g e 19 o f 25
UNKNOWN:
(Unintelligible). . .
SHIPMAN:
. .. wife.
UNKNOWN:
. . . is coming . . .
COMMISSIONER:
(Unintelligible).
UNKNOWN:
.. . (unintelligible).
COMMISSIONER:
7
8
SHIPMAN:
9
10
COMMISSIONER:
No.
11
SHIPMAN:
12
(Unintelligible)
13
COMMISSIONER:
No.
14
SHIPMAN:
15
(Unintelligible)
16
ENDS 11:03:36 AM
17
18
(Unintelligible)
19
UNKNOWN:
20
(Unintelligible)
21
PRICE:
. . . (unintelligible).
Transcript of Proceedings
Re: Shipman v. Shipman
Page 20 of 25
SHIPMAN:
No, I agree with everything other than just adding my brother and sisters to
be able to one of the ones.
PRICE:
Okay.
(Unintelligible)
COMMISSIONER:
SHIPMAN:
COMMISSIONER:
SHIPMAN:
Oh.
COMMISSIONER:
. . . record.
10
SHIPMAN:
11
COMMISSIONER:
Okay.
12
SHIPMAN:
Just wanted to try to hinder a possible future problem . . . ah, this home is
13
14
15
house out in Graham, my parents and him are talking and considering living
16
in the other ones house for a little while to, during the winter . . . so their
17
closer for the school stuff and switching back, so I simply wanted to add my
18
brother, Justin, sister, Stacy, or sister, Sierra, who will be living in that home
19
20
T r a n s c r ip t o f P r o c e e d in g s
R e:
S h ip m a n v . S h ip m a n
P a g e 21 o f 2 5
COMMISSIONER:
wouldnt want to . . .
SHIPMAN:
Okay.
COMMISSIONER:
. .. do i t . . .
SHIPMAN:
Thats fine.
COMMISSIONER:
.. .just add anybody and anyone to be doing this, ah, (unintelligible) let me
just hear the response.
8
9
10
SHIPMAN:
COMMISSIONER:
No, Im saying, youre indicating that they may switch residences . . . thats
11
a whole different story, they physically move o u t. . . and live in the other
12
13
(unintelligible). . .
14
SHIPMAN:
Theyre gonna . . .
15
COMMISSIONER:
. . . (unintelligible).
16
SHIPMAN:
. . . try it this summer .. . its, ah, theyre going to do it this summer and try
17
18
19
COMMISSIONER:
(Unintelligible).. .
20
SHIPMAN:
. . . brothers are . . .
21
COMMISSIONER:
. . . (unintelligible). . .
22
SHIPMAN:
. . . always there.
Transcript of Proceedings
Re: Shipman v. Shipman
Page 22 of 25
COMMISSIONER:
. . . response.
PRICE:
Your Honor, um, to simplify matters, Ms. Lund . . . thought that the brother
that was being addressed was a different brother, she has no issue with, um,
Justin, is it Justin . . .
SHIPMAN:
Correct.
PRICE:
not he lives there, as one of the people who can meet him at the comer,
thats fine.
COMMISSIONER:
Okay.
10
SHIPMAN:
11
COMMISSIONER:
(Unintelligible).
12
(Unintelligible)
13
PRICE:
14
SHIPMAN:
Yeah.
15
PRICE:
16
(Unintelligible)
17
PRICE:
Youre gonna sign as the party, so youre not the lawyer, youre just
(unintelligible).
18
19
(Unintelligible)
20
PRICE:
And then . . .
21
SHIPMAN:
(Unintelligible).
22
PRICE:
Transcript of Proceedings
Re: Shipman v. Shipman
Page 23 of 25
(Unintelligible)
SHIPMAN:
COMMISSIONER:
(Unintelligible).
SHIPMAN:
Ah, its . .. just (unintelligible) to chase him around and getting to see him,
its gonna be great.
5
6
(Unintelligible)
COMMISSIONER:
(Unintelligible) everyone.
PRICE:
(Unintelligible)
10
PRICE:
11
(Unintelligible)
12
UNKNOWN:
13
(Unintelligible)
14
ENDS 11:21:20
15
*****e n d
Were at recess.
o f p r o c e e d i n g s ****
16
Transcript of Proceedings
Re: Shipman v. Shipman
Page 24 of 25
1
2
3
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5
6
7
CERTIFICATIO N OF TRANSCRIPTION
State of Washington
County of Pierce
I, Patricia Wood, declare under the penalty of perjury under the laws of the State of
8
9
)
) ss.
)
Washington that the following is true and correct to the best of my knowledge and belief.
10
11
I certify that I am over eighteen years of age and not a party to this action.
12
I prepared the foregoing transcript from a CD of a proceeding that took place on May 28, 2013
13
regarding the above captioned matter and consists of the twenty-four (24) pages.
14
15
16
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^ .M O O D
' \ . f rAT O*
T r a n s c r ip t o f P r o c e e d in g s
R e:
S h ip m a n v . S h ip m a n
P age 25 o f 25
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
June 06 2013 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
Please take notice that the undersigned will bring on for hearing a motion for:
Pierce County Superior Court, County-City Building - 930 Tacom a Ave S - Tacoma, W A 98402
Motion - Revision
Calendar: FAMILY COURT - 2
9:00 AM
W O RKING COPIES SHALL BE DELIVERED TO THE COURT PURSUANT TO PCLR 7 (a) (7)
PARTY SETTING HEARING SHALL CONFIRM BY NOON TWO COURT DAYS PRIOR TO HEARING
Submitted by:
DATED:
June 5, 2013.
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
W SBA#:
34866
LAKEWOOD, WA 98499-2751
For:
1 of 1
24218
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448205
III
10-3-00961-1
40706996
ORFR
06-28-13
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No. 10-3-00961-1
Petitioner,
13
A gnsez)
ORDER MOTION FOR REVISION
and
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FAUBION, REEDER,
FRALEY & COOK, P.S.
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dfpt
IN OPEN C 0 U R l\
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JUN 2 8 2013
Presented by:
FAUBION, REEDER, FRALEY & COOK,
Approved by:
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Notice of presentation w a \e ^
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FAUBION, REEDER,
FRALEY & COOK, P.S.
2 42"Z S
10-3-00961-1
40790750
CME
7 '1
y201
,3
07-01-13
10-3-00961-1
Petitioner(s)
vs
Page 1 of 2
FILED
DEPT. 8
IN OPEN CO U R T
Respondent(s)
Judge/Commissioner BRIAN TOLLEFSt
Court Reporter TIMOTHY REGIS
Judicial Assistant/Clerk Brian Matson
JUN 2 8
DEPUTY,
Kathrme Price
Attorney for i
Daniel N Cook
SHIPMAN, TYLER
SHIPMAN, HUNTER
2013
IN
T H E
S U P E R IO R
C O U R T , P IE R C E
C O U N T Y , W A S H IN G T O N
vs
JASON WILLIAM SHIPMAN
Page 2 of 2
Judge/Commissioner
BRIAN TOLLEFSON
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
July 03 2013 3:07 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
Please take notice that the undersigned will bring on for hearing a motion for:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
Motion
Nature of Hearing: Other TO CORRECT SCRIVENERS ERROR
Calendar: FAMILY COURT - 2
9:00 AM
WORKING COPIES SHALL BE DELIVERED TO THE COURT PURSUANT TO PCLR 7 (a) (7)
PARTY SETTING HEARING SHALL CONFIRM BY NOON TWO COURT DAYS PRIOR TO HEARING
Submitted by:
DATED:
July 3, 2013.
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
LAKEWOOD, WA 98499-2751
1 of 1
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHING'
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
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7
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
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and
13
J A S O N W IL L IA M S H IP M A N
Respondent.
14
I. M o tio n
15
T h e undersigned m oves the court for an order correcting scriveners error. T h e
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Agreed O rder Motion for Revision entered on June 28, 2 0 1 3 , contains a scrivener's error
at P ag e 2, Lines 17-25.
At the tim e the A greed O rder w as entered, it w as agreed by and betw een the
20
parties that Mr. S hipm an would pick up the child on Friday, which is A ugust 1 6 th. T h e
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22
D A T E D thi
day of July 2 0 1 3 .
23
24
Daniel N. Cook, W S B A 3 4 8 6 6
O f Attorneys for R esponden t
25
Error.docx
Scrivener'S
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
10-3-00961-1
40864038
CME
07-15-13
Cause Number: 1 0 -3 -0 0 9 6 1 -1
Petitioner(s)
vs.
Page 1 of 2
DEPUw
SHIPMAN, JENNIFER KAY
Kathrine Price
Daniel N Cook
SHIPMAN, TYLER
SHIPMAN, HUNTER
IN T H E S U P E R IO R C O U R T , P IE R C E C O U N T Y , W A S H IN G T O N
JENNIFER KAY SHIPMAN
vs.
Page: 2 of 2
Judge/Commissioner:
BRIAN TOLLEFSON
MINUTES OF PROCEEDING
Court Reporter:TIMOTHY REGIS
1 c?'-s*. V: - i L
10-3-00961-1
40664039
07-15-13
OR
4
5
FILED
DEPT. 8
IN OPEN COURT
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JUL 12 2013
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
\B y
N.
In re th e M a rriag e of:
N o. 1 0 -3 -0 0 9 6 1 -1
J E N N IF E R K A Y S H IP M A N ,
n /k /a J E N N IF E R K A Y L U N D
Petitioner
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and
14
J A S O N W IL L IA M S H IP M A N
Respondent.
y
deputy /
-----------
O R D E R O N M O T IO N T O C O R R E C T
S C R IV E N E R S E R R O R
15
R E S P O N D E N T , J A S O N W IL L IA M S H IP M A N , having presented a motion for o rd er to
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correct scriveners error to this court. T h e court having considered the motion, testim ony
and th e court file, and finding good cause, It is O rdered.
T h e A greed O rd er Motion for Revision entered on June 28, 2 0 1 3 , contains a scriveners
20
21
read as follows:
22
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Order correcting Scriveners error - Page 1 of 2
S :\C A S E S 1 \S h ip m a n , J a s o n \D R A F T S \P L E A D IN G S \D is s o \O rd e r C o rre c tin g S c riv e n e r's
E rm r.d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
253-581-0894
1
This corrected order shall have the full force and effect and sam e rights and
2
3
4
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Presented by:
8
9
FA U B IO N , R E E D E R , FR A LE Y
& C O O K , P.S.
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A R IE L N. CO O K, W S B A # 3 4 8 6 6
O f Attorneys for Respondent
aJ.
CJUl
H R IN E P ty C E , W S B A # 44389
Attorney for Petitioner
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Brwr-doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
253-581-0894
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
No. 10-3-00961-1
COUNTY CLERK
Petitioner(s)
Vs.
Track Assignment:
Assignment Department:
Docket Code:
Notice of Adequate Cause & Note for Comm Cal filed w/Petition or no later than
Confirmation of Service
Modification of Custody
AREN
ORSCS
2/10/2015
2/24/2015
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 BRIAN TOLLEFSON
4/7/2015
4/7/2015
4/7/2015
6/9/2015
4/7/2015
6/30/2015
7/14/2015
7/28/2015
Week of 9/8/2015
9/15/2015
9/29/2015
10/13/2015 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/PETITIONER
If the case has been filed, the plaintiff shall serve a copy of the Case Schedule on the defendant(s) with the summons and complaint/
petition: Provided that in those cases where service is by publication the plaintiff shall serve the Case Schedule within five (5) court days
of service of the defendant's first response/appearance. If the case has not been filed, but an initial pleading is served, the Case Schedule
shall be served within five (5) court days of filing. See PCLR 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.
Dated: February 3, 2015
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
February 03 2015 11:50 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
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
Show Cause
Nature of Hearing: Parenting Plans, Restraining Orders
Calendar: Show Cause/Family Law
9:00 AM
February 3, 2015.
Signed:
NAME:
Phone:
(253) 686-3971
WSBA#:
For:
1 of 1
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
February 03 2015 12:06 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
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
Show Cause
Nature of Hearing: Parenting Plans, Restraining Orders
Calendar: Show Cause/Family Law
9:00 AM
February 3, 2015.
Signed:
NAME:
Phone:
(253) 686-3971
WSBA#:
For:
1 of 1
rv'i
OJ
J'fihiivfW Wtu
Liuv|
O
ip
no
Petitioner,
and
ID-3-CW UH
A c c e p ta n c e o f S e rv ic e
(A C S R )
O cjon UTilhawi
1.
A c c e p ta n c e o f S e rv ic e
C o n s e n t to P e rs o n a l J u ris d ic tio n
* MT#F
O th e r
Dated: t i l
IS
Y .'r h U /A
ature of Party or Lawyer /WSBA No. Accepting Service
Print or Type Name
Notice to party: You may list an address that is not your
residential address where you agree to accept legal documents.
Any time this address changes while this action is pending,
you must notify the opposing parties in writing and file an
updated Confidential Information Form (WPF DRPSCU
09.0200) with the court clerk.
[Address]
- V
rOi
OJ1
10-3-00961-1
44069309
C * F F* E
FEB 03
N o. 1 0 -3 -0 0 9 6 1 -1
Petitioner,
and
Jason Shipman
S u m m o n s (M o d ific a tio n /
A d ju s tm e n t o f C u s to d y
D e c re e /P a re n tin g P la n /
Respondent.
R e s id e n tia l S c h e d u le )
(S M )_________________________________
To.
Jennifer Lund
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.
v
[x]
[]
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:
6.
http://www.courts.wa.gov/forms
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.
One method of serving a copy of 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 4.1 of the state of Washington.
Dated: -3 ,^
/ S ____________
Print Name
F ile o r ig in a l o f y o u r r e s p o n s e w ith
S e rv e a c o p y o f y o u r re s p o n s e on.
t h e c le r k o f t h e c o u r t a t
'~5cjc} G ^
[Name]
[Address]
[Address]
SC\
___________
F IL E D
N '
^fcK
PIERCE COUNTYSUPERIORCOURT
KEVINSTOCK
CLERKOF THESUPERIORCOURT
TACOMAfcJA
III
,
10-3-00961-1
44069310
02-04-15
$PTMDG
FILED
FEB 0 3 2015
10-3-00961-1
p .m.
ftcpt. Date
02/03/2015
(M
n
U)
Receipt/Ites it Tran-Code
2015-03-01029/01 1104
Cashier: MLR
Paid By: shipman, jason
Transaction Ainount:
UT
Petitioner,
and
0-1
Respondent.
e
1.1
<p o 9 < / ~ /
N o.
L iSW ^
f\
Acct, Date
Time
02/03/2015 10:43 AM
Name (first/last)
P&'zGcn
P'
Name (first/last)____________________;_____________
~KC>
___________ .
Birth date
Name (first/last) _
'/-f s /
_ Birth date.
Docket-Code
tFFR
$56.00
1.3
D e p e n d e n t C h ild re n
Name (first/last)
H u W / tV '
Age
Name (first/last)
_Age
Name (first/last)
Age
Name (first/last)
Age
Name (first/last)
Age
Name (first/last)
Age
'
2.1
II. B a s is
This is a petition for an order modifying the prior custody decree/parenting plan/residential
schedule/judgment establishing parentage and approving my proposed parenting plan/residential
schedule, which is filed with this petition.
2 .2
A d e q u a te C a u s e
C h ild S u p p o rt
2 .4
J u ris d ic tio n a n d V e n u e
2 .5
J u ris d ic tio n O v e r P ro c e e d in g
This court has jurisdiction over this proceeding for the reasons below:
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.
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 - - ^
'J v ' - *
.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:
.
|~1
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.
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.
.
2 .6
Other:
Name of Child
Parents Name
Parents Name
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 list their
present addresses in the Confidential Information Form. Do not list the other party.):
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):
Ul
/vr^
'a .-
[U
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):
T'i
CU
U\
2 .7
H
O
C u s to d y D e c re e o r P a re n tin g P la n /R e s id e n tia l S c h e d u le
cA ~-
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.
The childrens environment under the custody decree/parenting plan/residential
schedule is detrimental to the childrens physical, mental or emotional health and
the harm likely to be caused by a change in environment is outweighed by the
advantage of a change to the children.
2.9
/
The other party has been found in contempt of court at least twice within three A
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.
2 .1 0
2.11
i I
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.
2 .1 2
A d ju s tm e n ts to N o n re s id e n tia l P ro v is io n s U n d e r R C W 2 6 .0 9 .2 6 0 (1 0 )
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:
0
0
0
0
Dispute resolution.
Decision making.
Transportation arrangements.
Other:
2 .1 3
S u b s ta n tia l C h a n g e in C irc u m s ta n c e
c l n '/ i
h f c t,
dfi-e* d t ^
i*l
c \r < fv ih y
2 .1 4
;s
n /r'
S e tte e )
v u * i * tj j /o
v jo W
P ro te c tio n O rd e r
If you need immediate protection, contact the clerk/court for RCW 26.50 Domestic
Violence forms or RCW 10.14 Antiharassment forms.
2 .1 5
S e r v ic e m e m b e r s C iv il R e lie f A c t S ta te m e n t
is not on active duty in the U.S. armed forces (excluding National Guard and
reserves);
is not on active duty and is a National Guard member or a Reservist residing in
Washington;
lam unable to determine whether the other party is or is not on active duty in the
U.S. armed forces;
lam unable to determine whether the other party is or is not on active duty as a
National Guard member or a Reservist residing in Washington.
B. Factual basis:
See the attached Department of Defense Manpower Data Center Status Report
Pursuant to Servicemembers Civil Relief Act (SCRA) obtained from
https://www.dmdc.osd.mil/appi/scra/. (You must have the persons social
security number to search in this site.)
Other factual basis:
c.
As indicated above, the other party is on active duty and (check all that apply):
The other party is represented by an attorney.
The court has appointed an attorney to represent the other party.
A stay of these proceedings has has not been entered by the court.
2.16
Other
111. R e lie f R e q u e s te d
(A
The moving party requests that the court find that there is adequate cause for hearing this petition arid 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.
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:
*
if
i*;
Date
Date
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
j (state)
______ on (date)
___.
Print Name
Signed at (city) ______________________ , (state)__________on (date)__________________ .
Signature of Requesting Party
Print Name
J o in d e r
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.
1waive notice of entry of the decree.
n \
I demand notice of all further proceedings in this matter. Further notice should be sent to
the following address (you may list an address that is not your residential address where
you agree to accept legal documents):
Any time this address changes while this action is pending, you must notify the opposing parties
in writing and file an updated Confidential Information Form (WPF DRPSCU 09.0200) with the
court clerk.
Date
Signature
Print Name
I demand notice of all further proceedings in this matter. Further notice should be sent to
the following address (you may list an address that is not your residential address where
you agree to accept legal documents): .
Any time this address changes while this action is pending, you must notify the opposing parties
in writing and file an updated Confidential Information Form (WPF DRPSCU 09.0200) with the
, court clerk.
, /
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.
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
tr
WITTMO
10-3-00961-1
02-04-15
44069312
FEB 0 3 2015
p.m.
I'M
f"';
Ui
N o . 1 0 -3 0 0 9 6 1 -1
Jenifer Lund
CJ
Petitioner,
and
Jason Shipman
M o tio n a n d D e c la ra tio n fo r
T e m p o r a r y O rd e r
(M T A F )
Respondent.
I. M o tio n
Based on the declaration below, the undersigned moves the court for a temporary order which:
[]
[]
[x]
[]
[]
[x]
[]
[]
[]
restrains or enjoins [ ] petitioner [ ] respondent from assaulting, harassing, stalking or molesting the
other party or the children, or using attempting to use, or threatening to use physical force against
the other party or the children that would reasonably be expected to cause bodily injury, or
engaging in other conduct that would place the other party in reasonable fear of bodily injury to the
other party or children. (If the court orders this relief, the restrained person may be prohibited
from obtaining or possessing a firearm, other dangerous weapon, concealed pistol license, or
ammunition under state or federal law for the duration of the order.)
[j
[J
[]
[]
[]
[]
[j
[]
[]
(If th is b o x is checked yo u m ust com plete paragraph 2.3 in the declaration below.)
requires the [ ] petitioner [ ] respondent to surrender any firearm, other deadly weapon, and
concealed pistol license in his or her immediate possession or control or subject to his or her
immediate possession or control to the sheriff of the county having jurisdiction of this proceeding,
to his or her lawyer or to a person designated by the court.
restrains or enjoins the [ ] petitioner [ ] respondent from removing any of the children from the
state of Washington.
restrains or enjoins the [ ] petitioner [ ] respondent from assigning, transferring, borrowing,
lapsing, surrendering or changing entitlement of any insurance policies of either or both parties
whether medical, health, life or auto insurance.
makes each party immediately responsible for their own future debts whether incurred by credit
card or loan, security interest or mortgage.
divides responsibility for the debts of the parties.
authorizes the family home to be occupied by the [ ] petitioner [ ] respondent.
orders the use of property.
requires the [ ] petitioner [ ] respondent to vacate the family home.
requires the [ ] petitioner [ ] respondent to pay temporaiy attorney fees, other professional fees and
costs in the amount of $___
___ to:
[x]
[]
other:
Si
No.
Print or Type Name
II. D e c la ra tio n
rty or Lawyer/WSBA
2.1
T lie .
C.U. ) d
iw
rtm kx!
tiw A .
P h ///C ^ f
e /~
~\ h e -
1d
i 5
f o r < y
1-0
O c tr e e
2.2
[]
2.3
[]
If the surrender of firearms, other deadly weapons, and concealed pistol license is
requested, please explain (check and complete all that apply):
[]
Has the other party used, displayed, or threatened to use a firearm or other
dangerous weapon in a felony? Describe:
[]
Has the other party previously committed an offense that makes him or her
ineligible to possess a firearm under the provisions of RCW 9.41.040? Describe:
[]
2.4
[]
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
j, (state)
Do n o t attach fin a ncia l records, p e rsonal health care records o r co n fidential reports to
th is declaration. Such records s h o u ld be served on the o th e r p a rty and file d w ith the
co u rt using one o f these co ve r sheets:
1) Sealed Financial Source Docum ents (WPF DRPSCU 09.0220) fo r financial records
2) Sealed Personal Health Care R ecords (WPF DRPSCU 09.0260) fo r health records
3) Sealed C onfidential R eport (WPF DRPSCU 09.270) fo r confidential reports
If file d separately using a co ve r sheet, the records w ill be sealed to p ro te c t y o u r p riva cy
(although they w ill be available to a ll parties in the case, th e ir attorneys, co u rt personnel
and certain state agencies and boards.) See GR 22(C)(2).
FILED
INOPENCOUR'f
TPROTSC
10-3-00961-1
x
El! PARTE DEP.ASTislEW?
02-*'15
44069322
FEB 0 3 2015
PIERCE COUNTS Clark
A
j2^L
DEWY
No. (O
Petitioner,
and
~y<=t'?Or1
3^ 7'
^Respondent.
O o *? 6 /
E x P a rte R e s tra in in g O rd e r/
O rd e r to S h o w C a u s e
(T P R O T S C /O R T S C )
Restraining Order'Summary:
[ ] Does not apply.
[ ] Restraining Order Summary is set forth below:
Name of person(s) restrained:
person(s) protected:
H Uw4
rV /
>
icisyt A
Q
. Name of
See p a ra g ra p h 4.1.
Violation o f a R estraining O rder in paragraph 4.1 below w ith actual knowledge o f its
term s is a c rim in a l offense u n d e r Chapter 26.50 RCW and w ill su b je ct the violator to
a rre s t RCW 26.09.060.
i. S h o w C a u s e O rd e r
It is Ordered th^p^Lpetitioner [ ] respondent appear and show cause, if any, why the restraints below
should not be continued in full force and effect pending final determination of this action and why the other
relief, if any, requested in the motion should not be granted. A hearing has been set for the following date,
time and place:
N
*")
Time:
MWdR/ rJiAf . T -^z0a // 5
i / SUPERjQft COURT
CQiiR1
Place: _____*
Room/Department:
r o ptJUif.
If you disagree wit$
ofidie[nfiff&Tiijiyou must respond to the motion in writing before the
hearing and by the dil^&^ihiWAu6 gQ0ty. At the hearing, the court will consider Written sworn
affidavits or declarations. Oral testimony may Not be allowed. To respond you must: (1) file your
documents with the court; (2) provide a copy of those documents to the judge or commissioners
staff; (3) serve the other partys attorney with copies of your documents (or have the other party
served if that party does not have an attorney); and (4) complete your filing and service of documer
within the time period required by the local court rules in effect in your county. If you need more
information, you are advised to consult an attorney or a courthouse facilitator.
Date:
Failure to appear m ay result in a Temporary Order being entered b y the co u rt that grants
the re lie f requested in the m o tio n w ithout fu rther notice.
II. B a s is
A motion for a temporary restraining order without written or oral notice to the^petitioner
[ ] respondent or that partys lawyer has been made to this court.
^
III.
F in d in g s
The court adopts paragraphs 2.1, 2.2, and 2.4 of the Motion/Declaration for an Ex Parte Restraining Order
and for an Order to Show Cause (Form WPF DR 04.0150) as its findings, except as follows:
[]
Further, the court finds that the nonrequesting party is absent and a) is on active duty as a National
Guard member or Reservist residing in Washington, or b) is a dependent of a National Guard
member or Reservist residing in Washington on active duty. Despite the service members or
dependents absence, failure to enter the temporary orders below would result in manifest injustice
to the other interested parties.
IV .
O rd e r
It is Ordered:
4.1
R e s tra in in g O rd e r
Violation o f a R estraining Order in paragraph 4.1 with actual notice o f its terms
is a crim inal offense u nder Chapter 26.50 RCW and w ill su bject the violator to
arrest. RCW 26.09.060.
[]
i H
Clerk's A ction. The clerk of the court shall forward a copy of this order, on or before
the next jud<cUl^blrfto (ame^>fjthfe apgrapnate law enforcement agency)
_______ {Jj&sivlAfi. i / v / which shall enter this order into any
computer-based criminal intelligence system available in this state used by law
enforcement agencies to list outstanding warrants. (A law enforcement information
sheet must be completed by the party or the partys attorney and provided with
this order before this order will be entered into the law enforcement computer
system.)
Service
The requesting 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.
Full Faith and Credit
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.
4 .2
O th e r R e s tra in in g O rd e rs
[]
[]
[]
CHk
c f4 -
4 .3
S u rre n d e r o f F ire a rm o r o th e r D a n g e ro u s W e a p o n s
[]
[]
4 .4
E x p ira tio n D a te
This order shall expire on the hearing date set forth above or 14 days from the date of issuance,
which ever is sooner, unless otherwise extended by the court.
Ex Parte Restraining Ord (TPROTSC/ORTSC) - Page 3 o f 4
WPF DR 04.0170 Mandatory (6/2014) - CR 65 (b); R C W 26.09.060
4 .5
W a iv e r o f B o n d
Date
M i
K jD
,
,
10-3-00961-1
44071636
CME
EX
02-04-15
FILED
OPEN COURT
PARTE DEPARTMENT
FEB 0 3 2015
PIERCE MWTV, Clerk;
vBy
k pu t T
Kathrine Price
Daniel N Cook
SHIPMAN, TYLER
SHIPMAN, HUNTER
1 0 -3 -0 0 9 6 1 -1
F E B R U A R Y 3, 2 01 5 09:21 A M - R E S P O N D E N T JASON S H IP M A N A P P E A R S B E FO R E TH E
C O U R T W IT H A R E Q U E S T FO R AN E X P A R TE R E S T R A IN IN G O R D E R . T H E C O U R T W ILL
C O N S ID E R T H E R E Q U E S T A F T E R A P E T IT IO N TO M O D IF Y IS FILED.
10:54 A M - BACK O N TH E R E C O R D . C O U R T R E Q U IR E S N O T IC E A N D D IR E C T S
R E S P O N D E N T TO C S D -R O O M 140 TO HAVE CALL PLACED.
11:12 A M - BACK O N T H E R E C O R D . P E T IT IO N E R J E N N IF E R S H IP M A N IS N O W
P R E S E N T . BOTH P A R TIE S A R E S W O R N . C O U R T R E V IE W S JIS. 11:12 A M - O P E N IN G
S T A T E M E N T BY R E S P O N D E N T A B O U T SO N E X C E S S IV E A B S E N C E FRO M S C H O O L. 11:13
A M - C O U R T IN Q U IR E S W H E N BOTH P A R TIE S P A R TIC IP A TE D IN M E D IA TIO N . 1 1 :15 A M R E S P O N S E BY P E T IT IO N E R E X P LA IN IN G S O N S A B S E N C E . 11:17 A M - C O U R T O R D E R E D
THAT:
NO C H A N G E IN C U S T O D Y
T H E P A R TIE S A R E TO P A R TIC IP A TE IN M E D IA TIO N P E N D IN G H E A R IN G
C H ILD TO BE E N R O LLE D IN C O U N S E L IN G IM M E D IA TE LY , BOTH P A R E N TS TO
P A R T IC IP A TE
BO TH P A R E N TS A R E TO C O M M U N IC A T E BY T E X T M E S S A G E S ; NO B LO CKING OF
TEXT M ESSAGES
H E A R IN G TO BE S C H E D U L E D FO R M A R C H 4TH
11:23 A M - M O T H E R A G R E E S TO A C C E P T S E R V IC E IN C O U R T.
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHING
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
5
6
7
8
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
10
11
12
13
and
14
No. 10-3-00961-1
Petitioner,
15
16
MOTION
17
COM ES NOW the Respondent, JASON SHIPMAN, by and through his attorney of
18
record, Daniel N. Cook, of FAUBION, REEDER, FRALEY & COOK, P.S., and respectfully
19
moves the Court for an Order Continuing the show cause hearing set for March 4, 2015,
20
21
22
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
1
D E C L A R A T IO N
2
My name is Daniel Cook and I am the attorney of record for the Respondent
3
4
5
hearing on the motion for March 4, 2015. An Ex Parte Restraining Order was issued on
February 3 as well, which ordered the parties to attend mediation before the hearing. At
this time, the parties have not been able to attend mediation, nor is one scheduled.
10
11
12
13
I request that the hearing in this matter be continued to March 31 to allow the
14
parties to attend mediation, and for me to prepare for a hearing if the parties do not
15
16
17
18
19
20
21
22
23
24
25
Motion for Order to Continue Hearings- Page 2 of 2
Lund, Jennifer and Shipman, Jason
S:\CASES1\Shipman, Jason\DRAFTS\PLEADINGS\Motion to Continue Hearing.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, WASHING
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
5
6
7
8
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
10
11
12
13
and
14
No. 10-3-00961-1
Petitioner,
15
16
MOTION
17
COM ES NOW the Respondent, JASON SHIPMAN, by and through his attorney of
18
record, Daniel N. Cook, of FAUBION, REEDER, FRALEY & COOK, P.S., and respectfully
19
moves the Court for an Order Continuing the show cause hearing set for March 4, 2015,
20
21
22
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
1
D E C L A R A T IO N
2
My name is Daniel Cook and I am the attorney of record for the Respondent
3
4
5
hearing on the motion for March 4, 2015. An Ex Parte Restraining Order was issued on
February 3 as well, which ordered the parties to attend mediation before the hearing. At
this time, the parties have not been able to attend mediation, nor is one scheduled.
10
11
12
13
I request that the hearing in this matter be continued to March 31 to allow the
14
parties to attend mediation, and for me to prepare for a hearing if the parties do not
15
16
17
18
19
20
21
22
23
24
25
Motion for Order to Continue Hearings- Page 2 of 2
Lund, Jennifer and Shipman, Jason
S:\CASES1\Shipman, Jason\DRAFTS\PLEADINGS\Motion to Continue Hearing.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
March 02 2015 10:35 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
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 Tacom a Ave S - Tacoma, W A 98402
Show Cause
Nature of Hearing:
9:00 AM
DATED:
March 2, 2015.
Signed:
Daniel N Cook
Phone:
(253) 581-0660
NAME:
W SBA#:
34866
Attorney for Respondent
LAKEWOOD, WA 98499-2751
For:
1 of
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHING!
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
5
6
7
8
9
10
11
12
No. 10-3-00961-1
13
and
14
Petitioners Notice of
Hearing for Adequate Cause
Determination
(Optional Use)
(NTHG)
[ ] Clerks Action Required
15
_________________________ Respondent.
16
To th e C le rk o f C o u rt a n d to. J e n n ife r L u n d
17
1.
18
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
19
20
2.
A hearing has been set for the following date, time and place.
21
Date: April 9, 2015
Time: 9:00 a.m.
Place: Pierce County Superior Court Room/Department: TBD
22
23
3.
24
1
4.
You may serve and file a response and opposing declarations prior to the hearing
2
date. If the court determines that adequate cause for hearing the petition is
3
established by the declarations, it will set a date for hearing on an order to show
5.
appearance, an order may be entered without further notice to you finding you in
10
11
Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
March 04 2015 11:55 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
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
9:00 AM
DATED:
March 4, 2015.
Signed:
Daniel N Cook
Phone:
(253) 581-0660
NAME:
WSBA#:
For:
34866
Attorney for Respondent
LAKEWOOD, WA 98499-2751
1 of
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHING!
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
5
6
7
8
9
10
11
In re:
JENNIFER KAY SHIPMAN
n/k/a JENNIFER KAY LUND,
No. 10-3-00961-1
Petitioner,
DECLARATIO N OF M AILING
and
12
13
14
15
16
17
18
19
20
21
Jennifer Lund
2323 7th St SE U101
Puyallup, W A 98374
22
23
I declare, under the penalty of perjury and the Laws of the State of Washington,
that the foregoing is true and correct.
24
DATED
March 4, 2015
S 'A
25
-<___________
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660