John Alika Kalii JR vs. Beth Ann Kalii 14-3-01646-7
John Alika Kalii JR vs. Beth Ann Kalii 14-3-01646-7
No. 14-3-01646-7
ORDER ASSIGNING CASE TO
JUDICIAL DEPARTMENT
D ocket Code: A S T
In accordance w ith PC LR 40(d), this case is hereby assigned to D epartm ent 12, Judge S T E P H A N IE A. AR E N D .
Notice to Petitioner:
O nce the case has been filed, the petitioner(s) shall serve a copy o f this O rder A ssigning Case to Judicial
D epartm ent on the respondent(s) w ith the sum m ons and petition. Provided, how ever, th a t in those cases w here
service is by publication the p etitioner shall serve a copy o f this O rde r A ssigning Case to Judicial D epartm ent
w ithin five (5) court days o f service o f the respondent's first response/appearance. If the case has not been filed,
but an initial pleading is served, a copy o f th is O rde r A ssigning Case to Judicial D epartm ent shall be served w ithin
five (5) court days o f filing. PC LR 1(b).
Trial Date:
A trial date m ay be obtained pursuant to PC LR 40(d) by filing a 'N ote o f Issue' fo r assignm ent o f a trial date by
noon at least six (6) court days prior to the date fixed fo r assignm ent o f the trial date. PC LR 40(d)
If a trial date is not obtained pursuant to PC LR 40(d), failure to app ea r on th is date w ill result in d ism issal o f
the case by the C ourt. PC LR 40(d)
A t th a t tim e the C ourt w ill provide you w ith a Case S chedule w hich shall include the trial date. Failure to
app ea r on this date w ill result in d ism issal o f the case by the C ourt. PC LR 40(d).
Certificate of Completion of Mandatory Parenting Seminar due from both parties by 06/24/2014. See
PCLSPR 94.05(c). https:\\www.co.pierce.wa.us\pc\services\lawjust\parentingseminars.htm
Uncontested Dissolutions/Settlements:
If this case is agreed upon by both petitioner(s) and respondent(s) w ho are represented by attorneys, you are not
required to w a it fo r the trial date in o rd e r to settle yo u r case; after appropriate tim e requirem ents have been met,
final pleadings m ay be presented in E x Parte. If you are s e lf represented and settle yo u r case and the
appropriate tim e requirem ents have been met, you m ay file a Note fo r Pro S e /S e lf R epresented D issolution
C ale nd ar to appear before a C ourt C om m issio ne r fo r entry o f final papers.
42414217
14-3-01646-7
CICS
04-23-14
14 3 01646 7
Case Title____________________________________ Case Number^_________________________________________
Atty/Litigant \T < Q 4 r fr l
Address^
City_
a) l l \
K A~
K A i-l*
\ A J / U 6 f J - A r N S T-
3/tV
#__________ Phone_______________________ _
____________________________
Zip
Please check one category that best describes this case for indexing purposes.
Ifyou cannot determine the appropriate category, please describe the cause o f action below . This will create a
Miscellaneous cause which is not subject to PCLR 3.
DOMESTIC RELATIONS
ADOPTION / PATERNITY
DISSOLUTION
Of Marriage with Child (D1C 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
____Invalidity (INV 3) FAM LAW
____Invalidity Domestic Partnership (INP 3) FAM LAW
____Child Custody (CUS 3) CUSTODY
____Parenting Plan / Child Support (PPS 3) FAM LA W
DOMESTIC RELATIONS
_ _ _ Foreign Judgment Domestic (FJU 3)Non PCLR
____Modification of Custody (MDC 3)Mod of CUSTODY
____Modification of Support Only (MDS 3) Non PCLR
___ Reciprocal, In County (RIC 3) Non PCLR
___ Reciprocal, Out of County (ROC 3) Non PCLR
___ Committed Intimate Relationship (CIR) FAM LAW
___ Mandatory Wage Assignment (MSC 3) Non PCLR
___ .Out of State Custody (MSC 3) Non PCLR
MISCELLANEOUS
Revised 09/01/2011 Fillable
F I LEU
ft
I. j
o
o
14-3-016467
42414221
SM
04-23-14
14-3-01646-7
IN COUNTY c t i ^ K 'S OFFICE
a .m
8
o
Jj 10
\.+
JJ 12
,+
APR2 2 201^
pm
o:)
Acct, Date
Tima
04/22/2014 11:28 AM
14
In re the Marriage of:
No.
Summons
(SM)
16
if)
Rcpt, Me
04/22/2014
Petitioner,
18
14 3 01646 7
and
20
22
24
26
1.
28
30
The petitioner
requesting:
has
started an action
in the
above
court
32
34
be
36
Additional requests, if any, are stated in the petition,
copy of which is attached to this summons.
38
40
42
44
2.
Summons (SM)
WPF DR 01.0200 Mandatory (6/2008)
CR 4.1
Page 1
$290=[
2
4
6
8
10
12
3.
14
16
18
20
4.
22
24
26
28
5.
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.
6.
7.
30
32
34
36
38
40
42
44
46
Summons (SM)
WPF DR 01.0200 Mandatory (6/2008)
CR 4.1
Page 2
2
4
Dated:
10
12
14
16
18
20
22
24
26
28
30
32
34
36
38
40
42
44
46
Summons (SM)
WPF DR 01.0200 Mandatory (6/2008)
CR 4.1
Page 3
14-3-01646-7
42414223
PTDSS
04-23-14
PH.
E lg C f COUNTY, WASHINGTON
KEVIN STOCK, County Clerk
ri 10
C)
('\i
---- *-------DEPUTY
12
14
16
In re the Marriage of:
No.
18
John Alika Kalii, Jr.
Petitioner,
20
and
22
Beth Ann Kalii
Respondent.
24
14 3 01646 7
I. Basis
28
1.1
Identification of Petitioner
30
32
34
1.2
36
Identification of Respondent
38
1.3
40
[ j
42
[X]
44
46
48
50
Name
Name
Name
Name
Name
Does not apply. There are no children dependent upon either or both
spouses.
The petitioner and respondent are both the legal (biological or
adoptive) parents of the following dependent children:
(first/last) Ka1ena Makani Kalii
(first/last) ___________________
(first/last)
_______
(first/last) ___________________
(first/last)
Age
Age
Age
Age
Age
7 years
[ ]
The petitioner is and the respondent is not the legal parent of the
following dependent children:
4
6
[ ]
The respondent is and the petitioner is not the legal parent of the
following dependent children:
Name
Name
10
12
14
1.4
16
This marriage is irretrievably broken.
18
20
1.5
22
24
2009 at Haleiwa,
26
[ ]
[ ]
Other:
28
30
32
34
1.6
36
Separation
[ ]
[X]
38
40
42
44
46
1.7
Jurisdiction
48
50
[X]
[X]
[X]
4
6
[X]
8
[ ]
10
[ ]
12
This
court
respondent.
does
not
have
jurisdiction
over
the
14
16
1.8
Property
20
22
[ ]
24
[X]
18
26
[ ]
the
parties'
[ ]
the
parties'
[X]
28
30
32
34
36
38
40
42
1.9
44
[ ]
46
48
Pet for Disso of Marriage (PTDSS)
WPF DR 01.0100 Mandatory (12/2012)
RCW 26.09.020
Page 3
[X]
4
[ ]
[ ]
8
10
12
14
[X]
16
[X]
18
1.10
Maintenance
20
22
[X]
[ ]
[ ]
Other:
24
26
28
1.11
30
32
[X]
[ ]
34
[ ]
36
38
40
[ ]
46
48
Other:
42
44
2
4
[ ]
[ ]
Other:
6
8
10
12
14
16
18
1.12
Protection Order
[X]
[ ]
20
22
[ ]
24
26
28
30
32
34
1.13
Pregnancy
36
38
[X]
[ ]
[ ]
Other:
40
42
44
46
2
4
1.14
[X]
[ ]
[X]
10
12
14
16
[X]
18
20
22
[ ]
24
[ ]
26
[ ]
28
30
32
[X]
34
36
38
40
42
44
[ ]
46
48
2
[X]
[ ]
10
12
[ ]
[ ]
4
6
8
14
16
18
20
22
24
26
28
30
32
[ ]
Other:
34
1.15
36
38
40
[ ]
[X]
42
Names of Children
44
Ka1ena Makani Kalii
46
48
Pet for Disso of Marriage (PTDSS)
WPF DR 01.0100 Mandatory (12/2012)
RCW26.09.020
Page 7
2
4
6
8
[X]
10
[ ]
12
16
18
20
[X]
14
22
[ ]
24
26
28
30
32
Claims to custody or visitation;
34
[X]
36
38
[ ]
40
42
44
46
48
Pet for Disso of Marriage (PTDSS)
WPF DR 01.0100 Mandatory (12/2012)
RCW 26.09.020
Page 8
2
4
Involvement
children;
in
any
other
proceeding
concerning
the
6
[X]
8
[ ]
10
12
14
16
Other legal proceedings concerning the children.
18
[X]
20
[ ]
22
24
26
1.16
Other
28
30
32
II. Relief Requested
34
36
38
[ ]
40
[X]
42
[X]
44
46
[ ]
[X]
[ ]
48
Pet forDisso of Marriage (PTDSS)
WPF DR 01.0100 Mandatory (12/2012)
RCW 26.09.020
Page 9
[ ]
[
[
[
[
]
]
]
]
8
[X]
10
12
14
[ ]
16
[ ]
18
20
22
or Lawyer/WSBA No.
24
26
28
30
32
34
36
38
40
42
44
46
48
[ ]
Joinder
I, the respondent, 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.
2
4
[ ]
[ ]
6
8
10
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.
12
14
16
[ ]
18
20
22
24
26
28
30
32
34
36
38
Dated: _________________________
40
_______________________
Signature of Respondent
Beth Ann Kalii_________
Print or Type Name
42
44
46
48
Pet forDisso of Marriage (PTDSS)
WPF DR 01.0100 Mandatory (12/2012)
RCW 26.09.020
Page 11
2
4
Exhibit A
6
The petitioner shall be awarded the following community and/or separate
property, and shall be ordered to pay the following community and/or
separate debts and liabilities:
8
10
12
14
2006
Ford
F150,
VIN
1FTRX14W16NB00322, and
all
debts
associated with said vehicle;
2009 Yamaha XVI95VGY, VIN JYAVP21E99A007281, and all debts
associated with said vehicle.
16
18
20
22
24
26
28
30
32
34
36
OTHER PROPERTY:
38
Living room furniture;
All property currently in the petitioner's possession, unless
otherwise awarded to the respondent;
All life insurance policies in the petitioner's name only, of
which the petitioner is the owner;
100% of the petitioner's Tacoma Fire Department LEOFF2
retirement account;
accounts in the petitioner's name only
40
42
44
46
Exhibit A
Page 1
4
6
name
OTHER DEBTS:
Mastercard debt;
Lowes debt;
Target debt;
All debts incurred by the petitioner after the date of the
parties' separation, March 30, 2014;
All other debts in the petitioner's name only.
10
12
14
The respondent shall be awarded the following community and/or separate
property, and shall be ordered to pay the following community and/or
separate debts and liabilities:
16
18
20
22
2000 Dodge Durango and all debts associated with said vehicle.
24
OTHER PROPERTY:
26
28
30
32
34
36
OTHER DEBTS:
38
Credit card debts in the respondent's name only;
Personal loans in the respondent's name only;
All debts incurred by the respondent after the date of the
parties' separation, March 30, 2014;
All other debts in respondent's name only.
40
42
44
46
Page 2
The petitioner and the respondent shall jointly be awarded the following
property and shall jointly be ordered to pay the following debts and
liabilities:
2
4
and
10
12
OTHER DEBTS
14
16
The petitioner and the respondent have previously divided all remaining
property and debts to the satisfaction of both parties.
18
20
Effective date:
22
24
26
28
30
32
34
36
38
40
42
44
46
Exhibit A
Page 3
Nothing Follows
A M.
APR22 2014
P.M.
6
8
10
12
14
No.
1 4 3 01 646 7
16
18
and
20
Respondent.
Notice: State and federal law provide protections to defendants/respondents who are in the military
service} and to their dependents. This notice only pertains to a defendant/respondent who is a dependent of
a member of the National Guard or a military reserve component under a call to active service under state
or federal authority, for a period of more than thirty (30) consecutive days. Other defendants/respondents
in military service also have protections against default judgments not covered by this notice. Dependents
o f a service member are the service members spouse, a service members minor child, or an individual for
whom the service member provided more than one-half of the individuals support for one hundred eighty
days (180) days immediately preceding an application for relief.
One protection provided is the protection against the entry o f a default judgment in certain circumstances.
If you are the dependent o f a member of the National Guard or a military reserve component under a call to
active service under state or federal authority, for a period of more than thirty (30) consecutive days, you
should notify the plaintiff/petitioner or, if the plaintiff/petitioner is represented by an attorney, the
plaintiff/petitioners attorney in writing of your status as such within twenty (20) days of the receipt of this
notice. If you fail to do so, then a court or an administrative tribunal may presume that you are not a
dependent o f an active duty member of the National Guard or reserves under state or federal authority, and
proceed with the entry o f an order of default and/or a default judgment without further proof of your status.
Your response to the plaintiff/petitioner or plaintiff/petitioners attorney about your status does not
constitute an appearancejof^ttris^lictional purposes in any pending litigation, a waiver o f your rights or a
response to the petitioifi, compj^int-th^other application for relief that was filed against you.
42
>
44
Dat
/ / / ^
re o f Petitioner
J
*4
r
2
4
14-3-01646-7
42414234
APRS
04-23-14
a m.
APR 22 20W
p .m.
8
10
12
14
16
No.
18
20
and
22
Petitioner,
14 3 01646 7
Respondent.
24
26
28
The undersigned enters an appearance in this action, and demands notice of all
further proceedings.
The Clerk of the Court and the opposing party will be
informed of any change in address.
Any notices may be sent to [You may list an
address that is not your residential address where you agree to accept legal
documents.]
30
Service Addr e s s :
32
Washington
98498
34
36
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.
38
40
42
44
46
48
Notice of Appearance (APRS)
WPF DRPSCU 01.0320 (6/2006)
Page 1
AM
APR
2014
22
--------------------
PM.
.DEPUTY
J'oHAsJ
A f l K *
K A L -ll
Financial Declaration
fcj Petitioner
[ ] Respondent
(FNDCLR)
Petitioner,
and
Bertf'-
kAL/i '
Respondent.
Name:
fcA L
A U K A
14 3 01646 7
No.
; O X
Date of Birth:
it j
fl
/*7f e -
$ ____________
$ _____________
$ ____________
$ _____________
Estimate of the other partys gross monthly income (from 3.1 f below)
[ ] $ ____________
[ ] unknown
Occupation:
2.2
2.3
^ r / ^ P
(1)
/ i i
i t
of
-fh c o N i/k
fiff
p fP T
/4
Where do you work. Employer's name and address must be listed on the
Confidential Information Form.
Li i
b. If no:
LJ
(2)
(1)
(2)
(3)
12L/Z#_i2r
s
frrr(KEp>
-X
III. Income Information
Aj
.+
If child support is at issue, complete the Washington State Child Support Worksheet(s), skip Paragraphs 3.1 and 3.2.
If maintenance, fees, costs or debts are at issue and child support is Not an issue this entire section should be
completed. (Estimate of other partys income information is optional.)
3.1
hLi}
3.2
Name
a.
sV , 3 6 Z -
b.
$ __________
c.
Business Income
$ __________
$ ___________
d.
cto
3*7
From____________________________
$ ___________
e.
Other Income
$ ___________
f.
g-
$ ___________
Income Taxes
b.
FICA/Self-employment Taxes
%__________
c.
$ __________
d.
$ __________
e.
$ __________
f.
$ __________
s_______
g.
$ ___________
s 3o^> o ^
s 2-s
h.
3 o 5 . o
s 7-or. 7 3
V 3 - 1 K
3.3
[
j
^ 5
3.4
Miscellaneous Income
a.
b.
c.
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
/Z 3
r o o . C~u
5.1
5.2
Housing
Rent, l st mortgage or contract payments
Total Housing
f
^
Utilities
Heat (gas & oil)
Electricity
1 7 ' <f-Q
5.3
5.4
//V. ft/
$ 3 Z o .o o
Cable
t jL 3 3 _ L . S C
Total Utilities
$ r3 C , t / c
$ __________
$ __________
Other
$ __________
Children
Day Care/Babysitting
$ __________
Clothing
s_______ -<S
$
- < *> ^
5.5
,cr &
/6 - &
Transportation
% 6*1
5.6
5.7
Parking
$ ___________
Total Transportation
5.8
Education
Gifts
Other
Miscellaneous Expenses
Life insurance (if not deducted from income)
Other_____________________________________________
Other_____________________________________________
5.9
5.10
5.11
Description
of Debt
Month of
Last Payment
Balance
Creditor
/ jr u ie f s
,______
__________
____________
___ ^
T t!* - ( t& r t- D
__________
Month of
Last Payment
Amount of
Monthly
Payment
____________
$ ________
Balance
___________________ $ ___________
/ ^ Z 7 , 3/
______
fiP&L $ VfiMSS
s_____
___________________________ $ ___________
___________________________ $ ___________
___________________________ $ ___________
Total Monthly Payments for Other Debts and Monthly Expenses
Financial Declaration (FNDCLR) - Page 5 of 6
WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
5.12
6.2
6.3
6.4
6.5
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]
l A / / \ , [State] on *
C 7 b H -fJ
/ 4 /T^ n 2 ^ / Patel.
K A L -t/
_______
frig financial records are being provided to the other party and filed separately with the court.
Financial records pertaining to myself:
^ .In d iv id u a l [ ] Partnership or Corporate Income Tax returns for the years
) "TL# /
f
including all W-2s and schedules;
[ ] Pay stubs for the dates of / c / ^ a / 3
3 / z - a / A
r 1 Other:
Do not attach these financial records to the financial declaration. These financial
records should be served on the other party and filed with the court separately
using the sealed financial source documents cover sheet (WPF DRPSCU
09.0220). If filed separately using the cover sheet, the records will be sealed to
protect your privacy (although they will be available to all parties in the case,
their attorneys, court personnel and certain state agencies and boards.) See GR
22 (C)(2).
\
9
AM
APR 22 201*
p i
'-j
(J
OJ
Kalii
Father John
Case No.
(C S W P )
1 4 3 01 646 7
Mother
$2,637.00
$4,352.00
-
$4,352.00
$2,637.00
$303.06
$230.89
$201.73
$43.85
$263.79
$303.06
$740.26
$4,048.94
$1,896.74
*$5,945.68
'/ h
$850.00
.681
.319
$271.15
$578.85
8. C alculating low incom e lim itations: Fill in only those that apply.
S elf-S upport Reserve: (125% o f the Federal Poverty G uideline.)
$1,216.00
$271.15
$578.85
Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
Father
Mother
$234.34
$234.34
$234.34
'
>i*
13. Total Health Care, Day Care, and Special Expenses (line 10d
plus line 12)
7.
'V
$234.34
14. Each Parent's O bligation fo r Health Care, Day Care, and Special
Expenses (m ultiply each num ber on line 6 by line 13)
$159.59
$74.75
$738.44 |
$345.90
$234.34
-
$234.34
$738.44
$111.56
$1,822.02
$853.53
$144.71
$67.79
a. Real Estate
b. Investm ents
c. V ehicles and Boats
d. Bank A cco un ts and Cash
e. R etirem ent A ccounts
f. Other: (describe)
Father's
H ousehold
M other's
Household
Father's
H ousehold
Paid f ] Yes [ ] No
Paid f ] Yes [ ] No
Paid f ] Yes [ ] No
26.
M other's
Household
-
Date
ifl
ro
("
J
o
n
18. O R D IN A R Y EXPENSES
Ka'ena
$850.00
iM
19. A D JU S T E D BASIC SU P P O R T
-T
20. O V E R N IG H T S W IT H M O TH E R
$850.00
117
21. % O V E R N IG H T S W IT H M O THER
(Line 20 divided by 365)
32.1
22. O V E R N IG H T S W IT H FATHER
248
Lfi
C()
23. % O V E R N IG H T S -F A T H E R
(Line 22 divided by 365)
67.9
24. M O T H E R S C R E D IT PROP
.140
25. F A T H E R S C R ED IT PROP
.860
26. M O T H E R S C R E D IT
(Line 19 tim es Line 24)
$119.00
27. F A T H E R S C R E D IT
(Line 19 tim es Line 25)
$731.00
Client: c:..\kalii jr. john alika\kalii jr, john alika.scp 04/18/2014 01:40 pm
S upportC a/c 2 0 1 4 {R e v . 1 0 /20 0 9 )
Cr.pyutjiu i014bv
Soif-AMM;C.tr.ubInn,
91 N IG H TS
$111.56
$119.00
-$7.44
k Iviw
P.M.
^ ashington
8
10
12
14
16
No.
[X] In re the Marriage of:
[ ] In re the Domestic Partnership of:
18
20
and
22
Petitioner,
1 4 3 01 646 7
Parenting Plan
[X] Proposed (PPP)
[ ] Temporary (PPT)
[ ] Final Order (PP)
Respondent.
24
28
30
[ ]
26
32
34
[ ]
[X]
36
38
40
42
Name
44
Age
7 years
Under certain circumstances, a s outlined below, the court may limit or prohibit a parent's contact with the child
and the right to make decisions for the child.
6
8
2.1
10
12
14
16
18
[ ]
20
22
[ ]
24
[ ]
26
28
30
2.2
32
34
36
[X]
[ ]
38
[ ]
40
[ ]
42
44
46
[ ]
[ ]
[ ]
6
[ ]
8
10
[ ]
12
14
III. Residential Schedule
16
18
20
22
The residential schedule must set forth where the child shall reside each day of the year, including provisions
forholidays, birthdays of family members, vacations, and other special occasions, and what contact the child
shall have with each parent. Parents are encouraged to create a residential schedule that meets the
developmental needs of the child and individual needs of their family. Paragraphs 3.1 through 3.9 are one
way to write your residential schedule. If you do not use these paragraphs, write in your own schedule in
Paragraph 3.13.
24
3.1
26
28
30
[X]
[ ]
32
from _____________________
to
34
36
38
40
from _____________________
42
44
46
to ________________________
3.2
School Schedule
Upon enrollment in school, the child shall reside with the [X]
petitioner [ ] respondent, except for the following days and
times when the child will reside with or be with the other
parent:
4
6
8
10
12
[X]
14
16
18
3.3
20
22
24
26
28
30
32
34
3.4
36
38
40
42
44
46
Parenting Plan (PPP, PPT, PP)
WPF DR 01.0400 Mandatory (6/2008)
RCW 26.09.016;. 181;.187;.194
Page 4
3.5
Summer Schedule
Upon completion of the school year, the child shall reside
with the [X] petitioner [ j respondent, except for the
following days and times when the child will reside with or be
with the other parent:
4
6
8
[ ]
[X]
10
12
14
16
18
20
22
24
26
28
3.6
30
32
34
36
3.7
38
With Petitioner With Respondent
(Specify Year
(Specify Year
Odd/Even/Every) Odd/Even/Every)
40
42
44
46
*
ODD
EVEN
ODD
*
EVEN
ODD
EVEN
July 4th
Labor Day
Veterans' Day
Thanksgiving Day
Christmas Eve
Christmas Day
2
4
6
EVEN__________
ODD___________
EVEN__________
ODD___________
*_____________
*_____________
ODD
EVEN
ODD
EVEN
*___
*___
8
10
12
A.
B.
Holidays shall
begin at 6:00 p.m. the day before the
holiday and shall end at 7:00 p.m. the day of the
holiday, except for those holidays marked with an
asterisk, July 4th and Thanksgiving.
C.
The July 4th holiday shall begin on July 4th at 9:00 a.m.
and shall end on July 5th at 12:00 Noon.
D.
E.
F.
Holidays which
fall on a Monday shall include
the
immediately preceding Friday, Saturday and Sunday,
beginning Friday at 6:00 p.m. and ending on Monday at
7:00p.m.
(*)
are
already
14
16
18
20
22
24
26
28
30
32
34
36
3.8
38
40
42
44
46
Mother's Day__________
Father's Day__________
Parenting Plan (PPP, PPT, PP)
WPF DR 01.0400 Mandatory (6/2008)
RCW 26.09.016;. 181;. 187;. 194
Page 6
_____________
EVERY________
EVERY
_____
Mother's Birthday
Father's Birthday
Childs Birthday
2
4
6
EVERY
ODD
EVEN
A.
B.
8
10
EVERY
12
14
16
3.9
18
[ ]
22
24
[X]
20
[X]
priority,
with
1 being
the
26
3
5
4
28
30
[ j
Other:
32
34
36
3.10
Restrictions
[X]
[ ]
38
40
42
44
46
[ ]
2
4
6
8
3.11
Transportation Arrangements
10
Transportation costs are included in the Child Support
Worksheets and/or the Order of Child Support and should not be
included here.
12
14
16
between parents
18
A,
B.
20
22
24
26
28
3.12
Designation of Custodian
The child named in this parenting plan is scheduled to reside
the majority of the time with the [X] petitioner [ ]
respondent.
This parent is designated the custodian of the
child solely for purposes of all other state and federal
statutes which require a designation or determination of
custody. This designation shall not affect either parent's
rights and responsibilities under this parenting plan.
30
32
34
36
38
3.13
Other
40
Make-up residential time:
42
44
46
2
4
6
8
10
12
3.14
14
16
18
20
22
24
26
28
30
32
34
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 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 days1
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.
36
38
40
42
44
46
notice
may
be
grounds
for
4
If no objection is filed within 30 days after service of the
notice of intended relocation, the relocation will be
permitted and the proposed revised residential schedule may be
confirmed.
6
8
10
12
14
16
18
20
The relocating person shall not move the child during the time
for objection unless: (a) the delayed notice provisions apply;
or (b) a court order allows the move.
22
24
26
28
30
32
34
36
4.1
38
40
42
44
46
Parenting Plan (PPP, PPT, PP)
WPF DR 01.0400 Mandatory (6/2008)
RCW 26.09.016;.181;. 187;. 194
Page 10
4.2
Major Decisions
Education decisions
[ ] petitioner
Non-emergency health care
[ ] petitioner
Religious upbringing
[ ] petitioner
Driver's license
[ ] petitioner
Marriage prior to age of
majority
[ ] petitioner
Entry into military service
(If parental permission
required)
[ ] petitioner
8
10
12
14
[X]
16
18
20
22
24
[
[
[
[
]
]
]
]
respondent
respondent
respondent
respondent
(X]
[X]
(X]
[X]
j oint
j oint
j oint
j oint
[ ]
respondent
[X]
j oint
[ ] respondent
[X]
j oint
26
28
4.3
30
[X]
32
[ ]
34
[ ]
36
38
40
[ ]
[ ]
42
(a)
44
(b)
46
48
Parenting Plan (PPP, PPT, PP)
WPF DR 01.0400 Mandatory (6/2008)
RCW 26.09.016;.181;. 187;. 194
Page 11
(c)
2
4
6
(d)
8
[ ]
10
12
14
16
V. Dispute Resolution
18
20
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.
22
[X]
24
26
28
30
32
counseling by _____________________________________ , or
mediation by
Pierce
County
Center
for
Dispute
Resolution____ , if this box is checked and issues of
domestic violence or child abuse are present, then the
court finds that the victim requested mediation, that
mediation is appropriate, and that the victim is
permitted to have a supporting person present during the
mediation proceedings, or
arbitration by ______
_______________________________.
34
[ ]
36
shall
be
allocated between
the
38
40
[X]
[ ]
42
[ ]
44
46
50 % petitioner 50 % respondent.
based on each party's proportional share of income from
line 6 of the child support worksheets.
as determined in the dispute resolution process.
2
In the dispute resolution process:
4
(a)
6
(b)
8
10
(c)
12
(d)
14
16
(e)
18
20
[ ]
22
No dispute
ordered.
resolution
process,
except
court
action,
is
24
26
[ ]
28
[X]
30
6.1
Unless
otherwise
required
by
a
court
of
competent
jurisdiction, each parent shall keep the other parent informed
at all times of his or her current residence address and
current residence telephone number. If there is any change in
this information, the other parent shall be notified of the
new information not later than twenty-four (24) hours after
the change goes into effect. If a parent does not comply with
this provision, any legal notice required to be served upon
the non-complying parent by any form of mail requiring a
receipt for delivery shall be satisfied by sending said notice
to the last known residence address on the non-complying
parent.
6.2
32
34
36
38
40
42
44
46
6.3
6.4
6.5
6.6
Each parent shall have the right to equal access to all the
child's medical, psychological, psychiatric,
counseling,
criminal, juvenile and education records, and to any other
information relevant to the child's best interest or welfare,
including, but not limited to, any records being kept by or
maintained by the State of Washington Department of Social and
Health Services, Child Protective Services Division, or any
other agency of Washington or any other state in which the
child may reside. Any third party having or maintaining any
such records is hereby authorized to release any and all
information upon presentation of a copy of this Parenting Plan
by a parent named herein, without the necessity of a court
order or a subpoena duces tecum, unless a child exercises a
4
6
8
10
12
14
16
18
20
22
24
26
28
30
32
34
36
38
40
42
44
46
2
4
6
8
10
6.7
6.8
6.9
6.10
12
14
16
18
20
22
24
26
28
30
32
34
36
38
40
42
44
46
in
PJ
()
6.11
6.12
Each parent has the duty to respect the parenting style and
authority of the other parent, and neither parent shall
attempt to undermine the authority of the other parent with
the child. Neither parent will make plans or arrangements
involving the child which would impinge upon the other
parent's authority or time with the child, without express
agreement of the other parent. If a child has a grievance with
a parent, the other parent must encourage said child to
discuss any such grievance directly with the parent in
question.
6.13
4
6
yjf
8
(j
f\l
. 4"-J
-.j
10
12
14
16
N
18
Lf'!
CO 20
22
24
26
28
30
[ ]
[X]
I declare
State of
faith and
true and
40
42
44
46
^ IVi
l\ C 'd
9f i l l
? k'rterk
'^ - D eputy
i"j 10
,J
12
-t 14
In re the Marriage of:
No-
Return of Service
(Optional Use)
(RTS)
16
N
ifi 18
c0
20
22
Petitioner,
and
14 3 01646 7
24
I Declare:
26
1.
2.
28
30
32
34
36
[X]
[X]
[X]
[ ]
[X]
[X]
[X]
38
40
42
44
46
48
[X]
[X]
[ ]
[ ]
[ ]
[ ]
[ ]
[ J
[X]
3.
Date:
a .m
Address:
/0 S /V -
10
f iv e
S '.
, W A
12
J.
14
[]
16
18
[]
20
[]
22
24
26
[]
28
30
32
34
5.
36
38
[]
Other:
40
42
6.
44
the
State
46
on
Si gned at
48
50
'
{Date
{City, prate)
-^ v y o
^.Signature
52
Return of Service (RTS)
WPF DRPSCU 01.0250 (7/2013)
CR 4(g); RCW 4.28.080(15)
Page 2
of
2
4
Fees:
Service
Mileage
T o tal
8
10
(Attach R e t u r n R e c e i p t here,
12
File the origi n a l R e t u r n of Service with the clerk. Provide a copy to the
law e n f o r c e m e n t a g e n c y w h e r e p r o t e c t e d p e r s o n r e s i d e s if the d o c u m e n t s
s e r v e d i n c l u d e a r e s t r a i n i n g o r d e r s i g n e d b y the court.
14
16
18
20
22
24
26
28
30
32
34
36
38
40
42
44
46
48
50
52
if s e r v i c e was b y m a i l .)
2
4
6
8
10
12
14
No.
18
Summons
(SM)
and
20
Beth Ann Kalii
Respondent.
22
24
26
1.
28
The petitioner
requesting:
[X]
[ ]
[ ]
[ ]
[ ]
30
32
34
has
started an action
in the
above
court
be
36
Additional requests, if any, are stated in the petition,
copy of which is attached to this summons.
38
40
42
44
2.
Summons (SM)
WPF DR 01.0200 Mandatory (6/2008)
CR 4.1
Page 1
#r
4
6
8
10
12
3.
14
16
18
20
4.
22
24
26
28
5.
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.
6.
7.
30
32
34
36
38
40
42
44
46
Summons (SM)
WPF DR 01.0200 Mandatory (6/2008)
CR 4.1
Page 2
mt-
Dated:
rfe of Petitioner (
or Lawyer/WSBA No.
10
12
1.4
16
18
20
22
24
26
28
30
32
34
36
38
40
42
44
46
Summons (SM)
WPF DR 01.0200 Mandatory (6/2008)
CR 4.1
Page 3
a .m .
14-3-01646-7
42419704
DCLRM
Ap r
22
2014
p .m .
04-2 4 -H
vnn
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Wounty
T O
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Cleric
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0 3 ^ 7 Ai
A L IK A
A L~U
NO
Petitioner(s),
DECLARATION OF MAILING
1 4 3 01 646 7
and
LiJ
fe n f
M W
Respondent(s).
1.
2.
)&>}-
following documents:
n h y > i -lA n ^
KlA
V t Z P A r e jT M . e h J 'T
/QA>fZ
___________________
to g g f t f K A L I lby mailing the same to him / her by regular first class mail
postage prepaid to the following address:
Cd \ 2_~Z
/ i/U
^ 4 -
LA kLEkJ& cP \}JA f r f t f
V / 2 - Z - / 2 - 0 1A - _____________ .
I d eclare under penalty o f perjury under the laws of the State o f W ashington that the
fo reg o in g is true and correct.
Signed at
Declaration of Mailing
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
NO. 14-3-01646-7
NOTICE OF APPEARANCE
ntaprsup-0001.pdf
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W A S H IN G
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
10
11
No. 14-3-01646-7
12
13
and
Response to Petition
(Marriage)
(RSP)
14
BETH ANN KALII,
15
16
Respondent.
17
18
I. Response
1.1
19
20
The allegations of the petition in this matter are adm itted or denied as follows
(check only one for each paragraph):
21
22
1.1
Admitted
23
1.2
Admitted
24
1.3
Admitted
1.4
Admitted
1.5
Admitted
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 S tre et SW , Ste 25
Lakew ood, W A 98499
253-581-0660
1
2
3
4
1.6
1.7
Admitted.
1.8
Denied.
1.9
Denied.
1.10
Denied.
1.11
Admitted.
1.12
Admitted.
1.13
Admitted.
1.14
Admitted.
1.15
1.16
N/A
7
8
9
10
Each allegation of the petition that is denied, is denied for the following reasons (List
separately):
11
1.6
Admitted this is the date the parties moved into separate residences.
Denied that the parties have divided their assets and liabilities.
1.8
1.9
Denied.
The division of the parties debts and liabilities should be
determined by the court at a later date.
1.10
Denied. The husband has historically made much more than the wife and
spousal maintenance would be warranted; however, it remains to be seen
what if any spousal maintenance is warranted based upon the employment
of both parties and the final division of debts and assets at the time of trial.
1.15
Respondent admits an order of child support and a parenting plan for the
parties child should be entered. Respondent denies that Petitioners
proposed parenting plan should be entered or that it is in the best interest
of the child. Respondents proposed parenting plan which will be filed later,
and she requests this be the parenting plan entered for the parties child.
12
13
14
15
16
17
18
19
20
21
22
1.2
23
Notice of all further proceedings in this matter should be sent to the address
below.
24
25
1.3
Other
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 S tre et SW , Ste 25
Lakewood, W A 98499
253-581-0660
1
2
II. Request for Relief
3
The respondent requests the court to grant the relief requested below.
Enter a decree.
5
6
10
11
12
13
14
Dated
15
16
17
18
19
20
21
22
23
24
25
Response to Petition (RSP) - P age 3 o f 3
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 S treet SW , Ste 25
Lakew ood, W A 98499
253-581-0660
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
Case number:.
I M - 3 P l l . ^ ' 7 _________
K ^ / /1
/ b O lO
Respondent
B e ^ Y i K a li i
Has successfully completed a Four Hour seminar
Certificate of Completion
Dated this 12th day of May, 2014
In the City of Lakewood, State of Washington
Instructors:
E-FILED
IN COUNTY CLERK'S OFFICI
PIERCE COUNTY, W ASHING Ti
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
10
JOHN A. KALII,
Petitioner,
11
and
12
BETH A. KALII,
Respondent.
13
I. Motion
14
15
Based on the declaration below, the undersigned moves the court for a temporary order
which:
16
17
18
19
20
Requires the Husband to pay the Wife $730 per month representing the cost of his
health care insurance.
Requires the Husband to pay the Wife $175 per month representing 76% of the
cost of the childs health care insurance.
Requires the Husband to pay the Wife $150 per month representing 3.5% of his
pension income.
21
Authorizes the wife to have temporary use and possession of the property.
22
Requires the Husband to pay $1,500 in attorneys fees and costs to the wife.
23
DATED this
24
i ____
DamSt-NrCool?, WSBA 3466W
Attorney for Petitioner
Motion for Temporary Order - Page 1 of 5
Kalii, Beth and Kalii, John
S:\CASES1\Kalii\DRAFTS\Pleadings\Motion for Temporary Order.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th Street SW , S uite 25
Lakew ood, W A 98499
253-581-0660
II. Declaration
2
3
4
BACKGROUND
I,
BETH KALII, am the Respondent in this action. JOHN KALII is the Petitioner.
JOHN and I have been together off and on for approximately 9 years. We had a child,
KA-ENA KALII, together 8 years ago (this month). JOHN and I were formally married in
9
10
11
12
I work
Monday through Friday for beginning at 6:30 a.m. and ending at 6:30 p.m. But there is a
great deal of off time interspersed between those hours while I am not driving a school
13
bus. I am off on all Holidays. I will work half days for one month out of this upcoming
14
15
16
17
18
19
20
21
22
23
24
Summer. I will be off work all but two days of August 2014.
JOHN worked for the City of Tacoma Fire Department for most of our relationship.
He retired a year or two ago. His gross income is now $4,352 per month and his net is
(according to his calculations) $4,048.
Our daughter spends half of the time in JOHNS residence and half of the time in mine.
He told me he
could not get private coverage because of a pre-existing condition. I was skeptical of this
claim, but at JOHNS request I enrolled him on my insurance through my employer, the
Clover Park School District. JOHNS coverage took effect November 2013 which was the
most recent open enrollment period.
Motion for Temporary Order - Page 2 of 5
Kalii, Beth and Kalii, John
S:\CASES1\Kalii\DRAFTS\Pleadings\Motion for Temporary Order.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th S treet SW , Suite 25
Lakew ood, W A 98499
253-581-0660
1
I have covered our daughter KA-ENA on my medical insurance from her birth. At
2
one point while JOHN was still working for the City of Tacoma, I was not getting enough
3
hours to pay for and cover KA-ENA through my employment with Clover Park. So JOHN
4
5
covered her for the last year of his work with the City of Tacoma. But when he retired I
was working and making enough to cover her again and so she was back on my health
The cost of healthcare insurance through my company is $1,771 per month. This
10
Clover Park or a Trust fund set-up by the Union, pays 100% of my health care insurance.
11
12
You can see on my paystub that the employer paid portion in April 2014 was $882.45.
The amount may vary each month depending upon availability of funds in the Trust, but it
13
14
of $887.58 per month that the Employee (me) paid but this amount varies from month to
15
20
21
22
23
24
I have also filed a sealed financial source document which is my medical options
pamphlet from Human Resources at my company.
It shows the cost for me and child is $1,046. It shows that the cost for me only is
$812.45.
It shows the cost for me and JOHN is $1,543 per month. It shows that the cost for
me only is $812.45. Hence, the cost of JOHNS insurance is $730.86.
So the total cost of JOHN and KA-ENAs insurance combined would be $964.41
per month; however, when I cover them together as a Spouse and Child there is a slight
(about $6) savings each month.
The document shows that the total cost for me, JOHN
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th S treet SW , S uite 25
Lakew ood, W A 98499
253-581-0660
1
and KA-ENA is $1,771 per month. The cost for me only is $812.45 per month. Hence,
2
when I am covering both spouse and child the cost for JOHN and KA-ENA together is
3
$958.55 per month. JOHNS is about $730 per month and KA-ENAs is about $230.
4
I am asking JOHN to pay 100% of his medical insurance of $730 per month.
Now
that I have put him on my insurance at his request, I am left with net income of only about
$1,290 per month. This is not enough to live on or get my own apartment or anything. I
absolutely cannot afford to live and pay my bills without JOHN paying his share of the
healthcare insurance. If he would prefer to forgo healthcare insurance that is his option,
10
11
12
or if he can get it cheaper somewhere else, that is fine; however, I cannot even cancel
him until the next open enrollment period in November 2014 so he must contribute at
least $730 a month until November 2014.
13
pay $175 per month which is 76% of the $230. Because he makes $4,048 net income
15
and I make $1,290 per month me makes 76% of our combined income.
16
17
18
In total I am asking JOHN to pay $905 per month toward the healthcare insurance.
PENSION
19
JOHN worked for the City of Tacoma a total of 33 years before he retired. JOHN
20
and I have been together 9 years (our daughter is 8 years old). He was employed with
21
the City of Tacoma for 7 of those years. Presumptively 7% would be community and I
22
would get 3.5%. JOHNS gross income from his pension is $4,300 per month so I am
23
24
asking the court to order him to pay $150 per month to me as a distribution of property
(pension). It can be characterized as spousal maintenance if necessary, on a temporary
basis, to shift the tax burden appropriately.
M o tio n f o r T e m p o r a r y O r d e r - P a g e 4 o f 5
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
1
PERSONAL PROPERTY
2
When I left the family home I took my clothing and a few personal items and my
3
car. I do not have any furnishings to set up a new apartment for my daughter and me. I
4
5
have done my best so far but I simply cannot go out and replace everything that we need
on $1,290 per month. I am asking the court to give me temporary use and possession of
8
9
10
11
12
1.
2.
3.
4.
5.
6.
ATTORNEY FEES
13
14
pay the other $1,500 within 60 days. I frankly do not have that money and cannot come
15
up with it while simultaneously paying $730 for JOHNS health care insurance and while
16
having to come up with first and last months rent and security deposit on an apartment. I
17
18
need help with attorneys fees so that I can move forward in this transition.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
19
20
Signed at (city)
(state)
21
22
23
24
M o tio n f o r T e m p o r a r y O r d e r - P a g e 5 o f 5
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W ASHING T
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner
12
and
13
BETH A. KALII,
Parenting Plan
Proposed (PPP)
Respondent.
14
15
16
17
18
19
20
Name
Age
KAENA KALII
21
22
23
24
Under certain circumstances, as outlined below, the court may limit or prohibit a
parents contact with the child and the right to make decisions for the child.
2.1
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 1 o f 1 0
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
253-581-0660
1
2.2
2
Does not apply.
3
4
5
6
7
8
3.1
10
11
3.2
School Schedule
Upon enrollment in school, the child shall reside equally with both parents on the
following schedule:
12
13
The child shall reside with the parents on a rotating and repeating
alternating week on/week off schedule. Exchanges from one home to the
other will be on Mondays after school or at 5:00 p.m. if there is no school.
14
15
3.3
16
17
18
The child shall reside with each parent during winter vacation as follows:
Winter Vacation shall be defined as commencing the day after school lets out for
the Winter Vacation Break and concluding on the day before school resumes.
19
In even numbered years, the mother shall have the child for the first
half of the Winter Vacation. Visitation shall begin the day after
school lets out at 9:00 a.m. until December 27th at 8:00 p.m. In
even numbered years the father shall have the child from
December 27th at 8:00 p.m. through the day before school
resumes at 6:00 p.m.
20
21
22
23
In odd numbered years, the father shall have the child for the first
half of the Winter Vacation. Visitation shall begin the day after
school lets out at 9:00 a.m. and conclude on December 27th at
8:00 p.m. The mother shall have the child from December 27th 8:00
p.m. through the day before school resumes at 6:00 p.m.
24
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 2 o f 10
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
1
3.4
2
The child shall reside with each parent during spring break as follows:
3
The first half of Spring Break shall be with the parent who has the child the
prior week under the alternating week schedule (Par. 3.2); the second half
of Spring Break shall be with the parent who has the child the week after
Spring Break under the alternating week schedule (Par. 3.2). The
exchange shall be on Wednesday at 12:00 p.m. unless otherwise agreed
by the parties.
4
5
6
7
3.5
Summer Schedule
8
Upon completion of the school year the child shall reside with each parent as follows:
9
10
11
3.6
12
13
Each parent shall notify the other parent in writing of his or her two weeks
of vacation no later than May 1 of each year. If there is a conflict in
vacation dates the fathers choice will control in odd years and the
mothers choice will control in even years.
14
15
16
17
18
19
20
21
22
23
24
3.7
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 3 o f 10
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
Holidays marked with an asterisk (*) shall be spent with the parent who is entitled to
the preceding weekend under the alternating week schedule.
Unless otherwise noted, Holidays shall be the night before at 6:00 p.m. until the day of
the Holiday at 8:00 p.m.
4
5
July 4th will be from 10:00 a.m. on July 4 until 12:00 p.m. on July 5.
3.8
The residential schedule for the child for the following special occasions (for
example, birthdays) is as follows:
8
9
10
Mothers Day
Fathers Day
Fathers Birthday
Mothers Birthday
Childs Birthday
11
12
13
With Mother
(Specify Year
Odd/Even/Everv)
Every
With Father
(Specify Year
Odd/Even/Everv)
Every
Every
Every
Odd
Even
If the Special Occasion is on a non-school day, the Special Occasion shall be the
night before at 6:00 p.m. until the day of the Special Occasion at 8:00 p.m.
14
15
If the Special Occasion is on a school day, the Special Occasion shall be from after
school on the day of the Special Occasion until the8:00 p.m. on the day of the Special
Occasion.
16
17
18
19
20
21
22
23
24
3.9
Restrictions
Does not apply.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 4 o f 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
3.11
Transportation Arrangements
2
3
Transportation costs are included in the Child Support Worksheets and/or the
Order of Child Support and should not be included here.
6
7
3.12
Designation of Custodian
The child named in this parenting plan are scheduled to reside the majority of the
time with both parents equally. Both parents are designated the custodian of the
child solely for purposes of all other state and federal statutes which require a
designation or determination of custody. This designation shall not affect either
parents rights and responsibilities under this parenting plan.
10
11
12
3.13
Other
13
Each parent acknowledges that the other parent spends substantially equal
residential time with the child. For purposes of any future relocation of the child,
neither parent may claim the presumption under RCW 26.09.520 favoring
relocation of the child and both parents are required to give the notice of
relocation under RCW 26.09.430 and .440 when relocating. Based upon the
child's long-term involvement in school, athletics and other extra-curricular
activities, the existence of family and social relationships and the connections to
health care professionals all in the Pierce County area the parties agree that the
child should remain in the Pierce County area if one parent decides to relocate
out of the Pierce County area.
14
15
16
17
18
19
20
3.14
21
This is a summary only. For the full text, please see RCW 26.09.430 through
26.09.480.
22
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.
23
24
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
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 5 o f 10
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
give notice within 5 days after learning of the move. The notice must contain the
information required in RCW 26.09.440. See also form DRPSCU 07.0500,
(Notice of Intended Relocation of A Child).
2
3
If the move is within the same school district, the relocating person must provide
actual notice by any reasonable means. A person entitled to time with the child
may not object to the move but may ask for modification under RCW 26.09.260.
4
5
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.
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.
10
11
12
13
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.
14
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.
15
16
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.
17
18
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.
19
20
21
4.1
Day-to-Day Decisions
Each parent shall make decisions regarding the day-to-day care and control of
each child while the child is residing with that parent. Regardless of the allocation
of decision making in this parenting plan, either parent may make emergency
decisions affecting the health or safety of the child.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 6 o f 1 0
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
253-581-0660
1
4.2
Major Decisions
2
Major decisions regarding each child shall be made as follows:
3
Education decisions
Non-emergency medical and mental health care
Religious upbringing
4
5
Regarding medical decisions, either parent may take the child for regularly
scheduled appointments with their ordinary physicians, dentists or medical
care providers for check-ups, vaccinations, routine/recurring doctor or
dental appointments or for treatment of mild or seasonal type illnesses
(e.g., cold, flu, allergy, earaches, anti-biotic, shortterm prescriptions etc.)
without triggering joint decision-making requirements. The parties shall
communicate as much as possible about even these routine medical and
dental decisions to ensure coordination of care and full advice to the
medical professionals caring for the child.
6
7
8
9
10
11
Joint decision means that the parent seeking to make a major decision
shall notify the other parent of the proposed major decisions he or she
intends to make and the other parent may object to the decision and/or
propose an alternative within 14 days of notice. If the other parent does
not object or propose an alternative the parents decision shall be final and
he or she may proceed immediately after the expiration of the 14 days.
The parent seeking to make a decision shall not take any irreversible
action in furtherance of a proposed major decision until after 14 days
notice, or, until after an agreement is reached or a court order is issued if
the other parent objects to the decision.
12
13
14
15
16
17
18
joint
joint
joint
4.3
19
V. Dispute Resolution
20
21
22
23
24
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
253-581-0660
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
To the greatest extent possible, the parents shall communicate with each other
by e-mail. Each parent shall maintain an e-mail account for this purpose and
keep the other party informed of their e-mail address.
3
4
5
Neither party shall discuss the residential schedule with the child except for plans
that have already been agreed to by both parties. Neither party shall provide
information to the child of the status of child support payments or other legal
matters regarding the parties.
6
7
Neither parent shall make disparaging remarks about the other parent or any
other remarks that might cause diminishment of the childs respect for the other
parent either to the child or in the presence of the child, nor shall they allow the
child to make disparaging remarks about the other parent.
10
11
12
13
14
15
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.
20
21
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.
22
23
If a parent fails to comply with a provision of this plan, the other parents obligations
under the plan are not affected.
24
Dated:______________________________ _
____________________
Judge/Commissioner
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 9 o f 10
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.
_______________ , W SB A #
Attorney for Respondent
3
4
5
6
7
Date
Date
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th S treet SW , Suite 25
Lakew ood, W A 98499
253-581-0660
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
JO H N A L IK A KALII JR
No. 14-3-01646-7
Petitioner(s),
N O TE FO R C O M M IS S IO N E R 'S C A LE N D A R
vs.
BETH A N N KALII
R espondent(s)
TO T H E C L E R K O F T H E S U P E R IO R C O U R T A N D TO :
Phone:
Petitioner
P lease ta ke notice th a t an issue o f law in this case w ill be heard on the date and tim e show n below:
9:00 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 1 2:00 N O O N T W O C O U R T D A Y S P R IO R T O H E A R IN G
DATED:
M ay 13, 2014.
S ig n e d :
/s / D aniel N C ook
NAM E:
D aniel N C ook
Phone:
(253) 581-0660
W SBA#:
34866
F o r:
A tto rn e y fo r R esp o nd e n t
LA K E W O O D , W A 98499-2751
1 of 1
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHING'
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
10
11
12
13
No. 14-3-01646-7
DECLARATION OF MAILING
Petitioner,
and
14
15
I,
Sally DuCharme, am over the age of 18, and competent to testify in the
above entitled case.
16
17
18
19
20
21
On May 13, 2014, I placed in the U.S. Mail a copy of the following
documents in the above-entitled caption:
1.
2.
3.
4.
5.
6.
7.
Notice of Appearance;
Response to Petition;
Proposed Parenting Plan;
Motion for Temporary Order;
Sealed Financial Source Documents;
Respondents Parenting Class Certificate; and
Note for Commissioners Calendar on June 11, 2014.
22
Said documents were addressed to:
23
24
John Kalii
9711 Winona ST SW
Lakewood WA 98498
25
Declaration Of Mailing
Kalii, John and Kalii, Beth
S :\C A S E S 1 \K a lii\D R A F T S \P le a d in g s \D e c la ra tio n o f M a ilin g .d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th S treet SW , Suite 25
Lakewood, W A 98499
Phone: (253) 581-0660
1
2
3
I declare, under the penalty of perjury and the Laws of the State of Washington,
that the foregoing is true and correct.
DATED
______ _
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
D e c la r a tio n O f M a ilin g
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
CO
O
02
4
6
8
OLO
in
O
<42
14
In re the Marriage of:
No-
OIL 8
Petitioner,
and
if 2 2
Respondent.
26
28
I. Motion
30
32
34
36
(Name of requesting party) John Alika Kalii, Jr. moves the court
for an order of default against (name of other party being
defaulted) Beth Ann Kalii. Venue of this action is proper as set
forth in the Declaration below.
38
40
Dated:
3 3 , / 3 . 2 - 0 / /
42
44
46
Mtn/Decl for Default (MTDFL)
WPF DRPSCU 03.0100 Mandatory (6/2012)
CR 55(a); RCW 26.09.030
Page 1
5 2
p
4
tl. Declaration
6
2.1
P10
in
12
14
P 16
f
_f
018
[ ]
Other:
i\\
\20
nj
2.2
^22
if )
[X]
[X]
28
30
[X]
32
[X]
34
[ ]
36
[X]
38
40
[X]
[ ]
42
[ ]
44
46
[ ]
48
Mtn/Decl for Default (MTDFL)
WPF DRPSCU 03.0100 Mandatory (6/2012)
CR 55(a); RCW 26.09.030
Page 2
2.3
6
8
10
12
[X]
[ ]
14
16
The Other Party cannot be found in the State of
Washington.
18
20
2.4
22
[X]
24
26
[ ]
28
[ ]
30
[ ]
32
34
2.5
36
[X]
[ ]
38
40
42
44
2.6
46
48
OO 11
OvLO
[
if'!
012
r-i
14
B.
Factual basis:
,16
[X] See the attached Department of Defense
Manpower Data Center Status Report Pursuant to
Servicemember Civil Relief Act (SCRA) obtained
from https://www.dmdc.osd.mil/appj/sera/. (You
must have the person's social security number
to search this site.)
[ ] Other factual basis:
q IS
l'J
\2 0
lO
22
u*'24
26
28
[ ] 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.
30
32
34
36
2.6.2 A.
(name of
38
40
42
44
46
48
iM
B. Factual basis:
o^
o
4
6
8
Or?-0
iCl
Cl2
ci
14
16
4
i8
u
l
M
v.20
[ ]
u)
r-2 2
[ ]
u24
[ ]
26
28
2.7
Other
30
32
34
36
Signed at
38
40
42
John Alika Kalii, Jr.
Print or Type Name
44
46
48
Mtn/Decl for Default (MTDFL)
WPF DRPSCU 03.0100 Mandatory (6/2012)
CR 55(a); RCW 26.09.030
Page 5
S C R A 3,0
fO
H
)
0(
Status Report
Pursuant to Scrviceinembers Civil R elief Act
L a s t N a m e : K A L II
F irs t N a m e : B E T H
M id d le N a m e : A N N
A c tiv e D u ty S ta tu s A s O f: A p r-1 7 -2 Q 1 4
-
'
Status
S ervice C om ponen t
NA
No
NA
NA
T h is re s p o n s e re fle cts the ind ivid u a ls' a c tiv e d u ty status based on the A ctive Duty S ta tu s Date
4
Left A c tiv e D u ty W ithm 367 D ays o f A c tiv e D uty S tatue Date
A ctive D uty End D ate
A ctive D u ty S la rl D ate
NA
S tatus
No
NA
S ervice C om p o n e n t
(
NA
T h is re sp o n se re fle cts w h e re the in d ivid u a l left active d u ty status w ithin 367 days preceding the A ctive D uty S ta tu s D a le
ij)
rn
in
NA
NA
S tatus
. No
S ervice C om ponen t
NA
T h is re sp o n se re fle cts w h e th e r the in d iv id u a l o r h is /h e r u n it has re ce ive d e a rty notifica tio n to re p o rt fo r a c tiv e duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you .provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty,
Y k o A ij, y h .
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DM DC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
4
cH
o
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.m il/faq/pis/PC09SLDR.htm l. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. 521(c).
This response reflects the following information; (1) The individual's Active Duty status on the Active Duty Status Date (2) W hether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
tfi
O
Program Administrator (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).
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
Li.)
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods,
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC 101(d)(1).
ijf'i
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 the SCRA
extend beyond the last dates of active duty.
Those who could 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
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
in
O :
0
6
8
(Til0
In
12
14
'-"16
rH
s 18
U>2 0
rH
-22
in
No-
and
\u \ ~
' ^ - ' 6 l t Q L lC p r 7
24
Respondent.
26
I. Basis
28
30
(name of requesting
32
34
II. Findings
36
38
40
42
44
2.1
46
Ord of Default (ORDFL)
WPF DRPSCU 03.0200 Mandatory (6/2008)
CR 55(a); RCW 26.09.020
Page 1
o 2
ij
4
2.2
6
8
ij'i10
ifi
012
cH
14
d16
H
q
2.3
18
\2 0
O
H22
[ ]
u"'24
[ ]
26
[ ]
28
30
2.4
Appearance
32
[X]
[ ]
34
36
38
40
2.5
42
44
46
48
Ord of Default (ORDFL)
WPF DRPSCU 03.0200 Mandatory (6/2008)
CR 55(a); RCW 26.09.020
Page 2
IS
[ ] 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.
O 2
0
4
6
8
Tao
in
012
14
,+16
"'J
o 18
.,2 0
A
rH22
2.6
Other
III. Order
U''2 4
26
it is Ordered:
28
30
32
34
36
38
40
42
44
46
48
CR 55(a); R C W 26.09.020
Page 3
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
May 27 2014 8:
KEVIN STO
COUNTYC.
2
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
Respondent.
12
13
14
YOU, AND EACH OF YOU will please take notice that Thomas R. Sabin, of
15
Goldberg & Jones PLLC, hereby appears on behalf of John A. Kalii, Petitioner, and
16
requests that all further pleadings herein, except original process, be served upon the
17
18
19
20
21
Attorney for Petitioner
22
23
N otice o f A p p e a ra n c e fo r P etitio n e r
P age 1
E-FILED
IN COUNTY C L E R K
PIERCE COUNTY, W
June 04 2014 3
KEVIN STO
COUNTY C .
NO: 14-3-01
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
Respondent.
12
I am the Petitioner in this action and make this declaration in response to the
13
motion for temporary orders filed by my wife. Her financial requests are confusing to
14
me so I will address them as best as I can. I am a retired firefighter, and I make
15
$4,028.91 per month from my retirement. My wife is a school bus driver for the Clover
16
Park School District and makes a net income for child support purposes of $2,160.03
17
per month, before deductions for health care insurance.
18
The first two of her requests for financial relief are for a contribution of $730.00
19
for my portion of the health care insurance and $175.00 for my percentage of our
20
daughters health care insurance, totaling $905.00 total contribution towards the health
21
insurance. The problem with that request is that her total average cost for health care
22
insurance over the last 8 months, including her portion thereof, is $920.73 per month.
23
Out of those 8 months four of the months the health insurance costs do not exceed
R e sp o nsive D ecla ra tio n o f J ohn Kalii
p _ nA
rd 9e
GOLDBhRG &
j o is l s p l l c
1200 Westlake Avc. N.Suite700
Seattle, Washington 98109
Tel: (206) 448-1010 - Fax: (206)448-0736
Email- [email protected]
$900.00 per month. What she is asking the court for is to have me cover the entirety of
Based upon the information she provided the total insurance for my wife, me and
our daughter is $1,771.03. The cost of insurance for the employee only is $812.45.
The total cost of the insurance for the spo use is $730.86 p rio r to the em p lo ye rs
c o n trib u tio n . I computed that by taking the cost for the spouse and the employee
($1,543.31) less the employee cost ($821.45). The total cost for insurance for our
the cost for the employee and child ($1,046.79) and subtracted out the cost for the
10
employee ($812.45). My percentage of the insurance for our daughter should be 64.5
11
12
The real issue is how to apportion the average of $849.43 that her employer
13
contributes to her health insurance costs. If you attribute the employer contribution to
14
the total insurance costs $849.43/$1,771.03 then the employer is contributing 48% of
15
the total costs of insurance. Using that figure the costs for the insurance for me is an
16
average of $380.05, the cost for my w ifes insurance is $422.47 and the cost for our
17
18
19
20
The next issue is my wifes odd request for a portion of my pension. Her
21
22
understanding that on temporary orders the court will not be involved in property
23
division; it is reserved for agreement or trial. However, even if it is assumed that this is
some sort of request for temporary spousal maintenance there was no financial
declaration provided, no bank records, no showing of need, if any, on her part. Her
request also doesnt take into account the substantial contributions that were made to
her SERS retirement plan while we were married. Ultimately, that is why it should be an
issue for the trial court. We have had a short term marriage, less than four and a half
years and have lived together less than seven years, having moved in with me in the
summer of 2007. Even if her attorney files a financial declaration and bank records, I
will not have the opportunity to address those issues. She is claiming that she has the
need for
10
My wife has requested certain furniture and other items from me, which again
11
seem to be a request for a pretrial distribution of property. She has requested her trunk,
12
which has already been delivered to her, and her wardrobe which I have no problem
13
with her having. She has also requested all of the kitchen utensils out of the camper
14
trailer, without any showing of need, but I am willing to provide those to her. I do not
15
understand her request for the outdoor furniture but I am willing to provide those for her.
16
However, as to her request for the king size bed, that is the bed that I have, I am using it
17
and I purchased prior to our marriage. It is the only bed I have. I assume, because she
18
hasnt told us, that she has a bed where she is residing, and her possible move to an
19
apartment some time in the future is not addressed. She may ultimately move into a
20
furnished apartment, she may have the need for some of these items, but there just isnt
21
22
23
She has requested that I pay $1,500 to her attorney fees. Although at the time
that I receive my retirement check I have a good amount of money in my account, by
10
11
12
h e r a lle g a tio n s.
T h is d e c la ra tio n is g ive n u n d e r p e n a lty o f p e rju ry o f th e law s o f th e S ta te of
W a s h in g to n a n d is tru e a n d c o rre c t to the b e s t o f m y kn o w le d g e .
13
14
15
16
17
18
19
20
21
22
23
g o i .dberg &
JONES t'U X
98169
ScattU,
T e l: (2 9 4 ) 4 4 M G 1 0 - F a s t (2&}44$-Q736
1
2
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
7
8
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
DECLARATION OF SIGNATURE ON
ELECTRONIC DOCUMENT
Respondent.
12
I declare under penalty of perjury of the laws of the State of Washington that the
13
foregoing electronic document attached to this declaration, which consists of 5 pages
14
including this declaration page, is a complete and legible image that I have examined
15
personally and that was received by me via email at the following address:
16
tsabin@ goldbergjones.com.
17
18
19
20
21
22
23
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W A S H IN G !
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
2
3
4
5
6
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 PIERCE
7
8
In re:
JOHN KALII
N o. 14-3-01646-7
10
P e titio n e r,
F in a n c ia l D e c la ra tio n
P e titio n e r
(F N D C LR )
And
11
BETH KALII
12
13
R e s p o n d e n t.
14
15
16
$4,028.91
$4,658.38
$185.00
$4,843.38
$2,667.00
17
II.
18
19
P e rs o n a l In fo rm a tio n
2.1
Occupation:
2.2
2.3
20
No
21
b. If no:
22
(2) What were your gross monthly earnings?
23
(3) Why are you presently unemployed?
retired
24
25
SupportCafc/FD 2014
1
III. Incom e In fo rm a tio n
2
3
4
If child support is at issue, complete the Washington State Child Support Worksheet(s), skip
Paragraphs 3.1 and 3.2. If maintenance, fees, costs or debts are at issue and child support is Notan
issue this entire section should be completed. (Estimate of other party's income information is
optional.)
3.1
6
7
8
9
10
11
12
13
14
a.
b.
c.
d.
e.
f.
9h.
15
16
17
18
Income Taxes
FICA/Self-employment Taxes
State Industrial Insurance Deductions
Mandatory Union/Professional Dues
Pension Plan Payments
Spousal Maintenance Paid
Normal Business Expenses
Total Deductions from Gross Income
(add lines 3.2a through 3.2g)
$323.46
Beth Kalii
$19.86
$123.89
$5.35
$46.10
$254.11
$449.31
$4,028.91
$2,217.69
John Kalii
$323.46
-
19
20
3.3
21
22
23
24
25
SupportCafc/FD 2014
3.4
2
3
Miscellaneous Income
a.
Child support received from other relationships
Name:
Name:
b.
Other miscellaneous income
Beth Kalii
John Kalii
-
4
5
6
7
8
9
10
11
c.
12
13
T o ta l M is c e lla n e o u s In c o m e
(add lines 3.4a through 3.4b)
3.5
14
3.6
If the income of either party is disputed, state monthly income you believe is correct and
explain below:
4.1
4.2
4.3
Cash on hand
On deposit in banks
Stocks and bonds
Cash value of life insurance
Other liquid assets:
15
16
17
_
-
IV. A v a ila b le A s s e ts
18
4.4
$36.00
$1,483.00
-
$5,924.16
19
V. M o n th ly E x p e n s e In fo rm a tio n
20
21
22
23
Monthly expenses for myself and 1 dependents are: (Expenses should be calculated for the future, after
separation, based on the anticipated residential schedule for the children.)
5,1
Housing
Rent, 1st mortgage or contract payments
Installment payments for other mortgages or
encumbrances
Taxes & insurance (if not in monthly payment)
T o ta l H o u s in g
$1,607.18
$1,607.18
24
25
Goldberg Jones
PLLC
SupportCa/c/FD 2014
5.2
2
3
Utilities
Heat (gas & oil)
Electricity
Water, sewer, garbage
Telephone
Cable
Other:
$168.26
$99.40
$114.94
$320.00
$133.86
T o ta l U tilitie s
$836.46
5.3
6
7
8
9
5.4
10
11
12
5.5
14
5.6
16
17
18
5.7
21
22
T o ta l F o o d S u p p lie s
$675.00
Children
Day Care/Babysitting
Clothing
Tuition (if any)
Other child-related expenses
Transportation
Vehicle payments or leases
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
Parking
Other transportation expenses
T o ta l T ra n s p o rta tio n
15
20
$400.00
$150.00
$125.00
T o ta l E x p e n s e s C h ild re n
13
19
$148.00
$50.00
$198.00
$684.69
$135.05
$165.00
$984.74
$75.00
T o ta l H e a lth C are
$75.00
$50.00
$20.00
$95.00
$117.00
$282.00
23
24
25
SupportCa/c/FD 2014
5.8
2
3
4
5
6
7
Miscellaneous Expenses
Life insurance (if not deducted from income)
Other:
Other:
T o ta l M is c e lla n e o u s E x p e n s e s
5.9
$4,658.38
T o ta l H o u s e h o ld E xp e n s e s
8
9
10
11
12
13
5.11
Other Debts and Monthly Expenses not Included in Paragraphs 5.1 - 5.8
Month of
Last Payment
Creditor/Description of Debt
Balance
May, 2014
MasterCard
$1,616.71
May, 2014
Target
$224.00
June, 2014
Lowes
$520.33
Amount of
Monthly Payment
$ 100.00
$25.00
$60.00
14
15
16
17
18
19
20
21
22
23
24
25
SupportCa/c/FD 2014
1
2
$185.00
$4,843.38
6.2
6.3
6.4
6.5
Other:
$3,000.00
6
7
$2,000.00
10
11
I declare u nder penalty o f perjury under the laws o f the state o f W ashington that the foregoing is true and
correct.
Signed at
12
13
14
Signature o f Declarant
15
T he following financial records are being provided to the other party and filed separately w ith the court.
16
17
18
19
20
21
22
Do not attach these financial records to the financial declaration. These financial records should
be served on the other party and filed with the court separately using the sealed financial source
documents cover sheet (WPF DRPSCU 09.0220). If filed separately using the cover sheet, the
records will be sealed to protect your privacy (although they will be available to all parties in fire
case, their attorneys, court personnel and certain state agencies and boards.) See GR 22 (c)(2).
23
24
25
Financial D eclaration (F'fiDC LR) - Page 6 o f 6
W PF DRPSCU 01.1550 (6/2006) - R CW 26.18.220 (1)
G o ld b e r g J o n e s P LLC
1200 W e s tla k e A v e . N . S u ite 700
S e a ttle , W a s h in g t o n 9 8 1 0 9
2 0 6 -4 4 8 -1 0 1 0
e m a il ts a b in @ g o ld b e r g jo n e s .c o m
SupportCWFD 2014
1
2
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
DECLARATION OF SIGNATURE ON
ELECTRONIC DOCUMENT
Respondent.
12
I declare under penalty of perjury of the laws of the State of Washington that the
13
foregoing electronic document attached to this declaration, which consists of 7 pages
14
including this declaration page, is a complete and legible image that I have examined
15
personally and that was received by me via email at the following address:
16
tsabin@ goldbergjones.com.
17
18
19
20
21
22
23
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHING
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCEI,
10
11
No. 14-3-01646-7
12
and
13
14
15
16
17
18
I, BETH KALII, make this declaration on the basis of my personal knowledge and in
reply to the Response Declaration of John Kalii filed on June 4, 2014.
JOHN says that my requests are confusing. There is nothing confusing about
19
them. I am asking that JOHN pay for his own health care insurance. I am asking that
20
21
community portion of his pension. I am asking for use of personal property to divided and
22
I am asking for attorney fees. Nothing about these requests are confusing.
23
JOHN then goes on to reach the exact same calculation of medical insurance
24
costs for me, spouse and child. We both agree that the cost of insurance for me is
25
R e p ly D e c la r a tio n - P a g e 1 o f 5
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
$812.45. We both agree that the cost of insurance for JOHN is $730.86.
We were
2
within $0.79 of each other on KAENAs cost of insurance so I will just adopt his number
3
We both agree that his net income is $4,048 per month. We both agree my net
income is $2,160 per month. We both agree that he should pay 64.5% of KAENAs
medical insurance cost which is $151.15. But he only agreed to pay that after I filed this
motion. Previously he refused to even help me with KAENAs medical insurance. That is
10
11
12
as $849.43 per month. That average calculation is probably close.
13
JOHN then assets that this payment by my employer should be partially applied to
14
HIS coverage. That is simply absurd. My employer pays for my coverage. The
15
amount paid by the employer is almost precisely the amount owed for my coverage each
16
17
month. If JOHN was not covered by my health care insurance plan I would pay
18
nothing for my insurance. There would also be a small part of KAENAs cost covered.
19
20
is common for the employee health care cost to be fully covered by the employer and for
21
the dependents to be paid by the employee. That is exactly what is happening here.
22
23
24
KAENA. So instead of sharing the cost of KAENAs insurance at $234.34 per month, we
25
R e p ly D e c la r a tio n - P a g e 2 o f 5
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
would share the cost of $197.36. This would mean JOHNS 64.5% share of her
3
4
insurance exchange or through his retirement, he can do that. But if he wants to remain
on my insurance he should pay the full amount we both agree is his share of $730.86 per
month. The total combined amount he should pay for KAENAs insurance and his own
9
10
11
JOHN makes a point about my out-of-pocket cost for insurance. He is right when
he says the total cost is $1,771.03. He is right when he says my company pays an
average of $849.43 per month. This means my out-of-pocket costs are $921.60. When
12
JOHN pays $858.15 that leaves me with an obligation of $63.45. My 35.5% share of
13
KAENAs $197.36 is almost precisely the same at $70 per month.
Because the
14
15
16
17
numbers vary a bit month to month based upon the amount of my employer
contribution my proposal is that JOHN pay a flat $850 per month to cover the cost
of his insurance and his contribution to KAENAs insurance. This is $55 less per
18
month than I originally asked for, based upon the application of the small excess my
19
20
PENSION
21
22
23
24
Regarding his pension, there is a huge difference between his pension and my
pension.
His pension is in pay status. He is receiving his pension each and every
month. My pension is not in pay status. I am do not have access to those funds and I am
not entitled to those funds while working. I cannot withdrawal them. I will not receive
25
R e p ly D e c la r a tio n - P a g e 3 o f 5
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
them until I retire. JOHN may be entitled to a small percentage of my retirement and we
2
can sort that out, but in the meantime, he is taking and using a small amount each month
3
which presumptively belongs to me. In contrast, I am not taking and using or spending
4
5
any money which belongs to him. Any money that he is entitled to from me is and will be
preserved until final distribution. But JOHN cannot continue to take and use all of the
8
9
10
11
12
This is not a request for maintenance. The court could consider a request for
maintenance in lieu of this request, or we could bring another motion; however, there is
simply no reason why he should have the full benefit of all of the community interest in his
pension during the pendency of this action.
PERSONAL PROPETY
13
property. I am asking to have temporary use and possession of certain property just as
15
16
17
The statute authorizes temporary orders. JOHN is using the vast majority of the things
18
we acquired and accumulated during our relationship. But JOHN should not have
19
exclusive use of everything. We now have two homes to furnish. I only receive (after
20
paying insurance) $1,290 per month. After paying rent I have very little left to pay for gas
21
and groceries. I cannot afford to go out and furnish an entire new house. But he just says
22
that he should get to use everything we own until trial and I should make do with nothing
23
until trial. This is totally unfair. I do not have money to rent a furnished apartment. I am
24
moving on the first of July into a two bedroom duplex and the rent is $850 per month.
25
R e p ly D e c la r a tio n - P a g e 4 o f 5
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
1
The only item he specifically objects to in my list was the bed. I do not have a bed
2
and I have been sleeping on a friends bed.
our relationship. That is not entirely true he did own it prior to the wedding date, but he
4
5
presumption would apply to the bed. However, if he is unwilling to part with the bed I
would be willing to accept the two reclining leather couches instead. I can use one of
10
11
Regarding attorney fees, he makes far more than I do each month. His gross is
$4,352 and my gross is $2,667.
$1,290.
12
requires him to pay $850 per month toward the health care insurances I pay, he still has
13
14
take positions like I should have no use of property until trial because he has the money
15
for an attorney and I do not. He can take positions like he should be able to use all of the
16
17
18
19
community pension and I should have none of it and without some assistance from him
for attorney fees I will have no ability to maintain a lawyer for a fair division.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
20
21
22
23
BETH KALII
24
25
R e p ly D e c la r a tio n - P a g e 5 o f 5
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHING'
June 06 2014 10:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
Superior Court of Washington
County of PIERCE *
8
9
In re:
JO H N KALII
No. 14-3-01646-7
10
Petitioner,
Financial Declaration
[ ]Petitioner
[X]Respondent
(FNDCLR)
And
11
BETH KALII
12
13
Respondent.
N am e: Beth Kalii
14
15
16
D ate o f Birth:
D eclarant's
D eclarant's
D eclarant's
D eclarant's
Estim ate o f
$1,290.00
$2,150.00
$2,150.00
[X]
t 1
17
18
19
20
U nknow n
O ccupation:
2.2
2.3
21
22
23
24
25
1
III. Income Information
2
3
4
If child su pp ort is a t issue, co m p le te th e W ash in gton State C hild S upport W o rkshe et(s), skip
P arag ra ph s 3.1 and 3.2. If m aintenance, fees, costs or debts are at issue and child su pp ort is Not an
issue th is entire section should be com pleted. (E stim ate o f other party's incom e inform ation is
optional.)
3.1
6
7
8
9
10
11
12
T o ta l G r o s s M o n th ly In c o m e
h.
$ 1 ,2 9 0 .0 0
-
13
14
15
16
17
18
a.
b.
c.
d.
e.
f.
gh.
Beth Kalii
Incom e T axes
F IC A /S elf-e m p lo ym en t T axes
S tate Industrial Insurance D eductions
M an da to ry U n io n/P ro fe ssio n al Dues
P ension Plan P aym ents
S pousal M ainten an ce Paid
N orm al B u siness Expenses
T o ta l D e d u c tio n s fr o m G r o s s In c o m e
20
$ 1 ,2 9 0 .0 0
21
22
23
24
25
(1)
3.4
2
3
John Kalii
Beth Kalii
(lis t s o u rc e a n d a m o u n ts )
4
5
6
7
8
9
10
11
c.
12
13
T o ta l M is c e lla n e o u s In c o m e
(ad d lin e s 3 .4 a th ro u g h 3 .4 b )
3.5
3.6
If th e incom e o f e ithe r party is disputed, state m onthly incom e you believe is correct and
explain below :
4.1
4.2
4 .3
C ash on hand
On d e p o sit in banks
S tocks and bonds
C ash va lu e o f life insurance
O th e r liquid assets:
14
15
16
17
IV .
18
4 .4
A v a ila b le A s s e ts
19
V.
20
21
22
23
M o n th ly E x p e n s e In fo r m a tio n
M onthly e xpe nse s fo r m yse lf and 1 dep en de nts are: (E xpenses should be calculated fo r the future, after
separation, based on th e a nticipated residential sch ed ule fo r th e children.)
5.1
H ousing
Rent, 1st m ortg ag e o r co ntract p aym ents
In sta llm en t p aym ents fo r o the r m ortgages or
e n cu m b ra nce s
T axe s & insu ra n ce (if not in m on thly paym ent)
T o ta l H o u s in g
$850.00
$ 8 5 0 .0 0
24
25
5.2
2
3
4
U tilities
H eat (gas & oil)
Electricity
W ater, sew er, garba ge
T ele ph on e
C able
O ther: Internet
$100.00
$25.00
$100.00
$80.00
T o ta l U t ilit ie s
$ 3 0 5 .0 0
$400.00
$50.00
$50.00
T o ta l F o o d S u p p lie s
$ 5 0 0 .0 0
5.3
6
7
8
9
5.4
10
11
12
5.5
14
5.6
16
17
5.7
22
T ransportation
V e hicle p aym ents or leases
V e hicle insu ra n ce & license
V e hicle gas, oil, o rd in a ry m ainten an ce
Parking
O ther tran spo rtatio n e xpenses
$100.00
$250.00
$ 3 5 0 .0 0
$20.00
T o ta l H e a lth C a re
18
21
$ 5 0 .0 0
T o ta l T r a n s p o r t a t io n
15
20
$50.00
T o ta l E x p e n s e s C h ild r e n
13
19
C hildren
D ay C are/B abysitting
C lothing
T uition (if any)
O th e r child -rela ted e xpenses
$ 2 0 .0 0
$25.00
$50.00
T o ta l P e r s o n a l E x p e n s e s
$ 7 5 .0 0
23
24
25
(1)
Lakewood, WA 98499
(253) 581-0660
SupportCa/c/FD 2014
5.8
2
3
4
5
5.9
T o ta l H o u s e h o ld E x p e n s e s
$ 2 ,1 5 0 .0 0
6
7
8
9
10
11
12
5.11
A m o un t o f
M onthly P aym ent
13
14
15
16
17
18
19
20
21
22
23
24
25
1
2
$ 2 ,1 5 0 .0 0
3
V I.
A tto rn e y F ees
6.1
$1,000.00
6.2
T he so urce o f th is m oney w as: $450 from bake sale at w ork; balance from w ag es and salary
6.3
6.4
6.5
O ther:
10
11
I declare under penalty o f perjury u nd er the law s o f the state o f W ashington th a t the fo re go ing is true and
correct.
S igned at
[City]
[S tate] on
ate].
12
13
14
15
T he fo llo w in g fin an cia l reco rd s are being provided to the o th e r party and filed se pa ra te ly w ith the court.
16
17
18
19
20
21
22
23
24
25
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W A S H IN G
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF PIERCE
10
In re the Marriage of:
11
12
13
14
No. 14-3-01646-7
JOHN ALIKA KALII, JR.
Petitioner,
ATTORNEY FEE
DECLARATION
and
15
My name is DANIEL COOK. I am the attorney for BETH ANN KALII Respondent herein.
16
Pierce, Thurston, King, Kitsap and Mason counties. I am a shareholder with Faubion Reeder
19
20
status) since November of 2003. I have been licensed to practice law in Washington since
21
May of 2004. I devote a substantial portion of my practice, more than 75%, to the practice of
22
family law and domestic relations issues. I actively serve as a Pro Tern Commissioner in
23
24
25
My hourly rate is $215 per hour. Based upon my knowledge of attorneys in the area,
$215/hour is a reasonable hourly rate for an attorney with over 10 years of experience.
A T T O R N E Y F E E D E C L A R A T IO N - P a g e 1 o f 2
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
1
A trained legal assistant assists me by performing many tasks necessary for the
2
efficient practice of domestic relations law. My legal assistant has a Bachelors Degree as
3
well as a Masters Degree in English and a Paralegal Certificate. My legal assistant has
4
5
6
7
more than 11 years of experience assisting attorneys in domestic relations and civil litigation.
It is a benefit to the client for the legal assistant to perform many tasks at a lower hourly rate.
Attached as Exhibit A is a true and correct copy of the billing history produced by my
billing software accurately reflecting the time my client was charged in connection with this
matter. These fees and costs include an estimated two and one-half (2.5) hours of attorney
10
11
12
time for appearance at a hearing on June 11,2014. Exhibit A shows that BETH KALII has
incurred total of $1,789 in fees.
I certify based upon my experience in domestic relations practice that the time
13
18
19
20
21
22
23
24
25
A T T O R N E Y F E E D E C L A R A T IO N - P a g e 2 o f 2
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
Dissolution
5/1/2014
Professional Services
Hrs/Rate
Amount
4/23/2014
DN
Conference
$215.00/hr
0.60
$129.00
5/12/2014
SD
Work
$100.00/hr
0.20
$20.00
5/13/2014
SD
Work
$100.00/hr
1.50
$150.00
DN
Conference
$215.00/hr
2.00
$430.00
SD
Work
$100.00
Beth Kalii
Page
Hrs/Rate
Amount
SD
Work
$100.00/hr
0.10
$10.00
6/2/2014
SD
Work
$10.00
6/4/2014
SD
Work
$100.00/hr
0.10
NO CHARGE
SD
Work
$20.00
6/5/2014
DN
Conference
$322.50
6/6/2014
SD
Work
$60.00
6/11/2014
DN
Ct.
Appearance
for hearing.
$215.00/hr
2.50
$537.50
10.40
$1,789.00
H
RE:
_______________ _________________________________ t
C
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C ourtroom num ber: 100
C alendar:C 1- S H O W C AU SE /FAM ILY LA W
Ixcrtrpt.pbldJoumatjentty_showcause_report
-fo
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
JO H N A L IK A KALII JR
No. 14-3-01646-7
Petitioner(s),
N O TE FO R C O M M IS S IO N E R 'S C A LE N D A R
vs.
BETH A N N KALII
R espondent(s)
P lease ta ke notice th a t an issue o f law in this case w ill be heard on the date and tim e show n below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
DATED:
Signed:
/s / D aniel N C ook
NAME:
D aniel N C ook
Phone:
(253) 581-0660
W SBA#:
34866
Attorney for Respondent
LA K E W O O D , W A 98499-2751
F o r:
1 of 1
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
JO H N A L IK A KALII JR
No. 14-3-01646-7
Petitioner(s),
N O TE FO R C O M M IS S IO N E R 'S C A LE N D A R
vs.
BETH A N N KALII
R espondent(s)
P lease ta ke notice th a t an issue o f law in this case w ill be heard on the date and tim e show n below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
DATED:
Signed:
/s / D aniel N C ook
NAME:
D aniel N C ook
Phone:
(253) 581-0660
WSBA#:
For:
34866
Attorney for Respondent
LA K E W O O D , W A 98499-2751
1 of 1
v 14-3-01646-7
42776450
06-19-14
ORV
1
2
INCOUNTYCORK'S OFFICE
A.M.
\JUN l
P.M.
. K ington
'unty
Clerk
oY_
.DEPUTY
6
7
8
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
AGREED ORDER
VACATING DEFAULT
Respondent.
14
THIS MATTER having come before the above entitled Court upon the agreement
15
16
of the parties, the court being fully advised in the premises, it is it is hereby,
17
18
19
VACATED. The matter shall be set for trial and a case schedule issued.
20
21
22
23
Dated:
JUN 1 9 2014
Juftae/Commissioner
Presented by:
f^AU BroNrTR EED ER r F R A t E /
^JBTONr^EEDE
& C O O K , P.S.
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
1
2
3
4
5
6
7
10
11
12
13
No.
BETH A. KALII,
Petitioner,
DECLARATION PURSUANT TO GR
17
and
14
I, Sally DuCharme, declare under penalty of perjury under the laws of the State
15
16
17
18
19
20
including this declaration page (but not including attachments), and is a complete and
21
legible image that I have examined personally and that was received by me via e-mail at
22
23
[email protected].
Signed at Lakewood, WA on June 17, 2014.
24
25
D e c la r a tio n P u r s u a n t t o G R 17 - P a g e 1 o f 1
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .'
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
JO H N A L IK A KALII JR
No. 14-3-01646-7
Petitioner(s),
N O TE FO R C O M M IS S IO N E R 'S C A LE N D A R
vs.
BETH A N N KALII
R espondent(s)
P lease ta ke notice th a t an issue o f law in this case w ill be heard on the date and tim e show n below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
DATED:
Signed:
/s / T H O M A S R A Y M O N D S ABIN
NAME:
T H O M A S R A Y M O N D SABIN
Phone:
(206) 448-1010
WSBA#:
For:
7748
Attorney for Plaintiff/Petitioner
1 of 1
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, V/z
June 30 2014 2:
KEVIN STO
COUNTY C.l
NO: 14-3-0'(
2
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
7
8
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
Respondent.I.
12
I. MOTION
13
14
15
Based on the declaration below, the undersigned moves the court for a temporary
order which:
A. Approves the parenting plan which is proposed by the Petitioner
16
17
18
19
20
21
22
23
Dated: (C ~o-lb
9^
Thomas R. Sabin, W S b ) t7748Attorney for Petitioner
2
3
4
II. DECLARATION
Temporary relief is required because we have a minor child, KaEna who is 8
years old. Both my wife and I had been active in the raising of our daughter and the day
to day duties regarding our child. I retired from the fire department in January of 2014,
and have been providing the daily care for our daughter since that time. My wife moved
out of the family home on March 30, 2014 when I told her that we needed to discuss a
divorce action. Since that time we have been exchanging the care of our daughter each
10
week on Friday. However, as the schedule has continued it is clear the strain that it is
11
putting on our daughter, and how much time she is spending with me.
12
My wife works as a school bus driver, during the school year and during summer
13
school. During the time that we lived together she left the home at 6:30 a.m. and would
14
not return until 6:30 p.m. Since my wife moved out March 30, 2014, during the school
15
year on the weeks that our daughter is scheduled to be with her mother, our daughter
16
has been awakened at her mothers house at 5:00 a.m., driven to my house and
17
dropped off at my house at 5:30 a.m. She is often very tired and cranky. She attempts
18
to get some more sleep at my house until I get her up at 6:40 a.m. to meet the school
19
bus at 7:20 a.m. She returns to my house every day from school at 2:45 p.m. and is
20
then picked up by one of my wifes daughters from my house about 7:30 p.m. and her
21
bed time is 9:00 p.m. Additionally, from May through June she was involved in track
22
club on Monday, Wednesdays and Fridays and isnt dropped off at her mothers house
23
until 8:00 p.m. This drain on her time is impacting her development by negatively
impacting her sleep and will have a negative impact on her school performance if it
continues.
The Respondent is also driving for summer school and works on June 23-27,
July 7-11 and July 21-25 and then her regular school schedule will start on August 27,
2014. Assuming that the weeks with her during the summer would be the weeks of
June 30-July 4, July 14-July 18, July 28-August 1, and August 11- August 15 I would
have no problem with the alternating weeks during the summer. However, once school
During the school schedule I am asking for one weekend per month to have our
10
daughter with me so that I can have some non school time with her to do things with her
11
and for her to spend time with her friends in the neighborhood. Otherwise, it makes little
12
sense for the health of our daughter to spend 1:55 of her waking hours with her mother
13
during the week, due to her mothers work schedule. She is picked up and dropped off
14
for the school bus every day from my house. During the 6 hours and 40 minutes she
15
spends with me she has to try to catch a nap and we can do some homework. We need a
16
parenting plan that recognizes what is good for our daughter rather than our own needs.
17
Additionally, my wife has recognized in text messages to me that our daughter wants to
18
19
I make a net income from my retirement of $4,028.91. My wife has a net income
20
of $2,160.03. I have attached to this declaration a child support worksheet. I think that
21
the court should take this into account when deciding the motions regarding the
22
23
th ro u g h m e o r on h e r o w n a t th is tim e . S he sh o u ld g e t s o m e in s u ra n c e on h e r ve h ic le . I
a nd has n o t re tu rn e d . S he c la im s to be m o v in g to h e r ow n a p a rtm e n t th is w e e k . I
10
11
S ig n e d a t L a ke w o o d , W a sh in g to n th is 3 0 th d a y o f Ju ne , 2014.
12
13
14
15
16
17
18
19
20
21
22
23
(CSWP)
F ather
$4,352.37
M other
$2,667.00
$4,352.37
$2,667.00
$323.46
$19.86
$123.89
$5.35
$46.10
$254.11
$323.46
$4,028.91
$449.31
$2,217.69
$6,246.60
)
$887.00
.645
.355
$572.12
$314.88
$1,216.00
$572.12
$314.88
Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
10. Health Care Expenses
a. Monthly Health Insurance 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)
d. Combined Monthly Health Care Expenses
(line 10c amounts combined)
11, Day Care and Special Expenses
a. Day Care Expenses
b. Education Expenses
c. Long Distance Transportation Expenses
d. Other Special Expenses (describe)
Mother
Father
-
_
_
.
$572.12
$314.88
17. Standard Calculation (line 15 minus line 16d or $50 per child
whichever is greater)
$572.12
$314.88
$1,813.01
$997.96
$143.03
$78.72
18. 45% of each parent's net income from line 3 (.45 x amount from
line 3 for each parent)
19. 25% of each parent's basic support obligation from line 9 (.25 x
amount from line 9 for each parent)
Mother's
Household
-
Father's
Household
$36.00
Father's
Household
Mother's
Household
--------- ---------
26,
Father's Signature
Mother's Signature
Date
City
Judicial/Reviewing Officer
Date
City
Date
SupportCalc * 2014
1
2
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
DECLARATION OF SIGNATURE ON
ELECTRONIC DOCUMENT
Respondent.
12
I declare under penalty of perjury of the laws of the State of Washington that the
13
foregoing electronic document attached to this declaration, which consists of 10 pages
14
including this declaration page, is a complete and legible image that I have examined
15
personally and that was received by me via email at the following address:
16
tsabin@ goldbergjones.com.
17
18
19
20
21
22
23
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W>
June 30 2014 2:
KEVIN STO
COUNTY C.l
NO: 14-3-0'(
2
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
Respondent.
12
This parenting plan is a Temporary Plan proposed by the Petitioner, John Kalii.
13
14
15
I. GENERAL INFORMATION
16
This parenting plan applies to the following child:
17
Name
Kaena Kalii
18
Age
8
19
II.
20
21
22
2.1
23
2.2
2
3
4
School Schedule
Upon enrollment in school, the child shall reside with the Petitioner, except for
the following days and times when the child will reside with or be with the other parent:
Every weekend except the second weekend of each month from 6:00 p.m. Friday
10
11
The school schedule will start when each child begins kindergarten
3.3
12
13
following days and times when the child will reside with or be with the other parent:
In odd numbered years the child shall be with the mother from end of school to
14
15
16
December 25th at noon and the father from December 25th at noon until the start of
classes following the winter vacation. In even numbered years the child shall be with
the father from the end of school until December 25th at noon and with the mother from
December 25th at noon until 7:00 p.m. the day before classes recommence.
17
18
3.4
19
20
21
following days and times when the child will reside with or be with the other parent:
In odd numbered years the child shall spend the mid-winter break with the mother and
the spring break with the father. In even numbered years the child shall spend the
spring break with the mother and mid-winter break with the father. Mid-winter and spring
22
23
break shall begin at the end of school and terminate at 7:00 p.m. the day before school
is scheduled to restart.
3.5
Summer Schedule
Upon completion of the school year, the child shall reside with the father, except
for the following days and times when the child will reside with or be with the other
3
parent:
Same as paragraph 3.2
4
5
3.6
exercised during the summer vacation from school. Notice of the proposed dates for
8
9
10
2014 shall be made by July 15th. For every other year the notice of the proposed dates
of the vacation must be communicated to the other parent on or before May 15th. In the
event of a conflict in dates, mothers dates shall control in even numbered years and the
fathers proposed dates in odd numbered years.
11
12
3.7
13
The residential schedule for the child for the holidays listed below is as follows:
14
With Father
15
16
17
18
19
20
21
22
23
With Mother
For purposes of this parenting plan, a holiday shall begin and end as follows (set
forth times):
Martin Luther King, Memorial Day, Labor Day shall include Saturday and Sunday
immediately preceding the holiday and shall end at 7:00 p.m.
July 4th shall begin at 9:00 a.m. July 4th and end at noon July 5th.
3
4
3.8
The residential schedule for the child for the following special occasions (for
8
9
With Father
None
Every
None
Every
Odd
With Mother
Every
None
Every
None
Even
Special occasions shall begin at 6:00 p.m. the day before the special occasion
10
11
and shall end at 7:00 p.m. the day of the special occasion.
In the years the mother is not scheduled to have the child on the childs birthday,
12
13
14
the mother shall have a period of up to four hours with the child during one of the seven
days preceding the childs birthday for a birthday celebration.
3.9
Paragraphs 3.3 - 3.8, have priority over paragraphs 3.1 and 3.2, in the following
15
16
order:
Rank the order of priority, with 1 being given the highest priority:
17
18
3.10
23
Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
21
22
19
20
2 holidays (3.7)
3.11
Transportation Arrangements
Transportation costs are included in the Child Support Worksheets and/or the
vehicle, the child shall be secured at all times in the safety restraints as provided by
3
4
5
applicable law and any person transporting the child shall have a valid drivers license
and valid liability insurance.
3.12
The child named in this parenting plan is scheduled to reside the majority of the
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Designation of Custodian
time with the father. This parent is designated the custodian of the child solely for
purposes of all other state and federal statutes which require a designation or
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determination of custody. This designation shall not affect either parents rights and
responsibilities under this parenting plan.
3.13
If the mother will be late for, or will be unable to exercise any scheduled period of
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Other
residential time with the child, the mother shall notify the father by telephone at least 48
hours prior to the scheduled beginning of the mothers scheduled residential time. If the
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Mother is unable to provide the 48 hour notice; said notice shall be made as soon as the
mother is aware of the delay/miss of residential time. If the mother complies with this
notice requirement, the mother shall have the right to make-up residential time with the
child as established between the parents. If the mother fails to comply with the notice
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requirement the mother shall not be permitted make-up time with the child.
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3.14
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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.
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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
Parenting Plan Proposed by Petitioner
Page 5
1
2
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
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contempt.
If no objection is filed within 30 days after service of the notice of intended
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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
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An objection may be filed by using the mandatory pattern form WPF DRPSCU
07.0700, (Objection to Relocation/Petition for Modification of Custody Decree/Parenting
Plan/Residential Schedule). The objection must be served on all persons entitled to time
with the child.
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The relocating person shall not move the child during the time for objection
unless: (a) the delayed notice provisions apply; or (b) a court order allows the move.
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
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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
Day-to-Day Decisions
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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
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4.2
Major Decisions
Major decisions regarding each child shall be made as follows:
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Education decisions
Non-emergency health care
Religious upbringing
Drivers License
Marriage prior to age 18
Entry into military prior to 18
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4.3
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above.
V. DISPUTE RESOLUTION
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Joint
Joint
Joint
Joint
Joint
Joint
The purpose ofthis dispute resolution process isto resolve disagreements about
carrying out thisparenting plan. This dispute resolution process may, and under some
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local court rules or the provisions ofthisplan must be used before filinga petition to
modify the plan or a motion forcontempt forfailingto follow the plan.
Disputes between the parties, other than child support disputes, shall be
submitted to (list person or agency):
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mediation by Pierce County Center for Dispute Resolution, if this box is checked
and issues of domestic violence or child abuse are present, then the court finds that the
victim requested mediation, that mediation is appropriate and that the victim is permitted
to have a supporting person present during the mediation proceedings, or
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The cost of this process shall be allocated between the parties as follows:
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50% Petitioner 50% Respondent.
The dispute resolution process shall be commenced by notifying the other party
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by written request.
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(a)
(b)
Unless an emergency exists, the parents shall use the designated process
counseling or mediation and of each arbitration award and shall be provided to each
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party.
(d)
If the court finds that a parent has used or frustrated the dispute resolution
process without good reason, the court shall award attorneys fees and financial
sanctions to the other parent.
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(e)
The parties have the right of review from the dispute resolution process to
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VI. OTHER PROVISIONS
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A.
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Each parent shall provide the other with the address and phone number of
Neither parent shall make derogatory comments about the other parent or
allow anyone else to do the same in the children's presence. Neither parent shall allow
or encourage the children to make derogatory comments about the other parent.
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C.
access and unhampered contact and communication between the children and the
other parent, and to promote the emotions of affection, love and respect between the
children and the other parent. Said contact shall include reasonable telephone and
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email contact with the child while away from the parent at the calling parents expense.
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2
All telephone calls shall be made between the hours of 5:00 p.m. and 8:00 p.m. Monday
through Friday or 9:00 a.m. and 8:00 p.m., during weekends or days where there is no
school for the child. If a parent calls and is unable to speak with the child, the parent
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shall leave a message and the other parent shall ensure that the child calls back as
soon as is possible, but no later than 24 hours thereafter. Neither parent shall listen in
on the telephone conversations between the child and the other parent, except with the
express consent of the calling parent,
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D.
All mail and packages sent to the child by a parent shall be given to the
child immediately upon arrival at the other parents residence. The parent at the childs
location shall provide any necessary assistance with opening and/or reading the
contents of the mailing container.
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E.
Neither parent shall use the child to request additional or altered time with
that parent. The parenting plan shall be supported by both parents in the presence of
the child. Neither parent shall use the child as a go-between for communication with the
other parent. Neither parent shall discuss with the child or within the childs hearing any
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disagreements or pending court actions the parents may have against the other.
F.
Each parent shall have the right to equal access to all the childs medical,
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limited to, any records being kept by or maintained by the State of Washington
Department of Social and Health Services, Child Protective Services Division, or any
other agency of Washington or any other state in which the child may reside. Any third
party having or maintain any such records is hereby authorized to release any and all
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G.
The childs school shall be kept informed of both parents addresses and
home and work telephone numbers, and the school shall be requested to send
information to both parents for such events as either parent requests.
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5
H.
Each parent shall have equal and independent authority to confer with
school, day care and other programs with regard to the childs progress, and each shall
have free access to school, day care and other records. Each parent shall have
authority to give parental consent or permission as may be required concerning school,
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day care o other programs for the child while the child is in her or her care.
I. Each parent shall have equal and independent authority to obtain information
regarding the well-being of the child, including but not limited to, copies of report cards,
school meeting notices, vacation schedules, class programs, request for conferences,
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results of testing, results of diagnostic tests, notices of activities involving the child,
samples of school work, order forms for school pictures, and all communications from
all schools, regular day care providers, and counselors. Each parent shall notify the
other, as soon as that information becomes known to the parent, of any parent teacher,
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conferences to be conducted regarding the child, and the other parent shall have the
right to attend any such conference.
J. Each parent shall have equal and independent authority to arrange routine
medical, optical, and dental services for the child, after coordinating with the other
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parent, while the child is in his or her care and residence. The parent scheduling any
such services shall provide the other parent with the name, address and office
telephone number of said care provider.
K. If a parent obtains emergency health care for a child, the parent shall notify
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the other parent as soon as possible of the fact that such care has been obtained, the
nature of the illness or injury and the contact information for reaching the care provider.
L. Each parent has the duty to respect the parenting style and authority of the
other parent, and neither parent shall attempt to undermine the authority of the other
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parent with the child. Neither parent will make plans or arrangements involving the child
which would impinge upon the other parents authority or time with the child, without the
express agreement of the other parent. If a child has a grievance with a parent, the
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2
p a re n t in q u e stio n .
M. T h e p a rtie s m a y m a ke m in o r a d ju stm e n ts, a s n ece ssary, to th e p ro visio n o f
th is P a re n tin g P la n b y a g re e m e n t. A s a p re c o n d itio n to a g re e in g to a n y su ch
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4
5
la w m u st b e filed .
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I d e c la re u n d e r p e n a lty o f p e rju ry u n d e r th e la w s o f th e s ta te o f W a s h in g to n th a t
th is pla n h a s bee n p ro p o se d in goo d fa ith and th a t th e s ta te m e n ts in P a rt II o f th is Plan
a re tru e and co rrect.
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^7
6 -3 0 -2 0 1 4 , L a ke w o o d , W a s h in g to n
John A. K alii
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V III. O R D E R B Y T H E C O U R T
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by
Petitioner
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D ated:_________________
____________________________
Judge/Commissioner
Presented by:
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
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and
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BETH A. KALII,
DECLARATION OF SIGNATURE ON
ELECTRONIC DOCUMENT
Respondent.
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I declare under penalty of perjury of the laws of the State of Washington that the
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foregoing electronic document attached to this declaration, which consists of 13 pages
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including this declaration page, is a complete and legible image that I have examined
15
personally and that was received by me via email at the following address:
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tsabin@ goldbergjones.com.
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E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
July 01 2014 12
KEVIN STO
COUNTY C .
NO: 14-3-0' i
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
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and
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BETH A. KALII,
SUPPLEMENTAL DECLARATION OF
JOHN KALII RE RESPONENT'S MOTION
RE USE OF PROPERTY AND PAYMENT
FROM RETIREMENT
Respondent.
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I am the Petitioner in this action and make this declaration in response to the
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motion of the Respondent for use of property and payment from my retirement fund.
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Initially her request for the use of property has for the most part been complied
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with at this time. The remaining issue is her demand for my bed or the couches that I
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have. I purchased the bed before we were married and while we were not living
18
together. It was purchased at a time where she had moved out due to conflict over her
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alcohol use and I had paid for her moving expenses in the Spring of 2009, and had
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given her the king size bed that we had. I had to purchase a bed, which is the one that I
21
have at that time and it is my only bed. The bed that belongs to our daughter I have
22
already given to her and is a trundle bed, meaning there are actually two beds in the
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set.
In reply Ms. Kalii indicated that she would instead take the only couches that we
have. She has two beds already, and she has a couch and chair in her living room now.
There is no reason that my house should be stripped of the only bed that I have and the
As to her request for a portion of my pension I believe that it is also an issue that
should await the trial. Although there is a community aspect to my pension, it may very
well be offset by the community aspect to her retirement plan through the state. The
court should also take into account the $5,800 that I had to pay towards the community
income tax obligation this year. It is also to note that my pension is the only thing that I
10
receive. As a retired firefighter, I do not get social security, and a portion of this pension
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is in lieu of social security. She did not file any bank records, so we do not know what
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liquid assets she has available to her. Taking all of that into account, I do not believe
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that the court should give her a portion of my pension on temporary orders. They have
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made it clear that it is not a request for spousal maintenance, that it is a request for a
15
distribution of an asset.
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In reviewing Ms. Kaliis financial declaration she has significantly understated her
17
income. In the one pay stub that she provided her gross earnings through April 30,
18
2014 year to date were $10,556.35. That is an average monthly gross salary of
19
$2,639.08 per month. If you look at her income figures for the prior year the average
20
salary was $2,667.00 per month. I believe her monthly base salary is spread out over
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12 months even though it is earned late August through June of the following year.
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Additionally, this year she is driving for summer school which will increase her salary by
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the earnings made during the summer. Further, her financial declaration does not take
S h e c h o se to m o ve into a d u p le x on a la k e fo r $ 8 5 0 p e r m on th w h e n th e re are
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e xtra m o n e y to p a y to her.
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______ , 201 4.
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Kmafl* [email protected]
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
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JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
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and
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BETH A. KALII,
DECLARATION OF SIGNATURE ON
ELECTRONIC DOCUMENT
Respondent.
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I declare under penalty of perjury of the laws of the State of Washington that the
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foregoing electronic document attached to this declaration, which consists of 4 pages
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including this declaration page, is a complete and legible image that I have examined
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personally and that was received by me via email at the following address:
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tsabin@ goldbergjones.com.
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E-FILED
IN COUNTY C L E R k
PIERCE COUNTY, W
July 01 2014 1 2
KEVIN STO
COUNTY C .
NO: 14-3-0'i
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
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JOHN A. KALII,
Petitioner,
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and
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BETH A. KALII,
CERTIFICATE OF
PARENTING CLASS
COMPLETION
OF
Respondent.
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Attached is a copy of the Certificate of Completion for the Dont Forget the Kids
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seminar.
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Attorney for Petitioner
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Page 1
A .
(CAL11
Respondent
John
k ^ a lii
Certificate of Completion
Dated this 23rd day of June, 2014
In the City of Lakewood, State of Washington
Instructors:
R o b e rt Steger, M S W
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W ASHINGT
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
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No. 14-3-01646-7
JOHN A. KALII,
Petitioner,
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and
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BETH A. KALII,
Respondent.
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COMES NOW attorney for Respondent, Daniel N. Cook, and presents to the
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DATED this
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C o v e rp a g e - P age 1 o f 1
S:\CASES1\Kalii\DRAFTS\Pleadings\Coverpage.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th S treet SW , Suite 25
Lakewood, W A 98499
253-581-0660
C om m ents:
Ms. Beth Kahlii is a positive influence on her students. She is able to com m unicate effectively w ith
students, coworkers, school staff, and the com m unity. Ms. Kahlii dem onstrates th a t she possesses the
specialized skills needed in o rd er to drive her bus safely. She is able to successfully com plete tasks that
are assigned to her at a m om ents notice. Beth is very dependable and conscientious in the jo b that she is
doing each day.
Date
E m ployee Signature
Date
C om m ents:
Beth Kalii daily interactions w ith s ta ff has been professional and appropriate. H er perform ance m eets or
e xceeds departm ent sta nd ard o f expectations as it relates to interactions with students, attendance,
driving abilities and personal responsibilities (i.e., accurate reporting o f tim e). Beth has been utilized by
the dispatchers at a m om ents notice to assist the team due to a b se n ce o f a nother sta ff m em ber, lost staff
or forgotten students. She openly accepts these changes to her routine and schedule.
T ha nk you Beth fo r being a g re a t m em ber o f the team and m odel for others.
Em ployees Name
Beth Kalii__________________________________________
Transportation / ASC______________________
Paul Vigil__________________________________________
C om m ents:
Beth is an excellent bus driver; she is self-m otivated and com pletes her daily duties with little or no
supervision. She is alw ays w illing to help out and does on a regular basis.
Beth has very few student
discipline issues on her bus as she is very active in preventing problem s before they start. Dispatch has
been able to use Beth on a fe w o ccasions to help during the activity time, to a ssist other buses that have
student discipline issues and no one else is available to assist from the office. T ha nk you for a great year.
I look forward to w orking with you again next year.
C om m ents:
Ms. Beth Kalii m akes a positive im pact on the students w ho ride her bus. She com m unicates with
credibility and confidence with cow orkers, school staff, and the com m unity. Ms. Kahlii dem onstrates a
high level o f com petence in the driving o f her bus. She displays a strong com m itm ent to successfully
com pleting all ta sks th a t are assigned to her. She follow s a variety o f approaches in activities and
techniques.
E m ployees N am e
Beth Kalii__________________________________________
T ransportation___________________________
Evaluator's N am e
Date o f Evaluation
05/17/10______________________________ ____________
C om m ents:
Beth m aintains a positive attitude when under stress and adapts well to change. She is professional and
appropriate in her com m unications with everyone in transportation. She is w illing to ask fo r help from
transportation and school sta ff when needed. She m eets or exceeds the expectations o f the
transportations departm ent.
Com m ents:
Ms. G ilm ore's perform ance as a bus d rive r m eets d epartm ent's expectations as outlined in th e class
specification. She reg ula rly perform s her dutie s and re sp o n sib ilitie s w ithout notice and interacts w ith
d epartm ent staff, school peers in a professional app ro priate manner.
Ms. G ilm ore has been utilize d th ro ug h ou t the y e a r to co ve r va riou s routes and is alw ays w illing to
support her co-w orkers and the departm ent.
D uring this rating period Ms. G ilm ore received a docum ented w ritten w arning fo r a tra ffic infraction.
Mrs. G ilm ore attended the Kids at Hope training, she show s a strong com m itm ent to the students and
com m unity that everyone is capable o f success, no exceptions.
Em ployee S ignature
Date
S u pe rviso r Signatured
Date
Employees Name
Transportation Department____________
Evaluators Name
Delohie Nielsen________________________________
Date of Evaluator
5/19/2009_____________________________________
The above named employee has met his/her job duties and responsibilities.
Comments:
Ms. Beliveau-Gilmores performance as a bus driver meets the expectations as outlined in the class
specifications. During this year, Ms. Beliveau-Gilmore was presented with various student behavior
challenges. Once we were able to clearly define the roles of each team member, set expectations for
students; provide consistent service and consequences the challenges were reduced. This could not have
been accomplished without Ms. Beliveau-Gilmores open mindedness and desire to be an effective
resource in her students' day.
Thank you for your hard work and commitment to those students you transport.
Date
!fh M
Date
Copy - Evaluatee
Copy - Evaluator
C om m ents:
Ms. G ilm o re's perform ance as a bus d riv e r m eets d epartm ent's e xpe cta tio n s as outlined in the class
sp ecificatio n. She regularly p erform s her d utie s and responsibilities w ith o u t notice and interacts with
d e p a rtm e n t sta ff, school peers in a professional appropriate m anner.
M s. G ilm o re has been u tilize d th ro ug h ou t th e y e a r to c o v e r va rio u s routes to su pp ort her co-w orkers and
th e d e p artm en t during e xcessive absences.
C om m ents:
Mrs. G ilm ore's perform ance as a bus driver m eets departm ent's expectations as outlined in the class
specification. She regularly perform s her duties and responsibilities w ithout notice and interacts with
departm ent staff, school peers in a professional appropriate m anner.
T hank you fo r a g re at school year.
PURPO SE:
W hen com pleted, this perform ance appraisal will serve as a guide fo r adm inistrative review o f an e m p lo ye e's status and
perform ance with the Em ployer.
It will be the im m ediate supe rviso r's responsibility to review and approve the cu rren t jo b description and to m a ke the
prim ary evaluation o f those em ployees w orking w ithin his or her area o f responsibility w ith the division a dm in istrato rs
approval.
A full and fra n k discussion w ith an em ployee concerning his or her w ork perform an ce is required. It w ill contribute toward
a better relationship betw een the em ployee and supervisor if conducted sincerely and wisely.
PROCESS:
Utilizing the key
done during the
responsibility or
individual rarely
each rating.
outlined below, rate the level o f perform ance o f each job responsibility and w ork trait on the basis o f w ork
year. Do not let your appraisal o f one responsibility or w ork tra it influence your rating o f another
w ork trait. Do not consult or recall prior ratings. You will be m ore o bjective if you fo rg e t them . One
m erits identical ratings in every responsibility or w o rk trait. Be se le ctive m ake independent decisions on
C onsider Overall P erform ance w ithout undue em phasis on recent or infrequent o ccurrences.
U nder C om m ents you m ust explain individual ratings and/or m ake recom m endations fo r a prom otion, tra n sfe r or further
training needs.
A ny recent C hanges in Job R esponsibilities (typical w ork) m ust be recorded on the last page fo r fu tu re review.
PE R FO R M AN C E KEY:
* 1. O utstanding (exceptional high level o f perform ance and ability).
2. S uperior (perform ance and ability above the average level).
3. Average (perform ance and ability adequate and acceptable).
* 4. Below expected level.
5. N /A (not applicable).
______* M ust be substantiated by a conference report or notation from adm in istrato r / supervisor.
Page 1 of 5
PERFORMANCE
KEY
1. Operates school buses on assigned routes and trips in accordance with state and district policies.
2. Practices defensive driving at all times and displays courtesy to other vehicle operators.
3+
3. Operates bus with mechanical efficiency at all times and in an appropriate manner.
4. Completes necessary paperwork, including daily bus logs and vehicle reports in accordance with district policy.
5. Maintains student discipline on the bus, completes misconduct reports in accordance with district policy.
3+
6. Performs daily vehicle inspection, fueling and interior cleaning of the bus as outlined in district procedures.
3+
9. Maintains a current first aid card and Washington State School Bus Drivers permit
10. Maintains good public relations within the district and community.
Page 2 of 5
W O R K T R A IT S (P le a s e co n tin u e
j s e k e y to d e s c rib e p e rfo rm a n c e .)
1
A T T IT U D E
M J J D
C O M M U N IC A T IO N
W ritte n
Oral
C O O P E R A T IO N
C onfidentiality
X
X I
XI
P R O F E S S IO N A L G R O W TH
Subordinates
PLA N N IN G
A b ility to plan ahead in order to m eet changing needs
H E E D
JU D G M E N T
A b ility to arrive consistently at (a) sound decision(s).
O R G A N IZA T IO N
r a n
W o rk assignm ents
T E C H N IC A L S K IL L S
- As required by jo b description
im m
V O LU M E O F W O R K
Page 3 of 5
H a v in g ra te d e a c h r e s p c .. J b i l i t y a n d w o r k t r a it,
p le a s e in d ic a te w h a t th e e m p lo y e e s o v e r a ll
p e r fo r m a n c e is in h is o r h e r p r e s e n t p o s it io n .
EC
Page 4 of 5
TO BE COMPLETED BY EMPLOYEE/SUPERVISOR
C O M M E N T S : Mrs. G ilm ore continues to perform her duties and responsibilities w itho ut notice as it relates to the class
specification o f school bus driver. She has gained and developed her know ledge, abilities and experience in w orking with
students with disabilities. H er u pbeat personality assists her in her overall p erform an ce o f providing excellent service for
NOTE: It is understood that in signing the evaluation form, the employee acknowledges having seen and discussed the contents with his or her
immediate supervisor.
Page 5 of 5
outlined below, rate the level o f perform ance o f each jo b responsibility and w ork trait on the basis o f work
year. Do not let your appraisal o f one responsibility or w o rk trait influence your rating o f another
w ork trait. Do not co n su lt or recall prior ratings. You will be m ore objective if you fo rg et them . One
merits identical ratings in every responsibility or w ork trait. Be selective, M ake independent decisions on
C onsider O verall Perform ance w itho ut undue em phasis on recent or infrequent occurrences.
U nder C om m ents you m ust explain individual ratings and/or m ake reco m m en d atio ns fo r a prom otion, tran sfe r or further
training needs.
A ny recent Changes in Job R esponsibilities (typical w ork) m ust be recorded on the last page fo r future review.
P E R FO R M A N C E KEY:
* 1. O utstanding (exceptional high level o f perform ance and ability).
2. Superior (perform ance and a bility above the average level).
3. Average (perform ance and a bility adequate and acceptable).
Below expected level.
^5 J N /A (not applicable).
* Muu st be substantiated by a co nference report or notation from a dm in istrato r / supervisor.
Page 1 of 5
J O B R E S P O N S IB IL IT IE S (typit
PERFORMANCE |
KEY
3
______________
2. Practices defensive driving at all times and displays courtesy to other vehicle operators.
3. Operates bus with mechanical efficiency at all times and in an appropriate manner.
4. Completes necessary paper work, including daily bus logs and vehicle reports in accordance with district policy.
5. Maintains student discipline on the bus, completes misconduct reports in accordance with district policy.
6. Performs daily vehicle inspection, fueling and interior cleaning of the bus as outlined in district procedures.
9. Maintains a current first aid card and Washington State School Bus Drivers permit.
10. Maintains good public relations within the district and community.
1
r
______________
J
1
______________ j|
f
Page 2 of 5
(
W O R K TR A ITS (Please contini^ .j use key to describe performance.)
1
A TTITU D E
im n
C O M M U N IC A TIO N
X
X
Written
Oral
C O O PER A TIO N
X
X
X
X
D ELEG ATIO N
Ability to effectively assign work to others
D E P EN D A B ILITY
X
X
Performance
Attendance
Confidentiality
PR O FE SS IO N A L G R O W TH
M JO D
W ork assignments
TE C H N IC A L S K ILLS
As required by job description
VOLUM E OF W O RK
M I
in a given time.
C U R R E N T O V ER A LL P ER FO R M A N C E
DISTRIBUTION: Original - Personnel
Page 3 of 5
H a v in g ra te d e a c h re s , v is ib ility a n d w o r k tr a it,
p le a s e in d ic a te w h a t th e e m p lo y e e s o v e r a ll
p e r fo r m a n c e is in h is o r h e r p r e s e n t p o s itio n .
Page 4 of 5
C H A N G E IN J O B R E S P O N S I eL
TIES (Please list any recent major change^ .. i the employee's responsibilities that you
feel should be review in the future by the School District.)
T O B E C O M P L E T E D B Y E M P L O Y E E /S U P E R V IS O R
C O M M EN TS: Mrs. Gilmore's positive, willing to learn and make a difference personality has assisted her in becoming
very versatile in her abilities and knowledge. As an alternate and regular driver, Mrs. Gilmore is able to perform any route
assigned to her without incident, at various times these routes were assigned at a moments notice. Mrs. Gilmore's ability
to adapt and adjust is evident by her transition ease from driving a regular bus route to driving a special service bus route.
I encourage Mrs. Gilmore to regularly review her resources (i.e., department employee and Washington.State School Bus
//
EMPLOYEE
'
NOTE: It is understood that in signing the evaluation form, the employee acknowledges having seen and discussed the contents with his or her
immediate supervisor.
Page 5 of 5
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W ASHING T
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
10
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
11
and
12
BETH A. KALII,
Respondent.
13
I.
14
Relief Requested
15
BETH KALII, Respondent, moves the court for an order shortening the period of
16
time required for a hearing regarding a Motion for Temporary Order to be heard on July
17
14, 2014, when the parties are scheduled to be in court on this matter for a hearing on
18
Petitioners motion.
19
20
This motion is based upon the Motion and Declaration for Temporary Order
submitted herewith.
21
, 2014.
22
F/^ B I O ^ E ^ D |^ F R A L E Y & COOK PS
23
24
25
M o tio n f o r a n O r d e r S h o r te n in g T im e - P a g e 1 o f 1
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
3
4
5
6
7
8
9
10
No. 14-3-01646-7
JOHN A. KALII,
Petitioner,
11
and
12
BETH A. KALII,
Respondent.
13
14
15
16
This matter having come before the court on Respondents Motion for Order
Shortening Time, the court having reviewed the records and court files herein and
otherwise deeming itself fully advised, it is hereby ORDERED:
17
The motion is GRANTED; time for hearing the motion for temporary order is
18
shortened and the hearing date is set for July 14, 2014, at 9:00 a.m.
19
20
Dated:
Judge/Commissioner
21
22
Presented by:
FAUBION, REEDER, FRALEY & COOK, P.S.
23
24
25
O r d e r S h o r te n in g T im e - P a g e 1 o f 1
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W ASHING T
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
10
11
and
12
BETH A. KALII,
Respondent.
13
I. Motion
14
15
Based on the declaration below, the undersigned moves the court for a temporary order
which:
16
17
18
19
20
21
DATED this 3
22
23
24
M o tio n f o r T e m p o r a r y O r d e r - P a g e 1 o f 2
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
1
II. Declaration
2
Temporary relief is required because:
3
4
5
See Declaration of Beth Kalii in Response to Petitoiners motion for temporary order
which is incorporated herein by this reference,
,o
^
7?-ffpo
pfifl 7 1 f S
f a / i ^ ^ T J ^ C
6
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
7
8
Signed at (city)
on (date) _
10
BETH KALII, RESPONDENT
11
12
13
14
15
16
17
18
19
20
21
22
23
24
M o tio n f o r T e m p o r a r y O r d e r - P a g e 2 o f 2
K alii, B e th a n d K alii, J o h n
S:\CASES1\Kalii\DRAFTS\Pleadings\Motion for Temporary Order2.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W A SH IN G '
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
10
11
No. 14-3-01646-7
JOHN A. KALII,
Petitioner,
12
and
13
BETH A. KALII,
Respondent.
14
15
16
17
18
19
20
Name
Age
KAENA KALII
21
II. Basis for Restrictions
22
23
24
Under certain circumstances, as outlined below, the court may limit or prohibit a
parents contact with the child and the right to make decisions for the child.
2.1
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 1 o f 1 0
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
S:\CASES1\Kalii\DRAFTS\Pleadings\PPP.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
253-581-0660
1
2.2
2
Does not apply.
3
4
5
6
7
8
3.1
10
11
3.2
School Schedule
Upon enrollment in school, the child shall reside equally with both parents on the
following schedule:
12
13
The child shall reside with the parents on a rotating and repeating
alternating week on/week off schedule. Exchanges from one home to the
other will be on Fridays after school or at 2:00 p.m. if there is no school.
14
15
3.3
16
17
18
The child shall reside with each parent during winter vacation as follows:
Winter Vacation shall be defined as commencing the day after school lets out for
the Winter Vacation Break and concluding on the day before school resumes.
19
In even numbered years, the mother shall have the child for the first
half of the Winter Vacation. Visitation shall begin the day after
school lets out at 9:00 a.m. until December 27th at 8:00 p.m. In
even numbered years the father shall have the child from
December 27th at 8:00 p.m. through the day before school
resumes at 6:00 p.m.
20
21
22
23
In odd numbered years, the father shall have the child for the first
half of the Winter Vacation. Visitation shall begin the day after
school lets out at 9:00 a.m. and conclude on December 27th at
8:00 p.m. The mother shall have the child from December 27th 8:00
p.m. through the day before school resumes at 6:00 p.m.
24
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 2 o f 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
3.4
2
The child shall reside with each parent during spring break as follows:
3
The first half of Spring Break shall be with the parent who has the child the
prior week under the alternating week schedule (Par. 3.2); the second half
of Spring Break shall be with the parent who has the child the week after
Spring Break under the alternating week schedule (Par. 3.2). The
exchange shall be on Wednesday at 12:00 p.m. unless otherwise agreed
by the parties.
4
5
6
7
3.5
Summer Schedule
8
Upon completion of the school year the child shall reside with each parent as follows:
9
Same as school year schedule.
10
11
3.6
12
13
Each parent shall notify the other parent in writing of his or her two weeks
of vacation no later than May 1 of each year. If there is a conflict in
vacation dates the fathers choice will control in odd years and the
mothers choice will control in even years.
14
15
16
17
18
19
20
21
22
23
24
3.7
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 3 o f 10
S:\CASES1\Kalii\DRAFTS\Pleadings\PPP.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
Holidays marked with an asterisk (*) shall be spent with the parent who is entitled to
the preceding weekend under the alternating week schedule.
Unless otherwise noted, Holidays shall be the night before at 6:00 p.m. until the day of
the Holiday at 8:00 p.m.
4
5
July 4th will be from 10:00 a.m. on July 4 until 12:00 p.m. on July 5.
3.8
The residential schedule for the child for the following special occasions (for
example, birthdays) is as follows:
8
9
10
Mothers Day
Fathers Day
Fathers Birthday
Mothers Birthday
Childs Birthday
11
12
13
With Mother
(Specify Year
Odd/Even/Everv)
Every
With Father
(Specify Year
Odd/Even/Everv)
Every
Every
Every
Odd
Even
If the Special Occasion is on a non-school day, the Special Occasion shall be the
night before at 6:00 p.m. until the day of the Special Occasion at 8:00 p.m.
14
15
If the Special Occasion is on a school day, the Special Occasion shall be from after
school on the day of the Special Occasion until the8:00 p.m. on the day of the Special
Occasion.
16
17
18
3.9
Paragraphs 3.31 - 3.8, have priority over paragraphs 3.1 and 3.2, in the following order:
19
20
Rank the order of priority, with 1 being given the highest priority:
4
2
holidays (3.7)
school breaks (3.4)
6
1
special occasions (3.8)
summer schedule (3.5)
3
winter vacation (3.3)
5
vacation with parents (3.6)
21
22
23
24
3.10
Restrictions
Does not apply.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 4 o f 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
S:\CASES1\Kalii\DRAFTS\Pleadings\PPP doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
253-581-0660
3.11
Transportation Arrangements
2
3
Transportation costs are included in the Child Support Worksheets and/or the
Order of Child Support and should not be included here.
5
6
7
8
3.12
Designation of Custodian
The child named in this parenting plan are scheduled to reside the majority of the
time with both parents equally. Both parents are designated the custodian of the
child solely for purposes of all other state and federal statutes which require a
designation or determination of custody. This designation shall not affect either
parents rights and responsibilities under this parenting plan.
10
11
12
3.13
Other
13
Neither parent shall consume non-prescribed drugs or alcohol in excess of the
legal limit to drive while he or she is personally caring for the child.
14
15
The father shall provide proof of treatment for his alcohol addiction issues.
16
Each parent acknowledges that the other parent spends substantially equal
residential time with the child. For purposes of any future relocation of the child,
neither parent may claim the presumption under RCW 26.09.520 favoring
relocation of the child and both parents are required to give the notice of
relocation under RCW 26.09.430 and .440 when relocating. Based upon the
child's long-term involvement in school, athletics and other extra-curricular
activities, the existence of family and social relationships and the connections to
health care professionals all in the Pierce County area the parties agree that the
child should remain in the Pierce County area if one parent decides to relocate
out of the Pierce County area.
17
18
19
20
21
22
23
24
3.14
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 5 o f 10
S:\CASES1\Kalii\DRAFTS\Pleadings\PPP.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
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).
2
3
4
5
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.
6
7
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.
8
9
10
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.
11
12
Failure to give the required notice may be grounds for sanctions, including
contempt.
13
14
15
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.
16
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.
17
18
19
The relocating person shall not move the child during the time for objection
unless: (a) the delayed notice provisions apply; or (b) a court order allows the
move.
20
21
If the objecting person schedules a hearing for a date within 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
23
4.1
Day-to-Day Decisions
Each parent shall make decisions regarding the day-to-day care and control of
each child while the child is residing with that parent. Regardless of the allocation
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 6 o f 10
S:\CASES1\Kalii\DRAFTS\Pleadings\PPP.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
of decision making in this parenting plan, either parent may make emergency
decisions affecting the health or safety of the child.
2
3
4.2
Major Decisions
Major decisions regarding each child shall be made as follows:
Education decisions
Non-emergency medical and mental health care
Religious upbringing
joint
joint
joint
Regarding medical decisions, either parent may take the child for regularly
scheduled appointments with their ordinary physicians, dentists or medical
care providers for check-ups, vaccinations, routine/recurring doctor or
dental appointments or for treatment of mild or seasonal type illnesses
(e.g., cold, flu, allergy, earaches, anti-biotic, short term prescriptions etc.)
without triggering joint decision-making requirements. The parties shall
communicate as much as possible about even these routine medical and
dental decisions to ensure coordination of care and full advice to the
medical professionals caring for the child.
8
9
10
11
12
Joint decision means that the parent seeking to make a major decision
shall notify the other parent of the proposed major decisions he or she
intends to make and the other parent may object to the decision and/or
propose an alternative within 14 days of notice. If the other parent does
not object or propose an alternative the parents decision shall be final and
he or she may proceed immediately after the expiration of the 14 days.
The parent seeking to make a decision shall not take any irreversible
action in furtherance of a proposed major decision until after 14 days
notice, or, until after an agreement is reached or a court order is issued if
the other parent objects to the decision.
13
14
15
16
17
18
19
20
4.3
21
22
23
24
V. Dispute Resolution
The purpose o f this dispute resolution process is to resolve disagreements about
carrying out this parenting plan. This dispute resolution process may, and under som e
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):
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 7 o f 10
S:\CASES1\Kalii\DRAFTS\Pleadings\PPP.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
1
2
3
The cost of this process shall be allocated between the parties as follows:
5
8
9
10
11
12
13
14
The dispute resolution process shall be commenced by notifying the other party
by written request via certified mail:
In the dispute resolution process:
(a)
Preference shall be given to carrying out this Parenting Plan.
(b)
Unless an emergency exists, the parents shall use the designated process
to resolve disputes relating to implementation of the plan, except those
related to financial support.
(c)
A written record shall be prepared of any agreement reached in
counseling or mediation and of each arbitration award and shall be
provided to each party.
(d)
If the court finds that a parent has used or frustrated the dispute resolution
process without good reason, the court shall award attorneys fees and
financial sanctions to the other parent.
(e)
The parties have the right of review from the dispute resolution process to
the superior court.
15
20
21
22
23
24
Each party shall have the right to equal access to all of the childs medical,
psychological, psychiatric, counseling, criminal, juvenile, and educational records,
and to any other information relevant to the childs best interest or welfare. These
may include, but not be limited to, any records being kept or maintained by a
State or Federal government department or agency. Any third party having or
maintaining any such records is hereby authorized to release any and all
information upon presentation of this order. Any person, including, but not limited
to, any physician, psychologist, counselor, officer or educator, may speak candidly
of or concerning the child named herein to either of the above named parents
without court order or subpoena authorizing same, upon presentation of this
order. It shall be the responsibility of the parent requesting the records to do so
directly with the source of the records.
Both parties shall allow the child to freely communicate with the other party,
including allowing the child to call the other party on the telephone. Both parties
shall have telephone access with the child, excluding the childs calls to that
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 8 o f 1 0
S:\CASES1\Kalii\DRAFTS\Pleadings\PPP.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
1
2
3
4
5
6
7
8
9
10
11
12
13
party, of not less than two calls per week at reasonable times and for reasonable
durations.
To the greatest extent possible, the parents shall communicate with each other
by e-mail. Each parent shall maintain an e-mail account for this purpose and
keep the other party informed of their e-mail address.
Neither party shall discuss the residential schedule with the child except for plans
that have already been agreed to by both parties. Neither party shall provide
information to the child of the status of child support payments or other legal
matters regarding the parties.
Neither parent shall make disparaging remarks about the other parent or any
other remarks that might cause diminishment of the childs respect for the other
parent either to the child or in the presence of the child, nor shall they allow the
child to make disparaging remarks about the other parent.
14
15
16
17
" / ( 3> / Z d / y
Date and Place of Signature
18
It is ordered, adjudged and decreed that the parenting plan set forth above is adopted
and approved as an order of this court.
19
WARNING: Violation of residential provisions of this order with actual knowledge of its
20
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.
21
22
23
When mutual decision making is designated but cannot be achieved, the parties shall
make a good faith effort to resolve the issue through the dispute resolution process.
If a parent fails to comply with a provision of this plan, the other parents obligations
under the plan are not affected.
24
Dated:________________________________
____________________
Judge/Commissioner
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 9 o f 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
S:\C4SES1\Kalii\DRAFTS\Pleadings\PPP.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
1
2
Presented by.
FAUBION, REEDER, FRALEY & COOK, P.S.
3
4
5
6
7
Date
Date
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 10 o f 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
S:\CASES1\Kalii\DRAFTS\Pleadings\PPP.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
E-FILED
IN COUNTY CLERK'S OFFICI
PIERCE COUNTY, WASHINGT
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
RESPONSE DECLARATION OF
BETH KALII
Respondent.
14
15
I, BETH KALII, make this declaration on the basis of my personal knowledge and in
16
response to Petitioners Motion for Temporary Order and Proposed Parenting Plan filed
17
18
SUMMARY
19
20
21
22
1. The court deny Petitioners motion for parenting plan designating him as the
Primary parent.
2. The court should adopt my proposed parenting plan maintaining the equally
shared residential schedule with both parents as co-primary parents.
23
3. The court should order child support paid to me with a slight deviation for
24
Petitioner based upon the residential time the child spends with him.
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00 th S treet SW , Ste 25
Lakew ood, W A 98499
253-581-0660
1
4. The court should award me attorneys fees and costs incurred in bringing this
2
motion.
3
PARENTING PLAN
4
5
JOHN and I began living together in 2006. We had a child, KAENA KALII, on
June 27, 2006. JOHN voluntarily chose not to be present at the hospital with me when
KAENA was born. JOHN kicked me out of his house five days after KAENA was born.
Eventually, we got back together and we began living together again in 2007. We were
10
11
12
Since we separated in March 2014 KAENA has been spending equal residential
time in both of our homes. After we separated JOHN went to We The People and
prepared dissolution documents. JOHN told me since he was retired and l was working
13
he would get custody if it was contested; however, JOHN told me if I would not ask for
14
however, there were other (financial) issues we did not agree. So JOHN filed for
18
dissolution and asked for primary placement in his proposed parenting plan.
19
JOHN filed for dissolution and filed a proposed parenting plan asking for primary
20
21
after I filed a motion asking for JOHN to pay the cost of his health care insurance and for
22
one-half of the community portion of his retirement that he brought this motion to change
23
Even after
24
attorney he kicked my daughter out of his house and wrote her a note saying:
25
R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 2 o f 7
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
I dont like doing this, but Im going to have to ask you to find
2
Attached as Exhibit A is a true and correct copy of the note he left my daughter.
JOHN is trying to punish me for asking him to pay his own insurance and for one-
half of the community portion of the retirement. I did not even ask for child support in my
initial motion. We were operating under a 50/50 parenting plan and it was working very
10
well for KAENA. But after I filed a motion asking for financial relief JOHN told my other
11
12
adult daughter she had to move out and then filed his own motion to only allow KAENA
to spend weekends with me.
13
Aside from being totally financially motivated, the picture that JOHN paints in his
14
declaration about the parenting plan is totally misleading and false. It omits crucial
15
information.
16
17
First, JOHN neglects to inform the court that for about one month after we
18
separated I formally added a stop to my bus route so that I could pick KAENA up from
19
the home where I was living with a roommate. So I would leave for work in the morning
20
and KAENA could stay in bed because my roommate was home and KAENA would not
21
have to wake up until her normal time to get on the bus outside of my house. That
22
schedule was in place for about a month until my roommate had surgery and I did not
23
want to leave KAENA with her in the mornings for the last week of school.
24
25
R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 3 o f 7
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
Second, for the very first month after I moved out, while I was in the process of
2
getting the new stop on my route established at my home, I lived 15 minutes away from
3
JOHN. I agree that it was not ideal to wake KAENA up early when I was leaving - but
4
5
also I do not think it was as bad as JOHN suggests. First, I did not wake KAENA up at
5:00 a.m. I had to be at work at 6:00 a.m. and I dropped KAENA off at his house at 5:45
a.m. so I woke KAENA up between 5:15 and 5:30. Many children have to get up early
when their parents leave for work early in the morning. Nevertheless, if the early wake-
up could be avoided I would avoid it and that is why I added the stop to my route.
10
11
12
Next year things will be substantially different. When we separated in April 2014 I
was already under contract for the school year so I was stuck in the shift that required me
to clock in at 6:00 a.m. Next year, I will contract for a different route even though that
13
14
years, and I am number 33 in seniority out of 100 drivers in my district. So I have a very
15
substantial number of choices of routes. I can very easily contract for a route that
16
17
18
19
requires me to clock in at 7:00 a.m. and then I will not have to drop KAENA off until 6:45
a.m.
Another big change now versus last school year is that I have moved from the
20
temporary place I was sharing with a roommate immediately after separation and have
21
established my own residence. My duplex is only 0.36 miles away from JOHNS
22
23
24
route and because I now live less than 5 minutes away from JOHN I will not have to wake
25
R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 4 o f 7
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
KAENA up until 6:30 a.m. which is only 10 minutes earlier than JOHN alleges she wakes
2
up in his home.
3
Another change that has occurred is that my adult daughter is now residing with
4
5
KAENA and me and depending upon her work schedule I may not even need JOHN to
provide any before or after school care for KAENA because my adult daughter will be
there and can watch her. Because my income is so low I also qualify for substantially
reduced before and after school care fees. The bottom line is that yes, on the weeks
10
KAENA spends with me I am working but that is not different than the vast majority of
11
12
parents in this country who have to have their children in before and/or after school care
while they work. I would like KAENA to spend time with her father rather than daycare
13
and that is why we have worked the schedule out the way we have, and that is one
14
reason I chose a duplex only 0.36 miles from JOHNS house. But my work schedule is
15
JOHN also fails to mention that my work schedule during the summer is
18
substantially different than during the school year. Frankly, I am irritated that I am even
19
20
2 summers. I have to work this summer because JOHN is refusing to pay for his medical
21
insurance.
22
contracted hours last school year. I clock in at 6:45 a.m. so I drop KAENA off at 6:30
23
24
But with that aside, my work schedule is different during the summer than my
a.m. and since we are now living so close I only wake her up about 6:20 - so only 20
minutes earlier than he alleges she woke up at his house during the school year. And
25
R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 5 o f 7
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
KAENA can sleep in much longer after I drop her off during the summer.
I will also be
2
off work for the entire month of August. There is simply no reason to modify the week
3
4
5
on/week off schedule in the summer and because my work schedule will begin later in the
fall, there is no reason to modify it once the school year begins again.
JOHN also makes reference to my alcohol use in one of his declarations. This is
have a problem with alcohol and I am frequently subjected to random UAs testing for all
illegal substances and I am frequently subject to a random alcohol test prior to work (my
10
boss has a Breathalyzer in her office). All of the full-time bus drivers are subject to these
11
tests.
Ironically,
12
JOHN has multiple speeding tickets and has been arrested at least three times, including
13
once for DUI.
14
his DUI.
15
16
17
JOHN also makes a reference to track that KAENA was enrolled in for a while.
What JOHN fails to mention is that both JOHN and I stopped taking her to track. We
18
both came to the same conclusion that with the adjustment and transition after separation
19
20
CHILD SUPPORT
21
22
23
24
I have adopted the calculations JOHN used in his child support worksheets for our
respective incomes.
the amount of $234.34 which is the amount JOHN previously admitted was the child only
portion of the health care insurance. This results in a standard calculation of $723 per
25
R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 6 o f 7
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
month. If JOHN receives a 100% deviation for a 50/50 residential schedule credit the
2
transfer payment is still $279.77. I ask the court to order $450 per month for child support
3
which will cover child support including JOHNS portion of KAENAs health care
4
5
insurance.
JOHN says I am understating my income but I am not. The problem is, my net
income is extra-ordinarily low due to the fact that I am being charged $730 per month for
his health care insurance. So that substantially lowers my income available to pay rent,
and buy food, gas and pay necessary bills and expenses.
10
ATTORNEY FEES
11
12
KAENA is not
suffering under the week on/week off schedule. I have made changes since the date of
13
separation (later work start time and found a residence close to the fathers home) to
14
15
me for bringing a motion for financial relief and he is trying to use custody of KAENA as
16
17
18
spent approximately 3.5 hours and charged me $750 in reviewing the materials filed by
19
JOHN related to the parenting plan and responding to them. I ask the court to award me
20
$750 for the attorneys fees incurred in responding to the parenting plan motion.
21
22
23
24
BETH KALII
25
R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 7 o f 7
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
EXHIBIT A
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7 /3/2014
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7/3/2014
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
$ 5 7 2 .1 2
$ 3 1 4 .8 8
$ 1 ,2 1 6 .0 0
$ 5 7 2 .1 2
$ 3 1 4 .8 8
F a th e r
M o th e r
-
$ 2 3 4 .3 4
$ 2 3 4 .3 4
$ 2 3 4 .3 4
$ 2 3 4 .3 4
$ 1 5 1 .1 5
$ 8 3 .1 9
9 plus
line 14)
$ 7 2 3 .2 7 |
$ 3 9 8 .0 7
9)
$ 2 3 4 .3 4
$ 2 3 4 .3 4
17. Standard Calculation (line 15 minus line 16d or $50 per child
whichever is greater)
$ 7 2 3 .2 7
$ 1 6 3 .7 3
$ 1 ,8 1 3 .0 1
$ 9 9 7 .9 6
$ 1 4 3 .0 3
$ 7 8 .7 2
P a r t V II: A d d it io n a l In f o r m a t io n a l C a lc u la tio n s
18. 45% of each parent's net income from line 3 (.45 x amount from
line 3 for each parent)
19. 25% of each parent's basic support obligation from line 9 (.25 x
amount from line 9 for each parent)
P a r t V III: A d d it io n a l F a c to r s f o r C o n s id e r a tio n
Father's
Household
Mother's
Household
26.
Father's
Household
Mother's
Household
-
Judicial/Reviewing Officer
Date
Ka'ena Kalii
$887.00
$887.00
183
50.1
182
23. %OVERNIGHTS-FATHER
(Line 22 divided by 365)
49.9
.500
.500
$443.50
$443.50
91 NIGHTS
$723.27
$443.50
$279.77
by
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHINGT
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
10
11
12
13
14
No. 14-3-01646-7
JOHN ALIKA KALII, JR.
Petitioner,
and
ATTORNEY FEE
DECLARATION
15
My name is DANIEL COOK. I am the attorney for BETH ANN KALII Respondent herein.
16
Pierce, Thurston, King, Kitsap and Mason counties. I am a shareholder with Faubion Reeder
19
20
status) since November of 2003. I have been licensed to practice law in Washington since
21
May of 2004. I devote a substantial portion of my practice, more than 75%, to the practice of
22
family law and domestic relations issues. I actively serve as a Pro Tern Commissioner in
23
24
My hourly rate is $215 per hour. Based upon my knowledge of attorneys in the area,
25
$215/hour is a reasonable hourly rate for an attorney with over 10 years of experience.
A T T O R N E Y F E E D E C L A R A T IO N - P a g e 1 o f 2
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
A trained legal assistant assists me by performing many tasks necessary for the
2
efficient practice of domestic relations law. My legal assistant has a Bachelors Degree as
3
well as a Masters Degree in English and a Paralegal Certificate. My legal assistant has
4
5
more than 11 years of experience assisting attorneys in domestic relations and civil litigation.
It is a benefit to the client for the legal assistant to perform many tasks at a lower hourly rate.
The following is an itemization of the fees charged to BETH KALII associated with the
responding to Petitioners Motion for Temporary Order and bringing Respondents own
10
7/3/2014
$645
7/14/2014
$107.50
11
12
13
TOTAL
14
15
16
17
18
0.5
$752.50
I certify based upon my experience in domestic relations practice that the time
charged was necessary and reasonable.
I DECLARE UNDER PENALTY OF PERJURY ACCORDING TO AND UNDER
THE LAWS OF THE STATE OF WASHINGTON THE ABOVE STATEMENTS ARE
TRUE AND CORRECT.
19
20
21
22
23
24
25
A T T O R N E Y F E E D E C L A R A T IO N - P a g e 2 o f 2
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
E-FILED
IN CO UNTY CLERK'S C
PIERCE COUNTY, WASH
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646
3
4
5
6
7
10
11
JOHN A. KALII,
No. 14-3-01646-7
Declaration of
A
Petitioner,
12
13
and
Z ,
[Name]
BETH A. KALII,
& n J x S 6 r?
Respondent
14
15
16
17
Name:
ei
-Z
Aqe:
J
Relationship to Party(ies):
Z r
^
t
/ c V plZ
18
19
20
21
22
(stateI )P ~ ) on (date)
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
- ii- I lI S
!i 7 7
>
.1
! I'
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I have no doubt that Bo loves his daughter. And I have witnessed the father
daughter bond. But I have also witnessed angry outburst and heard him degrade and
insult Beth. On one occasion I was on the phone with a mutual friend while Bo was
yelling very mean insults to Beth in the background. I asked where Beth was and was
told she was in the bedroom with Kaena trying to protect her daughter from hearing
daddy yelling out adult insults.
Its my opinion based on the violence and background of this other woman, as
well as her well documented hatred of Beth, and Bos adult insults and outburst, that
Kaena should be kept safe in her mothers (sic) custody. I think Bo with his daughter on
visits are good, but I urge the court to keep the other woman away from Kaena.
s/ Cathy Gibson
6/16/2014
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E-FILED
IN CO UNTY CLERK'S O
PIERCE COUNTY, W ASH
NO: 14-3-01646
2
3
4
5
6
7
10
11
JOHN A. KALII,
No 14-3-01646-7
Declaration of
Petitioner,
12
and
13
BETH A. KALII,
[Name]
Respondent.
14
15
Aqe:
Lf^j
16
17
Relationship to Party(ies): _ P n i n j
d0uj(yth _
18
l_________
19
20
21
22
Signed at (city)
23
24
A
Signature
'
'
--------- -*
25
Declaration C overpage P age 1 o f _______
S:\CASES1\Kalii\DRAFTS\Pleadings\Dec Coverpage.docx
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
7-3-2014
Thank you
s/Kelly Hartman
1 -3 -& W
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E-FILED
IN CO UNTY CLERK'S O
PIERCE COUNTY, WASH
NO: 14-3-0164 5
2
3
4
5
6
7
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Declaration of
[Name]
Respondent.
14
15
Name: / R P .n e.
P /)&
Age:
16
17
Relationship to Party(ies):
l/u M n r L
18
20
21
22
K ^ llJ n a d
. (state) U I a on (date)
23
24
>ignature
U LL
6 . 0 tA J
25
F A U B IO N , REEDER,
F R A L E Y & C O O K, P.S.
I have known Beth Gilmore Kalii for about eight years. She is a hard working
dedicated person; not only on the job but also as a mother.
She has a contagious smile and gets along with most everyone she meets. She
is easy to get along with and is very outgoing.
She is a wonderful person to be around and takes her friendships to heart.
She looked forward to her future not only as a mother but also as a wife. When
she received her camping trailer for her birthday last year from her husband, she was
estatic (sic). She looked forward to spending many nights out camping with family and
friends. She has had a rough patch of late but she has pulled herself up, holds her
head high and goes on; stronger and more dedicated than before.
It is unfortunate that because she is paying so much out of her check for medical
for Bo and her daughter that she now has very little money left for herself for food and
other necessities. Her friends from work make sure she eats at least once a day but
she still has lost over 30 lbs and is still dropping. She could use a little help as she left
with only her clothes and one cooking pot. Bo wants even the pot back.
- L~
have
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E-FILED
IN CO UNTY CLERK'S O
PIERCE COUNTY, WASH
K n o io
1
2
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D^ rtroO/)cd .
6
7
8
9
10
11
JOHN A. KALII,
12
and
13
BETH A. KALII,
Declaration of
[Name]
Respondent.
14
15
No. 14-3-01646-7
Petitioner,
Name:
C l j6LC R __________
Aoe: ^ 1
16
17
Relationship to Party(ies): C o
k )o r IC C /'
18
20
21
22
k f ) k z . i^/Q
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on (date) \ W i r
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23
24
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25
Declaration Coverpage Page 1 o f______
S:\CASES1\Kalii\DRAFTS\Pleadings\Dec Coverpage. docx
00 P
F A U B IO N , R EEDER,
F R A L E Y & C O O K , P.S.
I know Beth as a co worker and Relay for Life. She is a wonderful mother. She
had her daughter with her at some of the Relay Fundraisers. They had a lot of fun.
Beth always had something for her to do and never acted like she was interupting
(sic). Her daughter has shown that some one loving (Beth) has given her structure and
manners. And is a delightful child to be around
There was one day Beth and I were on the computer at work searching for Relay
For Life products. I was looking for Thundersticks. Beth asked what they were and that
she wanted some. I told her they were long inflated balloons that when hit together
makes a big sound. Smiling she ask is this going to get my daughter in trouble cause
her Dad likes it quiet around the house? Another coworker said yup! She said shed
let her play with them when hes not home.
Two days after I gave Beth a pair of Thundersticks. She said her daughter love
them and when her dad came home she, the daughter, stuck them in her roller skates
and rolled them around the house.
s/Jana Clark
July 1, 2014
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E-FILED
IN COUNTY CLERK'S C
PIERCE COUNTY, W ASH
NO: 14-3-01646
2
3
4
5
6
7
8
9
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Declaration of
[Name]
Respondent.
14
15
Name:
16
17
Age: S T S "
Relationship to Party(ies):
18
__________
19
20
21
22
Signed at
, (state) U J J V on (date) ^
) A-
23
24
Signature
25
Declaration Coverpage Page 1 of
S:\CASES1\Kalii\DRAFTS\Pleadings\Dec Coverpage.docx
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
7/3/14
s/Sidney D. Gilbert
__
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4--------;------ :-------------------------
E-FILED
IN CO UNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
2
3
4
5
6
7
9
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Declaration of
[Name]
Respondent.
14
15
Name:
Age:
16
( t e - l iy n k e i i ;
17
1/1 p n A ik e ^
u -qajjJ
18
20
21
22
, (state) IV A on (date)
*)"
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
July 3, 2014
I have worked with Beth for the past nine years. During that time I have
observed Beth as a hard worker, a good friend and a wonderful mother.
I now have the privilege of being Beths next door neighbor. Beth goes beyond
the call of duty to maintain a warm, clean living environment for her family.
s/Talley Schlag
_____________________________________________ A la k ,
I_____________ ___
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E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
July 11 201 9:
KEVIN STO
COUNTY L
NO: 14-3-01
2
3
4
5
6
7
8
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,*I
Respondent._______________________________________
12
13
I am the Petitioner in this action and make this declaration in reply to the false
14
and misleading statements made about me by my wife and her friends. Regarding the
15
declarations that have been filed by her friends, they are not based upon seeing me
16
with my daughter, or being in my house. They are based on what they have been told.
17
18
19
20
21
22
23
The fact of the matter is that, I personally do not know or even been around 5 of these 6
people and they have never even been to my home. My question is...How can they
possibly comment on who I am, what I've said or done, or what kind of parent I am, if
they don't even know me or been around me?
I filed my motion for a parenting plan based upon trying to do what is best for our
daughter. It is not good for her to be bounced around from house to house to school etc
through her school week. I am retired and have been providing the bulk of the
parenting for our daughter since I retired in January of 2013. My wife did not object to
Reply Declaration of John Kalii
Page 1
that, but for her own personal sense of self worth, she would rather have our daughter
transferred a number of times each day on the weeks she is to be with her mom, and to
be cared for by an aunt rather than our daughters father, solely for money and
winning.
May, not June. She and Ka'ena did not live with me until Ka'ena was over a year old. I
did not kick her out of my house 5 days after our daughter was born. Ka'ena has not
been spending equal residential time in our homes as Beth suggests. Although her
nights in each household have been approximately equally split, Kaena spends the bulk
10
of her waking, non school hours with me. Even during Beths week Kaena spends
11
approximately 27-30 hours with me. Her proposed Child Support Schedule worksheet
12
shows her as having Ka'ena 50 percent of the time, which is terribly skewed because it
13
doesn't take into account the total hours and the time taken from my (off week) when
14
she is supposed to be under her mother's care during "Beth's week". When the hours
15
16
I did not offer a 50/50 split if she didnt take money from me. All of her motions
17
have been about money, whereas my motion is based upon what is best for our
18
daughter. I do not believe having her bounced around from house to house during
19
Beths week and impacting her sleep and study schedule is good for our daughter. I
20
do not believe it is best for our daughter to be cared for by an aunt when I am available.
21
If the roles were reversed and I was working from 6:30 a.m. to 6:30 p.m. and her mother
22
was retired there would be no question that the court would think it was best for our
23
daughter to stay with the parent that is home for her during the school week. It is also
important to note that my wife does not deny that I have been providing a substantial
part of the care for our daughter over the last 19 months or that I am a bad parent.
As for Beth's 29 year old daughter, she was initially asked to find another place
because of the conflict issue I had with Beth knowing about everything going on in my
house through her daughter. I later retracted the letter I gave her daughter and told her
she could stay as long as she wished and that if she were ever to need a place, she
It is odd that my wife would allege that I am focused on money, but if you look at
all of her motions, they are only about money. I do need to be able to pay the bills, but I
10
have not objected to paying my portion of the health insurance, just how it is computed.
11
It is my wife that is asking for a pre trial distribution of my pension without ever revealing
12
her bank records and other available resources to the court. It is Beth who is
13
determined to sacrifice what is best for Ka'ena, for monetary gain. Beth claims that she
14
has to work Summer School because I am refusing to pay for my medical. I began
15
paying Beth for my Medical in June and will continue to do so until I am allowed by the
16
Medical Plan to be released. I have tried but it was told by the insurance provider that
17
18
19
attempt at character assassination" as Beth wants to imply. It is real and has been the
20
main reason for our separations in the past and it was stated that it was the basis for
21
our separation in the spring of 2009. A woman who loves and cares so deeply for her
22
child does not drink and smoke during the entire pregnancy of that child! She claims to
23
have taken a number of UAs over the last ten years but has not provided any of them to
the court. But the point is that she is lashing out with whatever dirt she can attempt to
dig up rather than looking at what is best for our daughter. I did not allege that she has
My Parenting Plan is necessary for the best interests of our daughter. It will
eliminate loss of sleep and stress on Ka'ena if she is not shuttled between houses twice
a day during the school weeks that Beth is supposed to have her. She should not be in
day care or cared for by other family members when I am available to provide her care.
It is sad that my wife is looking at this from the perspective of her convenience rather
than what is best for our daughter. Beth claims that her older daughter can provide the
10
care for Kaena while she is working. That daughter has a full time job with Buffelen
11
Lumber Company for over a year and has not had the luxury of caring for Ka'ena,
12
13
14
Kaenas best interest. My wife submits in her declaration how she will get a later start
15
time so she doesn't have to bring Ka'ena to my home so early in the morning, when
16
Ka'ena is supposed to be under her care. What she fails to address is the fact that
17
Ka'ena will still have to be dropped off with me after school to stay until Beth is finished
18
with work and she may very well be working later in the day than she is now due to the
19
change in schedule.
20
21
22
This declaration is given under penalty of perjury of the laws of the State of
Washington and is true and correct to the best of my knowledge.
23
1
2
3
4
5
J o h n K alii
6
7
8
9
10
11
12
13
14
15
16
17
18
19
1
2
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
7
8
JOHN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
DECLARATION OF SIGNATURE ON
ELECTRONIC DOCUMENT
Respondent.
12
13
14
15
16
17
18
I declare under penalty of perjury of the laws of the State of Washington that the
foregoing electronic document attached to this declaration, which consists of 6 pages
including this declaration page, is a complete and legible image that I have examined
personally and that was received by me via email at the following address:
[email protected].
19
20
21
22
23
14-3-01646*7
42912328
07-15-14
CME
No. 14-3-01646-7
M e m o r a n d u m o f J o u r n a l E n tr y
vs.
] Show Cause
BETH ANN KALII
(ADM02)
R espondent(s)
b^AQS
___
S (j
L in d *'
For R espondent
For Petitioner
C)a
RE:
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1
2
3
4
5
6
7
10
No. 14-3-01646-7
11
JOHN A. KALII,
Petitioner,
12
and
13
BETH A. KALII,
Parenting Plan
Temporary (PPT)
Respondent.
14
15
16
17
18
I. General Information
This parenting plan applies to the following child:
19
20
Name
Age
KAENA KALII
21
Under certain circumstances, as outlined below , the court may limit or prohibit a
parents contact with the child and the right to make decisions for the child.
2.1
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 100th S treet SW , Suite 25
L akew ood, W A 98499
253-581-0660
2.2
2
Does not apply.
3
4
5
6
3.1
10
11
3.2
School Schedule
_ --
Upon enrollrmrrtsoschool, the child shall reside equally with both parents on the
following s c h e d u le :^ ^ ^ ^ ^
12
13
The child shall reside with mfes^rents on a rotating and repeating
alternating week on/week off sche&trie^Exchanges from one home to the
other will be on Mondays after school oraF5?Q&p.rn. if there is no school.
14
15
16
17
18
3.3
19
20
21
22
23
24
In even numbered ye^rs, the mother shall have the child for the first
half of the Winter Vacation. Visitation shall begin the day after
school lets out at 9:00 a m until December 27th at 8:00 p.m. In
even numbered years the Tether shall have the child from
December 27th at 8:00 p.m. through the day before school
resumes at 6:00 p.m.
In odd numbered years, the father shall have the child for the first
half of the Winter Vacation. Visitation si^all begin the day after
school lets out at 9:00 a.m. and conclude on December 27th at
8:00 p.m. The mother shall have the child from December 27th 8:00
p.m. through the day before school resumes at 6:00 p.m.
Parenting Plan (PPP, PPT, PP) - Page 2 of 10
W P F D R 01.0400 M a ndatory (6/2008) -R C W 26.09.016, .181; .187; .194
Kalii, Beth and Kalii, John
FA U B IO N , R EED ER ,
3.4
2
ya
***
x
P x L u n fK
The child shall rekkte with each parent during spring break as follows:
/ '7
vJ
The first half of Sf>R(ig Break shall be with the parent who has the child the
prior week under the^lternating week schedule (Par. 3.2); the second half
of Spring Break shall be with the parent who has the child the week after
Spring Break under the alternating week schedule (Par. 3.2). The
exchange shall be on W ednesda^aM 2:00 p.m. unless otherwise agreed
by the parties.
4
5
6
7
3.5
Summer Schedule
8
Upon completion of the school year the child shall reside with each parent as follows:
10
11
3.6
CsfT&rC
Same as SchoohY^ar Schedule, and in addition: each parent shall have two
weeks uninterruptechvith the child for vacation during the summer months when
the child are off from schctok^
12
13
Each parent shall notify the ot?fespgrent in writing of his or her two weeks
of vacation no later than May 1 of eacITYeaF-JHhere is a conflict in
vacation dates the fathers choice will control inocfcbyears and the
mothers choice will control in even years.
14
15
16
17
18
19
20
21
22
23
24
3.7
*
Memorial Day
Easter
Even
Odd
July 4th
Even
Odd
*
*
Labor Day
Veterans Day
Even
Odd
Thanksgiving Day
Odd
Even
Christmas Eve
See Par. 3.3
See Par. 3.3
See Par. 3.3
Christmas Day
See Par. 3.3
P a r e n tin g P la n (P P P , P P T , P P) - P a g e 3 o f 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
Holidays marked with an asterisk (*) shall be spent with the parent who is entitled to
the preceding weekend under the alternating week schedule.
Unless otherwise noted, Holidays shall be the night before at 6:00 p.m. until the day of
the Holiday at 8:00 p.m.
4
5
July 4th will be from 10:00 a.m. on July 4 until 12:00 p.m. on July 5.
3.8
__
The residentteKsQhedule for the child for the following special occasions ( % /
example, birthdays)S$as follows:
8
9
10
Mothers Day
Fathers Day
Fathers Birthday
Mothers Birthday
Childs Birthday
11
12
13
\ j M t h Mother
(Spesify^Year
Odd/Even7Evefv)^
Every
With Father
(Specify Year
Odd/Even/Everv)
E v e r y ^ -^ ^
Every
^
Every
Odd
Even
If the Special Occasion is on a non-school day, the Special Occasion shall be the
night before at 6:00 p.m. until the day of the Special Occasion at 8:00 p.m.
14
15
If the Special Occasion is on a school day, the Special Occasion shall be from after
school on the day of the Special Occasion until the8:00 p.m. on the day..of the Special
Occasion.
16
17
18
3.9
Paragraphs 3.31 - 3.8, have pribqty over paragraphs 3.1 and 3.2, in the following order:
19
20
21
22
23
24
3.10
Restrictions
Does not apply.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 4 o f 10
WPF DR 01.0400 Mandatory (6/2008) - ROW 26.09.016,.
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
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.
6
7
3.12
Designation of Custodian
The child named in this parenting plan are scheduled to reside the majority of the
time with both parents equally. Both parents are designated the custodian of the
child solely for purposes of all other state and federal statutes which require a
designation or determination of custody. This designation shall not affect either
parents rights and responsibilities under this parenting plan.
10
11
12
13
3.13
Each parent acknowledges that the other parent spends substantially equal
residential time with the child. For purposes of any future relocation of the child,
neither parent may claim the presumption under RCW 26.09.520 favoring
relocation of the child and both parents are required to give the notice of
relocation under RCW 26.09.430 and .440 when relocating. Based upon the
child's long-term involvement in school, athletics and other extra-curricular
activities, the existence of family and social relationships and the connections to
health care professionals all in the Pierce County area the parties agree that the
child should remain in the Pierce County area if one parent decides to relocate
out of the Pierce County area.
14
15
16
17
18
19
20
Other
3.14
21
This is a summary only. For the full text, please see RCW 26.09.430 through
26.09.480.
22
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.
23
24
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
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 5 o f 10
W P F D R 0 1 . 0 4 0 0 M a n d a t o r y (6/2008) - R C W 26.09.016, .181; .187;. 1 9 4
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
5920 100th S treet SW , Suite 25
L ake w o od , W A 98499
253-581-0660
1
give notice within 5 days after learning of the move. The notice must contain the
information required in RCW 26.09.440. See also form DRPSCU 07.0500,
(Notice of Intended Relocation of A Child).
2
3
If the move is within the same school district, the relocating person must provide
actual notice by any reasonable means. A person entitled to time with the child
may not object to the move but may ask for modification under RCW 26.09.260.
4
5
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.
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.
10
11
12
13
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.
14
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.
15
16
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.
17
18
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.
19
20
21
4.1
Day-to-Day Decisions
Each parent shall make decisions regarding the day-to-day care and control of
each child while the child is residing with that parent. Regardless of the allocation
of decision making in this parenting plan, either parent may make emergency
decisions affecting the health or safety of the child.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 6 o f 10
W P F D R 0 1 . 0 4 0 0 M a n d a t o r y (6/2008)
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
4.2
Major Decisions
2
Major decisions regarding each child shall be made as follows:
3
Education decisions
Non-emergency medical and mental health care
Religious upbringing
4
5
Regarding medical decisions, either parent may take the child for regularly
scheduled appointments with their ordinary physicians, dentists or medical
care providers for check-ups, vaccinations, routine/recurring doctor or
dental appointments or for treatment of mild or seasonal type illnesses
(e.g., cold, flu, allergy, earaches, anti-biotic, short term prescriptions etc.)
without triggering joint decision-making requirements. The parties shall
communicate as much as possible about even these routine medical and
dental decisions to ensure coordination of care and full advice to the
medical professionals caring for the child.
6
7
8
9
10
11
Joint decision means that the parent seeking to make a major decision
shall notify the other parent of the proposed major decisions he or she
intends to make and the other parent may object to the decision and/or
propose an alternative within 14 days of notice. If the other parent does
not object or propose an alternative the parents decision shall be final and
he or she may proceed immediately after the expiration of the 14 days.
The parent seeking to make a decision shall not take any irreversible
action in furtherance of a proposed major decision until after 14 days
notice, or, until after an agreement is reached or a court order is issued if
the other parent objects to the decision.
12
13
14
15
16
17
joint
joint
joint
4.3
18
Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2.
19
V. Dispute Resolution
20
21
22
23
24
S:\CASES1\Kalii\DRAFTS\Pleadings\TemporaryParentingPlan.doc
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P.S.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
durations.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 8 o f 10
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
To the greatest extent possible, the parents shall communicate with each other
by e-mail. Each parent shall maintain an e-mail account for this purpose and
Neither party shall discuss the residential schedule with the child except for plans
that have already been agreed to by both parties. Neither party shall provide
information to the child of the status of child support payments or other legal
matters regarding the parties.
4
5
6
Neither parent shall make disparaging remarks about the other parent or any
other remarks that might cause diminishment of the childs respect for the other
parent either to the child or in the presence of the child, nor shall they allow the
child to make disparaging remarks about the other parent.
8
9
10
(Only sign if this is a proposed parenting plan.) I declare under penalty of perjury
under the laws of the state of Washington that this plan has been propose^
good faith and that the statements in Part II of this Plan are true and cor;
11
12
13
14
15
16
17
18
19
20
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.
21
22
23
24
If a parent fails to comply with a provision of this plan, the othen parents obligations
under the plan are not affected.
Dated:
1 1
" (
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 9 o f 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
Presented by:
2
3
4
5
6
7
Date
Date
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 10 o f 10
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
3
4
5
6
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
7
8
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
Respondent.
12
I. JUDGMENT SUMMARY
13
1.1
1.2
14
15
16
II. BASIS
17
2.1
Type of Proceeding
18
19
20
21
2.2
22
23
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.
Temporary Order of Child Support
Page 1
1
2.3
Other
2
3
III. FINDINGS AND ORDER
4
It Is Ordered:
5
3.1
6
Name (first/last)
Age
Kaena Kalii
7
8
3.2
9
Name:
Birth date:
Service Address:
10
11
12
13
14
15
CT'OtfW
/i-ZQ-W
970
^ S u ) _______
(-JYiceoJociol ( <*j A- CfS
______
The Obligor Parent Must Immediately File With the Court and the Washington
State Child Support Registry, and Update as Necessary, the Confidential
Information Form Required by RCW 26.23.050.
The Obligor Parent Shall Update the Information Required by Paragraph 3.2
Promptly After any Change in the Information. The Duty to Update the
Information Continues as long as any Support Debt Remains due Under This
Order
16
17
For purposes of this Order of Child Support, the support obligation is based upon the
following income:
18
A.
3.3
^ 0^3'
19
20
21
Name:
Birth date:
Service Address:
22
23
The Obligee Must Immediately File With the Court and the Washington State Child
Support Registry and Update as Necessary the Confidential Information Form
Temporary Order of Child Support
Page 2
C O U M S K K C & JO N E S I U .C
IZIIO Westlake Asc. N Suilc 700
Seville, Wilmington 98100
Tel: (106) 4-18-1010 - Kan: (206H48-0736
Kmail-ISAltl.VffiCOUlKKIiCJOM'lS.rO.M
3
4
5
For purposes of this Order of Child Support, the support obligation is based upon the
following income:
g
A.
7
8
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
10
11
12
Service of Process
13
3.5
Transfer Payment
14
15
16
17
The obligor parent shall pay the following amounts per month for the following
children): f r s U a j 0 /
t
M CffriLo
T4kfA/e 'Asrv
Ttter
' N a m e ^ ^ A m o u n ? ^ 7'3 ne&L7ir
Kaena Kallii
$ (/ G\<Ch oc>
18
19
20
21
[]
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:
22
23
COUHJKItC <s ,j o m :s
n .i .c
1100 West litki A n1, N Suilc 700
Scuttle, W in liiitjtto n 0SIO*)
3.6
2
3
4
Standard Calculation
$ -~?X2>
3.7
[]
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:
10
11
12
13
14
[]
Income of other adults in the household of the parent requesting a
deviation for other reasons;
fp
The chi Id(TerT^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 child(ren)"do(es) not receive public assistance;
TJ^oblkpjMTas^e^iaUijshed-tbatihs-^^
15
'obligee'has-'^stabirsh^d that iFis unjust to apply4h@-slf-supWrt
16
17
[]
18
19
20
21
22
23
3.8
1
3.9
2
Starting Date:
C TtV Ly
Day(s) of the month support is due:
3
4
3.10
*0tC
3*0/7/_________
Incremental Payments
Does not apply.
5
6
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:
9
10
11
12
13
14
[]
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:
15
17
18
19
Name_
Mailing Address_______
16
20
21
22
23
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 :v
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 child(ren).
3.12
1
2
7
8
9
10
11
12
[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.]
Wage withholding, by notice of payroll deduction or other income
withholding action under Chapter 26.18 RCW or Chapter 74.20A RCW, without further
notice to the obligor, is delayed until a payment is past due, because:
^
the parties have reached a written agreement that the court
approves that provides for an alternate arrangement.
13
14
15
[]
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.
16
17
[]
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.
18
Good Cause:
19
20
21
3.13
Termination of Support
22
23
Support shall be paid provided that this is a temporary order, until a subsequent
child support order is entered by this court. ..
*.
c o k d b k iu ; a j o n k s p k l c
1200 WVslIakc A\ e. N., Suite 700
Seattle, Wnthingimi 9K1 09
Tel: (206)448-1010(206)448-0736
Kmail- ISAinNrftCOUHJKRCJONKS.COM
3.14
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.
3
4
3.15
Does not apply because all payments, except medical, are included in the
transfer payment.
S'
. c
The petitioner shall pay
% and the respondent
^
%
(each'parents proportional share of income from the Child Support Schedule
Worksheet, line 6) of the following expenses incurred on behalf of the child(ren) listed in
Paragraph 3.1:)
[]
day care.
[]
educational expenses.
[]
long distance transportation expenses.
[]
other:
6
7
8
9
10
11
12
13
3.16
14
15
Periodic Adjustment
Does not apply.
3.17
16
17
The parents shall sign the federal income tax dependency exemption waiver.
fZ e s & u /6 >
18
3.18
19
Each parent shall provide health insurance coverage for the child(ren) listed in
paragraph 3.1, as follows:
20
21
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.)
22
A.
23
Evidence
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. .
1
B.
2
The court makes the following findings:
3
John Kalii
Beth Kalii
4
11
5
6
[X]
7
8
9
[ i
10
[ ]
11
12
13
11
14
15
[ ]
16
17
18
i i
[ ]
t i
[ ]
19
20
21
22
23
o
1
ir"i
()
C.
Parties obligations:
The court makes the following orders:
2
John Kalii
Beth Kalii
11
[X]
11
f-
11
[ ]
i ]
[ ]
11
[ ]
rj
3
4
,
H
n"i
H
6
7
if)
10
11
r12
13
14
15
16
17
18
19
20
21
22
23
h
Temporary Order of Child Support
Page 9
(7
[ ]
2
3
[ ]
4
(Only one parent may be excused.)
5
6
7
D.
Both parties obligation:
If the child(ren) are receiving state financed medical coverage, the Division of Child
Support may enforce the responsible parents monthly premium.
8
9
10
11
12
13
14
15
16
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.
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.
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.
18
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.
19
20
A parent required to provide health insurance coverage must notify both the Division of
Child Support and the other parent when coverage terminates.
17
21
22
23
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
; .. T
v
RCW.26:18.170.,,If a parent.does not provide proof of accessible coverage for the
child(ren):throughprivate insurance, a parent may be required to satisfy his or her
./.
Tem porary Order of Child Support
Page 10
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 child(ren) 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 child(ren) receives state-financed medical coverage through DSHS under
RCW 74.09 for which there is an assignment.
3
4
5
6
7
8
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.
9
3.19
10
11
12
13
14
Both parents have an obligation to pay their share of uninsured medical expenses.
The petitioner shall pay G
_____ % of uninsured medical expenses (unless stated
otherwise, the petitioners proportional share of income from the Worksheet, line 6) and
the respondent shall pay
_____ % of uninsured medical expenses (unless stated
otherwise, the respondents proportional share of income from the Worksheet,
line 6).
**T'*4fr*Lc
t/vclur&jA-y
f f a t d-Gd-Lr# / * s s o n f a x *
rt is //vtLuv&o ^ rfr?
/ ^ re v s t f / X i r t T f * * # } - S ' 3.20 Back Child Support
(N
No back child support is owed at this time.
No back interest is owed at this time.
15
16
17
3.21
18
19
20
21
3.22
Other obligations that may be owed are not affected by this order.
Back interest that may be owed is not affected by this order.
22
23
:{
, <
r
C O LD IS K R C & JO N K S IM .I.C
1200 WVstliikc A ir. N..Siiilr 700
Sfitltlc, Washington JB1(19
Tel: (206) 448-1010 - Fas: (20(>H4N-0736
Krnail- 'rSAUIN(!nOU)UKU(;.IOM'.S.(;().VI
1
2
through (date)
3.23
Other
3
4
5
Dated: ^ j
1^ f
6
7
8
Presented by:
GOLDBERG JONES PLLC
'9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
(CSWP)
F a th e r
$ 4 ,352 .37
$ 2 ,667 .00
$4,352.37
$ 2 ,667 .00
$323.4 6
$19.86
$123.89
$5.35
$46.10
$254.11
M o th e r
$323.46
$449.31
$ 2 ,217 .69
$4 ,028.91
$6,246.60
"
- v- ';
$887.00
.645
h t-
'i
r *,
ji
.355
$ 5 7 2 .1 2
$ 3 1 4 .8 8
8. C alculating low incom e lim itations: Fill in only those that apply.
S e lf-S up p ort R eserve: (125% o f the Federal P overty G uideline.)
$ 1 ,2 1 6 .0 0
$ 5 7 2 .1 2
$ 3 1 4 .8 8
F a th e r
M o th e r
-
$ 2 3 4 .3 4
$ 2 3 4 .3 4
ft
$ 2 3 4 .3 4
'
13. T otal Health C are, D ay C are, and Special E xpenses (line 10d
plus line 12)
' 4
$ 2 3 4 .3 4
$ 1 5 1 .1 5
$ 8 3 .1 9
$ 7 2 3 .2 7 |
$ 3 9 8 .0 7
$ 2 3 4 .3 4
-
$ 2 3 4 .3 4
17. S tandard C alculation (line 15 m inus line 16d or $50 per child
w h ich e ve r is greater)
$ 7 2 3 .2 7
$ 1 6 3 .7 3
$ 1 ,8 1 3 .0 1
$ 9 9 7 .9 6
$ 1 4 3 .0 3
$ 7 8 .7 2
18. 45% o f each parent's net incom e from line 3 (.45 x am o un t from
line 3 fo r each parent)
19. 25% o f each parent's b asic su pp ort obligation from line 9 (.25 x
a m o u n t from line 9 fo r each parent)
Father's
H ousehold
M other's
H ousehold
a. Real Estate
b. Investm ents
c. V e hicles and Boats
d .B a n k A cco un ts and C ash
e. R etirem ent A cco un ts
f. O ther: (describe)
.
.
-
g .O th e r Incom e (describe)
Father's
H ousehold
M other's
H ousehold
26.
SupportCalc 2014
R E S ID E N T IA L S C H E D U L E C R E D IT U S IN G F O R M U L A
18. O R D IN A R Y EX PE N S E S
19. A D JU S T E D BASIC S U P P O R T
20. O V E R N IG H T S W ITH M O T H E R
21. % O V E R N IG H T S W ITH M O T H E R
(Line 20 divided by 365)
22. O V E R N IG H T S W ITH F ATH ER
Ka'ena Kalii
$887.00
$887.00
183
50.1
182
23. % O V E R N IG H T S -F A T H E R
(Line 22 divided by 365)
49.9
24. M O T H E R S C R E D IT PR O P
.500
25. F A T H E R S C R E D IT PR O P
.500
26. M O T H E R S C R E D IT
(Line 19 tim es Line 24)
$443.50
27. F A T H E R S C R E D IT
(Line 19 tim es Line 25)
$443.50
28. O V E R N IG H T T H R E S H O L D S E LE C T E D :
91 N IG H TS
29. T R A N S F E R P A Y M E N T BE FO R E C R ED IT:
30. R E S ID E N T IA L C R E D IT TO F ather IS:
$723.27
$443.50
31. T R A N S F E R P A Y M E N T A F T E R C R ED IT:
$279.77
10
11
No. 14-3-01646-7
12
JOHN A. KALII,
Temporary Order
(TMO)
13
and
Petitioner,
14
BETH A. KALII,
Respondent.
15
16
17
18
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
22
23
24
25
it is Ordered:
3.1
Restraining Order
There are no restraining orders in effect under this cause number and the court is
not entering one now.
T e m p O rd e r (T M O ) - P a g e 1 o f 4
W PF DR 04.0250 Mandatory (06/2012) - R C W 26.09.060; .110;. 120;. 194, .300(2)
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
3.2
Temporary Relief
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JOHN KALII shall pay m HI- I h r<"Xlt H ? 1! per month representing 76% of the
cost of the childs health care insurance.
JOHN KALII shall m v to
pension income.
J
Starting Date:
Day(s) of the month payment is due:
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-jtjgBPAUPf l a rQ
^0 g **
- p ^ t/tc & p rn ^ ju ( y
ymex/T
By W> eFt/ort/f
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[]
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[]
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Child support shall be paid in accordance with the order of child support,
signed by the court.
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The parties shall comply with the Temporary Parenting Plan signed by the
court.
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[]
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BOTH PARTIES are restrained and enjoined from removing any of the
children from the state of Washington.
Each party shall be immediately responsible for their own future debts
whether incurred by credit card or loan, security interest or mortgage.
T e m p O r d e r (T M O ) - P a g e 2 o f 4
W PF DR 04.0250 Mandatory (0 6 /2 01 2)-R C W 26.09.060; .110; .120; .194,. 300(2)
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
4
5
&
[]
[]
JOHN KALII shall pay temporary attorney fees, other professional fees and
costs in the amount of $_
to: FAUBION, REEDER,
FRALEY & COOK, P.S.
[]
Other:
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K,
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Dated:___2 . /
/ W
T^T^l
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bylARRY COUTURE
Presented by:
FAUBION, REEDER, FRALEY & COOK,
P.S.
T e m p O rd e r (T M O ) - P a g e 3 o f 4
W PF D R 04.0250 Mandatory (06/2012) - R C W 26.09.060; .110;. 120;. 194, .300(2)
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
3
4
Date
Date
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T e m p O r d e r (T M O ) - P a g e 4 o f 4
W PF DR 04.0250 Mandatory (06/2012) - R C W 26.09.060; .110;. 120;. 194, .300(2)
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
IN T H E S U P E R IO R C O U R T O F T H E S T A T E O F W A S H IN G T O N
IN A N D F O R P IE R C E C O U N T Y
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
M o t io n - R e v is io n
C a le n d a r : STEPHANIE A. AREND
Submitted by:
DATED:
Signed:
NAME:
Phone:
(206) 448-1010
WSBA#:
For:
7748
Seattle, WA 98109-3529
1 of 1
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
July 23 2014 12
KEVIN STO
COUNTY CL
NO: 14-3-0H
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR PIERCE COUNTY
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JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
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and
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BETH A. KALII,
Respondent.
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I. MOTION
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tern Larry Coutures ruling from the hearing held on July 14, 2014.
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1. The court enter the temporary parenting plan proposed by the Petitioner.
2. The court should change the temporary order of child support to reflect no
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insurance for the Petitioner and his contribution to his proportional share of the costs of
the health insurance for minor child.
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E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
IN T H E S U P E R IO R C O U R T O F T H E S T A T E O F W A S H IN G T O N
IN A N D F O R P IE R C E C O U N T Y
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
M o t io n - R e v is io n
C a le n d a r : STEPHANIE A. AREND
Submitted by:
DATED:
Signed:
NAME:
Phone:
(206) 448-1010
WSBA#:
For:
7748
Seattle, WA 98109-3529
1 of 1
E-FILED
IN COUNTY CLERK'S OFFICI
PIERCE COUNTY, W ASHING Ti
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
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4
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No. 14-3-01646-7
JOHN A. KALII,
Petitioner,
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and
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BETH A. KALII,
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_________________________ Respondent.
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I. Motion
Based on the declaration below, the undersigned moves the court for a temporary order
which:
Approves the parenting plan which is proposed by BETH KALII,
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DATED this
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Daniel N. Cook, WSBA 34866
Attorney for Respondent
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II. Declaration
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M o tio n f o r T e m p o r a r y O r d e r - P a g e 1 o f 2
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
A temporary residential schedule for the parties child was ordered on July 14, 2014, for
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3
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the summer schedule only. The childs residential schedule for the school year has yet to
be determined. It is necessary to put a hearing on the court calendar in advance of the
new school year so that the childs time with each parent during the school year is clearly
established.
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Signed at (city)
(state)
on (date)
rf'
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BETH KALII, RESPONDENT
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M o tio n f o r T e m p o r a r y O r d e r - P a g e 2 o f 2
FAUBION, REEDER,
F R A L E Y & C O O K , P .S .
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
Please take notice that an issue of law in this case will be heard on the date and time shown below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
DATED:
August 4, 2014.
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
Attorney for Respondent
LAKEWOOD, WA 98499-2751
1 of 1
11miII111! MU I : in.! II
43075795
ORCNT
Respondent.
STIPULATION
COM ES NO W Thomas R. Sabin, attorney for Petitioner, and Daniel Cook,
attorney for Respondent and Stipulate to a continuance of the hearing set for August 15,
2014 for Revision of the July 14, 2014 ruling of Commissioner Pro Tern Larry Couture
due to the absence of the attorney for the Petitioner for bereavement purposes and a
pre scheduled family vacation for the attorney for the Respondent. Counsel stipulate to
the continuance of the hearing to September 5, 2014 which is the next available date,
and consent tg ih e .setting of the hearing after the limitation sent in Civil Rule 59 (b).
The courthaving considered the above stipulation and the files and records
herein and deeming itself fully advised in the premises hereby
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ORDERS, ADJUDGES and DECREES that the Revision hearing set for August
15, 2014 be continued to September 5, 2014.
DATE
y /
S? ^
/y
4
rudae/Gourt Commissioner-
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Presented by:
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DEPT. 12
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W-OPCN COUKT )
AUG 0 8 2014
^PIERCE
COjJNTf,
Clerk
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% MD
No. 14-3-01646-7 /
08-25-14
ORDER SETTING!
CASE SCHEDULI
Petitioner(s)
AU621 2014
pier c e
vs.
COUHty 'lerk
BETH AN N KALII
R espondent(s)
D ocket C ode: O R S C S
('!]I
1,1"l
Set Settlement Conference Date with Judge/Commissioner JOHN A. MCCARTHY (See PCLR 16 & PCLSPR
94.04)
Plaintiffs/Petitioners Disclosure of Primary Witnesses
12/08/14
01/19/15
. -L
H
l^M
j
02/23/15
Discovery Cutoff
03/30/15
04/13/15
04/13/15
i\l
]\!
12/22/14
r\)
02/09/15
Week Of 04/27/15
Tria!
05/11/15 9:00
Unless otherwise instructed, ALL Attorneys/Parties shall report to the trial court at 9:00 AM
on the date of trial.
N O T IC E T O P L A IN T IF F /P E T IT IO N E R
If the case has been filed, the p la intiff shall serve a copy o f the Case S chedule on the d efendant(s) w ith the su m m on s and
com plaint/petition: Provided th at in those cases w here service is by publication the p laintiff shall serve the C ase S chedule
w ithin five (5) court days o f se rvice o f the d efe nd a nts first response/appearanee. If the case has not been filed, but an
initial pleading is served, the C ase S chedule shall be served w ithin five (5) court days o f filing. See PCLR 3.
N O T IC E T O A L L P A R T IE S
All attorneys and parties shall m ake them selve s fa m ilia r with the Pierce C ounty Local Rules, particularly those relating to
case scheduling. C om pliance w ith the scheduling rules is m andatory and failure to com ply shall result in sanctions
appropriate to the violation. If a sta te m e nt o f arbitrability is filed, PC LR 3 does not apply w hile the case is in arbitration.
ORDER SETTING
CASE SCHEDULE
Petitioner(s)
vs.
CC:
D ocket C ode: O R S C S .
Page 2 of 2
S u p e r io r C o u r t
14-3-01646-7
43169102
LTR20
08-25-14
o f th e
i a t e o f W a s h in g t o n
f o r P ie r c e C o u n t y
p il e
AUG2 12014
THOMAS RAYMOND SABIN
1200 Westlake Ave N Ste 700
Seattle, WA 98109-3529
RE:
DANIEL N. COOK
5920 100th St SW Ste 25
LAKEWOOD, WA 98499-2751
Dear Counsel/Litigant:
The above referenced case has been reassigned to The Honorable K. A. van Doorninck,
Department 20. The Assignment for Trial date set for September 5, 2014 has been cancelled.
Please find enclosed an Order Setting Case Schedule. If you have any questions please call
me at (253) 798-6688.
Sincerely,
MICHELE TUFTS
Judicial Assistant
Enclosure
cc:
Petitioner(s)
vs.
BETH ANN KALII
R espondent(s)
Plaintiff/Petitioner's Attorney
THOMAS RAYMOND SABIN
PART A
J t& K -
___________________
F o r d u e c a u s e ( j u d i c i a l A s s ig n m e n t R o ta tio n !! )
O th e r
/ R e c u s a l / J u v e n ile F a m ily
C o u r t / R e fe rre d t o F a m ily C o u r t ), th e a b o v e e n title d a c tio n is r e fe r r e d t o A d m in is t r a t io n
fr o m D e p t.
/ 2 f o r r e a s s ig n m e n t.
PART B
a c t o n is re a s s ia n e d t e r h e a r in q t o D e p t. N o .
day o f
^ T rid /pp.m
.m . A lllf p a r tie s a re t o r e p o r t
, 20 I f
, at
//J
r e c tly ^ fn d im m e d ia te; lv
ly t o th e a b o v e n u m bb e re a d e p
e n t i f r e a s s ig n m e n t is f o r
im m e d ia te t r ia l.
(
C a s e t o re m a in in D e p t. N o __________, J u d g e ___________________________ f o r m o n it o r in g a n d
c a s e m a n a g e m e n t p u r p o s e s b u t d e c la r e d a V is it in g J u d g e (V IS I) c a s e o n __________d a y
o f ______________________ , 20______ b y P r e s id in g J u d g e ___________________________ .
A v is it in g J u d g e f r o m a n o th e r W a s h in g to n S ta te C o u n ty w ill b e a s s ig n e d t o p re s id e o v e r
t h is c a s e .
r l , /)
r\ .
/)
C a le n d a r C o o rd in a to r
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
Please take notice that an issue of law in this case will be heard on the date and time shown below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
DATED:
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
Attorney for Respondent
LAKEWOOD, WA 98499-2751
1 of 1
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W A S H IN G
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
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4
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JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
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BETH A. KALII,
Respondent.
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15
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I, BETH KALII, make this declaration on the basis of my personal knowledge and in
in support of my Motion for Temporary Parenting Plan.
This declaration is for a review hearing.
18
submitted full declarations regarding the parenting plan. I am asking the court to adopt
19
my proposed parenting plan maintaining the equally shared residential schedule with both
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review hearing is needed because the prior Pro Tern commissioner mistakenly believed
the trial date was September 5, 2014, so the Pro Tern commissioner only ordered a
23
residential schedule for the summer. See, Clerks Minute Entry dated July 14, 2014.
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am asking the court to maintain the alternating week on/week off in the school year.
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Response Declaration of Beth Kalii - Page 1 of 3
Kalii, John and Kalii, Beth
S:\CASES1\Kalii\DRAFTS\Pleadings\Reply Declaration of Beth Kalii re Work Schedule.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-1 00 th S tre et S W Ste 25
Lakew ood, W A 98499
253-581-0660
John and I also have a history of cooperative and peaceful shared parenting.
2
In a prior declaration I explained I am a bus driver with the Clover Park School District.
3
4
5
John complained that I had to leave for work early and that caused a problem for KAENA
in the shared residential schedule.
adult daughter. A major reason for both of these changes was to avoid early morning
wake-ups for KAENA. I also explained that my residence is only 0.36 miles from Johns
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I write this supplemental declaration to explain to the court my work schedule in the
upcoming school year.
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I clock in for my morning run at 7:00 a.m. and then out at 9:15 a.m.
I clock in again for a mid-morning run at 10:30 a.m. to 12:30 p.m.
I clock in again for my afternoon run at 2:00 and out at 4:15 (sometimes
4:30 depending upon weather and traffic)
This is projected to be about 6.5 hours per week.
schedule I can also pick-up additional routes on the weeks that KAENA is not with me.
Overall I anticipate working an average of almost 40 hours per week by working more
19
hours on the weeks KAENA is not with me.
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The child care arrangements for KAENA on the weeks she is with me will be:
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In the MORNING: I will get KAENA up around 6:15 a.m. and drop her off at
JOHNS house around 6:45 a.m. Her bus stopped at JOHNS house around
7:20 a.m. last year. This is not unreasonably early for KAENA at all.
In the AFTERNOON: KAENA will take the bus to JOHNS house. Last year
the bus stopped at his house around 2:55 p.m. I will be there to pick
KAENA generally by 4:30 p.m. but no later than 5:00 p.m.
R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 2 o f 3
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
If JOHN does not want KAENA to come to his house in the morning or afternoon it
2
is a very simple matter to arrange brief before and after school care through the YMCA
3
programs at her school. The fact is, KAENA only needs one-half hour in the morning (30
4
5
minutes) and one hour and a half (90 minutes) of care before and after school based
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BETH KALII
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R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 3 o f 3
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
SCHOOL
f DISTRICT
tody, It&diyCoHO/row.
TRANSPORTATION DEPARTMENT
Delphie Nielsen, Director
Sally Ducharme
Legal Assistant to Daniel N Cook
Faubion, Reeder, Farley & Cook
5920 100,h St Sw Suite #25
Tacoma, WA 98499
Please accept this as official notification that Ms, Beth Kalii is an employee with Clover Park School
District's transportation as a school bus driver.
Clover Park's school year will begin on Wednesday, August 27, 2014 and is anticipated to end June 9,
2015 pending no delays in school due to inclement weather or unforeseen circumstances.
Due to her level of seniority, Ms. Kalii was able to acquire the following bus routes and schedule and will
remain as such up until Ms. Kalii bids on additional assignments if she so desires.
7 :0 0 -9 :1 5 /1 4 0 0 -1 6 :1 5
10:15-12:15
Should you have any questions regarding this information, please do not hesitate to contact me or Paul
Vigil in my absence at (253) 583-5494 or via email at [email protected] .
O '
Delphie Nielsen
Director of Transportation
E-FILED
IN COUNTY CLERK'S O
PIERCE COUNTY, WASH
NO: 14-3-01646-
3
4
5
6
)
9
IN RE:
MARRIAGE OF
)
)
10
JOHN KALII,
Cause No.14-3-01646-7
)
11
Petitioner,
versus
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13
14
)
)
Respondent.
)
)
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APPEARANCES
2
3
4
Thomas R. Sabin,
GOLDBERG JONES,
Seattle,
(206)
10
JOHN KALII:
Attorney at Law
PLLC
Suite 700
Washington 98109
448-1010
tsabin@g o l d b e r g j o n e s .com
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12
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Daniel Cook,
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18
19
Lakewood,
20
(253)
21
Attorney at Law
P.S.
Suite 25
Washington 98499-2751
581-0660
d c o o k 0 f l r - l a w .com
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23
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1
2
3
4
COMMISSIONER COUTURE:
SABIN:
01646-7.
10
is it Kalii?
MR.
COMMISSIONER COUTURE:
9:35:04
AUDIO BEGINS
MR.
Kalii.
Counsel,
COOK:
11
MR.
identify themselves,
Good morning,
Kalii.
Your Honor,
please.
Daniel Cook on
SABIN:
And,
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13
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COMMISSIONER COUTURE:
I'm Tom
And I think
Okay,
16
so there's no misunderstanding.
17
18
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Mr.
Is that correct,
Sabin?
20
MR.
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COMMISSIONER COUTURE:
SABIN:
That is correct.
Okay.
Mr.
22
23
tried.
24
25
he sent me an
or does he
But I
that --
6
7
MR.
COOK:
right?
MR.
COMMISSIONER COUTURE:
10
11
12
13
question,
14
MR.
15
SABIN: . Yes.
Cook,
if you want me to
I certainly will.
COOK:
No objection,
Your Honor.
Thank you.
17
MR.
COOK:
Okay,
go ahead.
working copies?
COMMMISSIONER COUTURE:
I did.
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21
22
MR.
COOK:
23
And frankly,
24
are.
25
But
so.
COMMISSIONER COUTURE:
19
Mr.
you know,
16
18
So,
Obviously,
Roger G. Flygare
&
Well,
it's
and there
Associates, Inc.
that Mr.
motion.
his
That
10
pension.
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12
13
14
that is.
15
He is in pay status.
before he retired,
Three and a
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17
would receive.
18
that.
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20
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22
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if the
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11
12
it down to $280.
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14
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17
18
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$849, on average.
21
who is
That's the
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Roger G. Flygare
&
That it
Associates, Inc.
But, you
1
2
8
9
10
11
numbers.
12
13
14
It's just that Mr. Kalii should pay the full amount of
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insurance.
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Should be reduced by
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22
And now
This is bad
23
child.
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25
we filed.
way,
was filed.
Kalii says
10
"Well,
11
weeks,
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13
but
And
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15
for the child and for the parents that Mr. Kalii can
16
provide care for the child during the child's weeks with
17
mom.
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20
And it is a plus
Now,
the
21
schedule.
22
Now,
first of all,
frankly,
Okay?
23
route that she could pick up her child day-in and day-
24
out,
25
from school,
and take her to school every day and bring her home
and drop her off,
you know,
residing together.
year.
medical insurance.
available to her.
She
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13
She's
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18
But she was locked into a contract when she moved out
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22
Which,
frankly,
for children,
24
She couldn't
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25
It's just
certain children,
look,
if
1
2
I will."
So,
a more ordinary
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11
been,
you know,
12
this,
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14
and
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Also,
There's no
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late also,
22
But,
You know,
She doesn't
I didn't
I don't
I think it was
23
24
25
just
But I
anyway,
My
it was
10
And, you know, one of the issues was that, you know,
She'll be
you know,
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11
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She's going to
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And, you know, the child will get to spend that time
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the child should not have residential time with the mom.
19
20
evaluation.
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work .
Roger G. Flygare
&
Associates, Inc.
11
mom.
child.
So,
Well,
if we need
10
COMMISSIONER COUTURE:
11
MR.
SABIN:
Okay,
Your Honor,
Mr.
Sabin?
first of all,
12
of issues.
13
14
support,
15
The
child
temporary orders.
is
16
17
18
attorney's fees,
19
MR. COOK:
20
MR.
21
COMMISSIONER COUTURE:
22
MR.
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25
SABIN:
SABIN:
And I'm
Yeah,
there's a shock.
counsel kind of
12
during school?
3
4
more until 6:45 where he got her up, put her on the bus
at 7:20.
house, stay there until about 7:30 when she was picked
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up.
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that.
19
Didn't
So, the net affect is, this little girl was getting
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bounced.
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22
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25
So, our proposal was that during school that the child
13
weekend a month.
In fact,
10
So,
boom,
boom,
And it seems
11
12
following week.
13
boom.
14
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17
18
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But during
20
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time,
to mom.
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And the only reason this was filed was for that, to
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25
14
1
2
early,
go to bed,
whatever.
pension.
that.
of
portion,
Not taking
10
11
awarded,
12
decisions.
13
Because,
14
social security.
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16
17
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So,
20
data?"
maintenance,
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property."
25
22
24
19
21
So,
he doesn't get
What's not
15
1
2
being said?
What's obvious?
And what's the one big thing that we're not seeing
here?
and
records.
She
sources of income?
resources?
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11
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support.
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17
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Court made mention to the Court that the reason they were
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transporting and for the school, and whatnot, was she was
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Well, likewise
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as
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period.
But,
16
the
8
9
10
11
But that
12
13
14
15
16
17
18
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20
be making
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22
for the use of the home, each pay their own bills.
23
24
25
Roger G. Flygare
&
Associates, Inc.
17
of that.
She claims she has need, but she somehow went and got
that.
8
9
10
11
12
13
14
15
to mom.
And
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17
COMMISSIONER COUTURE:
18
MR. COOK:
Very brief.
19
20
month.
21
22
recognize
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24
25
18
So,
$920 deducted.
The incomes
The Court
at face value, because this mother has done all that she
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residence.
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up super early.
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17
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She's got her adult daughter living with her now, and
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19
into,
But
contribution to each.
COMMISSIONER COUTURE:
do.
parenting plan.
Okay.
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11
12
13
school.
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15
16
17
18
plan.
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20
21
22
interjecting that.
23
24
don't .
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20
1
2
Sabin.
least of which
hers.
dollar amount?
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11
12
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14
15
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undifferentiated.
18
And she
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20
21
22
23
we have here.
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25
21
Court.
trial.
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11
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And I
MR. COOK:
No, I
14
April.
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16
September 5th".
17
18
COMMISSIONER COUTURE:
We could
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20
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22
23
24
25
MR. SABIN:
Your Honor?
COMMISSIONER COUTURE:
22
1
2
parenting plan.
8
9
10
and just
11
MR. COOK:
12
COMMISSIONER COUTURE:
Right.
and it
13
14
15
16
MR. COOK:
COMMISSIONER COUTURE:
18
MR. COOK:
20
I guess the
17
19
it
$1050, undifferentiated.
of child support.
COMMISSIONER COUTURE:
Well, I don't
I think by law
21
22
23
24
25
Roger G. Flygare
&
Associates, Inc.
A rv e y
23
1
2
MR.
SABIN:
I guess,
Your Honor,
COMMISSIONER COUTURE:
MR. SABIN:
$1050 total?
COMMISSIONER COUTURE:
Total.
And it's
maintenance.
10
is $150.
11
MR. SABIN:
12
COMMISSIONER COUTURE:
13
14
apologize to you.
15
16
17
So, I apologize.
18
MR. SABIN:
19
It's my mistake.
And will
I misunderstood the
20
MR. COOK:
21
COMMISSIONER COUTURE:
22
23
24
25
MR. COOK:
Honor.
24
MR.
SABIN:
Straton Lucas
(phonetic).
k
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
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23
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25
Roger G. Flygare
&
Associates, Inc.
25
1
2
IN RE:
CAUSE NO.
4
5
6
7
8
9
AFFIDAVIT
I, Patricia Tuffield, do certify that the audio recording
10
11
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13
best of my ability.
14
15
16
17
18
Patricia Tuffield
19
Transcriptionist
20
21
22
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25
ORIGINAL
Roger G. Flygare & Associates,
Inc.
26
E-FILE
IN COUNTY CLE
PIERCE COUNTY
September 05 2
KEVIN St
COUNTY
NO: 14-3-0
2
3
4
5
JO HN A. KALII,
Petitioner,
10
and
11
BETH A. KALII,
N O T IC E O F IN T E N T TO W IT H D R A W
Respondent.
12
TO:
13
A N D TO:
A N D TO:
14
15
16
17
_____________
T'herelSTro-sehedtJeeHfiat'dal'e:18
19
20
21
The last known address of Petitioner is Mr. John A. Kalii,9711 Winona St SW,
Lakewood, W A 98498, and all future pleadings in this matter should be directed to him at
said address. If no address is stated above, then after said withdrawal of the undersigned
attorney of record and so long as the address of the withdrawing attorneys client remains
undisclosed and no new attorney is substituted, the party may be served by filing with the
clerk of the court an affidavit of attempt to serve pursuant to Civil Rule 5(b)(1)-
22
Dated this 5th day of September, 2014.
23
1
2
3
4
5
6
7
8
9
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/
f,J
43247986
court
09-09-14
ORFR
4
5
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7
IN T H E S U P E R IO R C O U R T O F W A S H IN G T O N , C O U N T Y O F P IE R C E
JO H N A LIK A KALII JR
ORDER
P etitioner(s) ,
(O R )
vs.
10
11
12
IS
13
r n E / A ' o s 8 > f r N O s
S T l Z / Q f i t 'P .A J
P e ^ e o i^ iC r
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o h
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D ATED this
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21
JU D G E K. A. van D oorninck
22
23
fo r P laintiff/P etitioner
24
25
WSBA#35f//v/ /a
u l
r w
t*0
w sba#
2 > ^
& &
A - KAL-li
No.
Petitioner^,
and
Declaration of
A .
K A U (
[Name]
(Optional Use)
(PCLR)
R e s p o n d e n t^ .
Name:
Age:
A /_____________________________________
P -T IT I
I Declare:
kCJLePT
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f~B A S oN A g L
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PATM E/SlT
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LAKL\AJ<D0D
[City]
[State]on
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lb- Z-Q[A-
[Date],
14-3-01646-7
43301863
09-16-14
DCLR
IN COUNTYc l ^ cs OFFICE
am
S E P jU 7 2 (m
f^ A L -M
Petitione
and
No.
/if ~
" 7
^ > fP aJ
___f^ A K t 4 T < M 6 T L - h h l
Respondent (^f?
[Name]
(Optional Use)
(DCLR)_______________________
Age:
>
Declaration of
A < KArL-ll
Name:
^ T/OHri. A t A
*1
(________________
r e r i r i p n t ^
I Declare:
s e z
h rrN re M p
L A Kt-IK>/0>P
[City]
IA/A~
[State] on
), / .
[Date].
Parenting Plan:
I,
John Alika Kalii, will agree with the 50/50% Parenting Plan
14-3-01646-7
43301867
09-18-14
DCLR
'NC W T Y ? f8 ^ 0FF(ce
AM
s e p it
W *
KEVIN
A Petitioner^,
No.
" V
and
D a M m ' i z e s f M < z e
R e sp o n d e n t^
[Name]
M , P f A -C .
(Optional Use)
Age:
\.7 2 > tb U A -
K A - L j t ______________
____I_______________________________
p g r n t > tie
/ Declare:
___________ A T T A ^ t t M & M r s
r -
, [ C ity ]
tv /A
_ [State] on _
? )/
< 7 c >1+k L
I b 'Z O l^ r
K A L -1
rD a te l
I________
POP Name:
0501
Rx Bin:
Rx GRP:
Rx PCN:
610494
ACUWA
9999
'
, Washington
healthplanfinder
d id t com pare, covered.
JOHN A KALII
9711 WINONA ST SW
LAKEWOOD WA 98498
j'f
07/24/2014
Application ID:
1163284
ct>We received and reviewed your application and determined the following:
Name "
John A Kalii
Program
. EligibilityBegin Date{
-Washington Apple
Health Adult Coverage
07/01/2014
"
Appeal Rights
If you disagree with the decisions above you have the right to appeal. See the attached information about
your appeal rights. There are deadlines to appeal so you should act quickly.
By email at [email protected]
By Fax 360-841-7620;
By mail at:
PO Box 946
Olympia WA 98507
You can drop off an application, renewal form, or any other documents requested by the
Washington Healthplanfinder at a local Community Service Office. To locate the nearest
Community Service Office, call the Washington Healthplanfinder number above or go online at
Correspondence ID: EE004-7636968
Page 1 of 9
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGT(
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
10
11
No. 14-3-01646-7
DECLARATION OF MAILING
Petitioner,
12
and
13
14
15
16
17
I, Sally DuCharme, am over the age of 18, and competent to testify in the
above entitled case.
On September 17, 2014, I placed in the U.S. Mail a copy of the following
documents in the above-entitled caption:
18
19
20
John Kalii
9711 Winona ST SW
Lakewood WA 98498I
21
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
25
Declaration Of Mailing
Kalii, John and Kalii, Beth
S:\CASES1\Kalii\DRAFTS\Pleadings\Declaration of Mailing.doc
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTt
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
9
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Respondent.
14
15
16
17
I, BETH KALII, make this declaration on the basis of my personal knowledge and in
in support of my Motion for Temporary Parenting Plan.
This declaration is for a review hearing.
18
entered an agreed order striking his Revision hearing and setting over all issues for
19
20
21
22
23
Parenting Plan.
24
watch KaEna before and after school on my weeks. That is fine. If we need to set up
25
Response Declaration of Beth Kalii - Page 1 of 3
Kalii, John and Kalii, Beth
S:\CASES1\Kalii\DRAFTS\Pleadings\Reply Declaration of Beth Kalii re Review.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 S tre et SW , Ste 25
Lakew ood, W A 98499
253-581-0660
1
commercial child care I will do so. But it cannot be just for contingencies - it would have
2
to be set up every other week or I will not be able to hold a spot in a commercial daycare.
3
So if John notifies me that he will not provide before and after school care on his weeks I
4
5
will set up commercial child care and the cost will be a shared expense.
Health Care Insurance. John submitted a declaration saying he obtained his own
insurance and that he will no longer be covered by my plan. That means I will no longer
was coming off of my benefits. I was told that I would receive a refund of the premium I
10
11
12
already paid for September 2014. Presuming that does actually take place that is good.
Of course, if the understanding John and I have is mistaken in some way than we will
need to come back to court to address it.
13
Child
Support/Maintenance.
Previously
the
court
ordered
$1,050
in
14
15
predicated on the substantial amount I was paying for Johns insurance so I agree that
16
17
18
19
payment; or, if the court deviates in child support because of the 50/50 residential
schedule than spousal maintenance should be ordered.
20
The standard calculation of child support on the worksheets I filed on July 3, 2014,
21
(and nothing has changed since then) is $723 per month with inclusion of the health care
22
23
24
from $723 per month then I request spousal maintenance in amount sufficient to equal
25
R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 2 o f 3
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
$723 per month. This is still a reduction of $327 per month from the amount the court
2
previously ordered for undifferentiated family support.
3
John improperly references settlement negotiations in his materials filed with the
4
5
6
court.
I understand that he probably did not understand the rules related to settlement
negotiations so I am not claiming he acted in bad faith; however, that information should
not be stricken.
conversation allegedly took place. But I did have conversation with my attorney after the
revision motion where my attorney asked me if I would accept Johns offer of $300 per
10
month child support. I declined to accept $300 per month. As of the date of writing this
11
12
declaration we have not been able to reach an agreed upon number to settle this issue
short of court action. So I am asking for the court to order the full payment of $723 per
13
month. Particularly if I am going to have to get child care for KaEna even with that as a
14
shared expense that is going to further tax my monthly budget and I will need the full
15
16
17
18
19
Signed at Lakewood, WA on September 17, 2014.
20
21
BETH KALII
22
23
24
25
R e s p o n s e D e c la r a tio n o f B e th K a lii - P a g e 3 o f 3
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
am.
43321699
14-3-01646-7
09 -22-H
AFPT
SEP 19 20ft PM
K E V IN S T O C K ^ o u n ty C le rk
'B f o /M
A ' f c /u - /r
Petitioners),
and
no.
/ f
- 3 - > /^ 6 'r 7
Declaration of
B A T H
K A * - i /
Respondent(s).
at** &T tt K A C /(
[Name]
(Optional Use)
(DCLR)_______________________
A r < K A U ! _________________
7<D 4M
Age:
/ ______________________________________
I Declare:
A iT A c m o
/M p ju t jE O '
M Y rAAeUT/A/r PfiAAi
^
S iA T A /e j-Z E Z ?
J T A H rH S A
re
A e v /z r io
rjfc S A / L D
U T T T tT T
&A?
7Z>
M Y
0 A
3 T H
k H A //
A t e A /f L /A /f r ____________________________________
A A v e r:
/it & T
5 B - 2 z T .
I/O
[City]
lA /A '
[State] on
[Date].
1. Drinking and smoking through her entire pregnancy with Ka'ena. This
may be the cause for Ka'ena's hyperactivity and lack of attention
problems. I can present family witnesses who lived in our home as well
as personal friends of both of us who can support this claim.
2. Continued alcohol use during marriage. I have family witnesses that
can also support this claim.
4. No insurance on her vehicle past or present. Would request that she
provide proof of insurance.
5. Passenger in past vehiclular homicide/ hit and run with ex-husband
and continues to drink. I have court documents to support this.
6. Submited inaccurate notarized statements against me as to my
parenting skills and history, by co-workers who neither knew me
personally and/or had never been to my home. I have notarized
statements to dispute these statements.
8. Leaving Ka'ena in the care of others during Beth's scheduled week
(example...Daughter Katerri's ex-boyfriend, 30's male) to watch her
when Beth was at work seminars. I was uncomfortable with Ka'ena's
safety in that and disapproved, but told by Beth that I couldn't tell her
what to do.
9. Beth's purchase of a pet and not supervising and providing proper
l
care for the animal (hamster), resulting in the death of said pet by
accidental suffocation by Ka'ena.
After meeting with Beth's attorney (Daniel N. Cook) at a Sept 5, 2014
court hearing, I mentioned to Mr. Cook that I could not afford to be
paying Beth $700 to $1000 a month, as I am now on a fixed income. He
agreed that it was a bit extreme. He then went on to add, "Would you
be willing to settle on $300 a month and agree to the 50/50 custody?" I
replied "I would be willing to do that." "But she's not going to go for
that." And he replied, "Yes, she will." In a subsequent meeting on Sept.
17, 2014, Mr. Cook informed me that Beth would not accept my $300
agreement and that Beth now needed $400. Also assuring me that this
was only temporary and not final, I again agreed. The next day, Sept.
18, 2014,1recieved a Declaration of Beth Kalii re: Review Hearing
stating that they were again seeking $723 a month with inclusion of
Spousal maintenance. The deviation reduction of $327 a month from
the court ordered undifferentiated family support of $1,050 fails to
address the additional deduction of the Sept. 1, 2014 cancellation of my
health care insurance with Beth. I am asking the Court to dismiss any
Spousal maintenance on the grounds that this has only been a (4) four
year marriage and does not warrant such action. Dispite all attempts by
Mr. Cook to seek an agreement on my part to his extended offers, I am
now refusing Beth's Parenting Plan and asking the Court for it's
consideration of my Parenting Plan. In addition I am asking that Beth
pay (according to the Child Suport Schedule provided to me by Mr.
Cook) the amount of $314.88 minus my portion of $151.15. Which
,v
[0
H
day, every school week, for the entire 9 month school year. Not to
mention other issues that might arise, such as colds or viruses
associated with such facilities. I would hope that the Court find that this
is much more beneficial where it concerns care and welfare of Ka'ena. It
is my belief that the degree of her welfare is solely dependent on which
rO
1
/
Additionally it should be noted that Beth had the option and still has
the opportunity of being Ka'enas bus driver. She every/school day
h
f\
\j
driver for Clover Park School District Beth also has all holidays, Spring
r,
and W inter breaks, Summer breaks off, in which she can adjust child
C1
O'*
AM
SFP 19 20ft
RM.
Dr-----------
.DEPUTY
C fo H N
K A L I/
Petitioner^),
and
& T rt
A -
no .
Declaration of
K A L I /
t a m m y
R espondent^.
Name:
^
________________________________ ]p r _
\3 ^ V \-o ^
I D e c la re :
L T r& <
/s >
A T T /t e m
p A /L e y
[Name]
(Optional Use)
(DCLR)____________________ _
A ge:
f V - 3 - 0 / b 6 - 7
p *
State o f.
3 8 *
Connty of
A A A A A A A AA A
S^ANTHARTBODCHARD'
TAHW Qi M W
Notarv Public
Notary Pubflc
State or W ashington
M y Com m ission Expires
Decem ber 1 ,2 0 1 7
m imt v
. tcc \ . m i
My Commission Expires;
_______ , [City]
[State] on ^
- .
[Date],
~ 6 ? - 1 4
/
M y name is Tammy Dailey, ex wife of John Kalii of 24 years and have known him
for 40 years. I refer to him as Bo.
Bo and I raised 2 beautiful respectful God fearing sons together. Bo is a very good
father, then and now, as well as a loving caring grandfather taking our grandkids
anytime. I've also witnessed Bo with Kaena and I have no doubt she will grow up
knowing how loved she is and will be respectful in all ways as well. Bo cares for
all her needs and spends quality tim e with Kaena.
A fter finding out Bo and Beth split up, I began visiting my grandchildren at his
home. Soon after, I lost my job and Bo, as he helps everyone else, let me move in
as well, being in a bad situation not able to pay my rent. Katerri (Beths daughter)
was living there as well. W hen Kaena m et me she began calling me mama Tammy
because she knows Im her 2 half brothers mom. I wasnt comfortable with that
because I feared it would only cause trouble with Beth. Bo told me she calls her
1 /2 sisters dad papa Steve that it was no big deal. I told Kaena if she wanted to
call me Tammy thats okay with me, but she continued to happily call me mama
Tammy and I felt for me to dispute this it would only cause confusion for her so I
just let it go.
Since I've been here Kaena and I have baked cookies, planted flowers, painted
wood flowers for our flow er garden, gone to the lake several times, gone
shopping, cleaned the pool together, gone to the dog park, sat outside in the
mornings playing computer games and never have I ever disgussed anything
about her m other with her. However, Kaena came back to Bo's house after her
week with her m other and said to me "my mom says you're mean to her." Besides
the fact I've not seen Beth in 4 years, Im puzzled as to why she would be having
this conversation with her 8 year old who seems just fine with everything until
Beth starts questioning her and having this kind of talk with her. Soon after that,
Kaena said " M y mom says her sister and brother are mean to her." im puzzled by
this. The very first tim e I m et Beth, within minutes she began telling me about herl
life and was literally crying. It appeared to me she was thriving on sympathy and
my concern is she is doing this with her daughter now by the things she is telling
Kaena. Beth has also text Bo calling him very terrible names, In am concerned,
weather she is doing this in front of Kaena as well. Also claiming Katerri was
kicked out of the house as soon as Beth retained an attorney about 2 months ago.
I was here the day Katerri moved out, Bo and my son took 3 truck loads to Beth
and I helped Katerri put things in her car. It was July 1st when her mother got her
place. Katerri was never kicked out in fact after Bo giving her a letter asking her to
plan on moving, he later told her if she wanted to stay she could that she didnt
have to leave I was sitting right there with them when he told her this.
As far as Cathy Gibsons letter to the court. The only time I have ever crossed
paths with her, is when I was Bartending and she would come in and drink almost
on a daily basis. I knew her boyfriend Casey since the 70s but I knew nothing
about her and she knew nothing of me. Very disheartening being called vile, mean
and psychotic by someone who has never had a conversation with me. She also
states Kaena was forced to call me mama Tammy, as stated above, that was
completely Kaena's choice and Cathy wasn't in the state when any of this
occurred. Her information is hear say.
In reference to the letters Cathy Gibson said I wrote to Beth years ago, it was out
of total frustration because Beth was interfearing, knowing Bo and I were trying
to reconcile our 24 year marriage and she was married at that time to Steve. The
fact of the matter is, I was granted a one year restraining order on Beth after she,
her then husband Steve and his girlfriend showed up at the house and began
threatening me. I was living with Bo at that time, from 2006-2007. i moved in
with Bo again in 2009 we were again trying to repair our marriage. Beths
constant calling and texting all day caused havok with Bo and I and I moved out.
According to Bo he broke up with Beth on both occasions because of her
continuous drinking. The first time, drinking and smoking during the entire term
2
of her pregnancy. This was very upsetting to Bo it bothered him a lot. Beths
oldest daughter was born 1.5 lbs so he couldnt understand why she was drinking
and smoking during her entire pregnancy.
Bo has expressed to me, this is the main reason he is divorcing her now along with
working full time and not contributing to any of the expenses in the household.
That he has been wanting to start this divorce for the last 2 years and just kept
putting it off that he was losing motivation because of the situation and was
finding it hard to even start a divorce. That he was so busy taking care of this
house, cleaning, cooking and paying bills he was just tired and beginning to feel
hopeless. When I asked him why he married her knowing she drank so much, he
said because of Kaena. He felt it was the right thing to do and he thought she
would stop drinking with his constant complaints, but it became very clear that
her drinking came first and he was tired of it.
I have watched Bo willingly taking Kaena anytime on Beths time without malice at
all, about 30 hours a week of her time. He gladly takes her anytime Beth wants
him to. But Kaena, being dropped off and picked up so many times each day, does
seem a bit hectic and disturbing to the day just alot of back and forth going on
making the stability factor a little unstable. Bo has expressed concern that during
the school year, Beth picking her up just in time to put her to bed and that just
doesnt make sense to him.
Beth has maliciously spread the word, not only to the court but mutual friends
that Bo kicked her and Kaena out of the house leaving them homeless. Bo would
NEVER do such a thing, ever. But Beth insists on dragging Bo's name through the
mud for her own benefit.
Bo is a very caring and loving man, always ready to stand up to the plate and help
someone in need and do the right thing. I know for a fact, he has Kaena's best
interest in mind. As long as I've known Bo, money has never been that important
to him, in fact when he and I thought we may be losing our Lake house of 18
3
Ou
H
years, Bo said to me, "This house is made of wood and glass. Our family is the only
thing important about it" Family and friends have always come first. I have no
doubt, Kaena will grow to have these same caring qualities and morals.
With all due respect,
Tammy Dailey
JU R A T
]. j
State of.
C':j
County of.
A A A AA A
Subscribedandsworn/affirmedtobeforem
ethis id_dayof
20_M_, by
SAM AN TH A R. BO UCHARD
N otary Pubflc
State o f W ashington
M y Com m ission Expires
Decem ber 1 ,2 0 1 7
^
VAFrtM
.<I
Notary Public
My Commission Expires:
bee l - M i
SEP 19 20ft
p .m.
WASHINGTON
KEVIN STOCK, County Clerk
A . KAL 11
!" re:
P etitio n er^,
and
pgTtf A . KALit
R espondent^.
No.
Declaration of
com
[Name]
(Optional Use)
(DCLR)
t 9S
d & /? ? ^ ) >
Age:
Relationship to the parties in this action:
I D e c la re :
is
- 3 '
ATTACHED
sro ct^
Signed at
J ail 6~
[City] L
[State] on
V ^ D a te ].
I, C a s e y C o m s to c k , h a v e b e e n f r ie n d s w i t h B o K a lii f o r 3 0 + y e a r s . I h a v e s p e n t m a n y o f th e s e
y e a r s a r o u n d B o a n d h is f a m ily . I'v e w a t c h e d h is t w o s o n s a n d d a u g h t e r g r o w in t o a m a z in g
in d iv id u a ls . B o h a s h e lp e d m a n y p e o p le t h r o u g h t o u g h a n d f in a n c ia lly h a r d t im e s in t h e p a s t.
F ro m p a y in g t h e i r r e n t a n d g r o c e r ie s , t o p r o v id in g s h e lt e r in h is o w n h o m e . H e h a s d o n e t h a t
f o r h is o w n f a m ily m e m b e r s m a n y t im e s . A f t e r 3 3 y e a r s w i t h t h e T a c o m a F ire D e p a r t m e n t , h e
is n o w r e t ir e d a n d c h e e r is h e s a ll t h e t i m e t h a t h e c a n s p e n d w i t h h is 8 y e a r o ld d a u g h t e r ,
K a 'e n a .
I a m a ls o w r i t i n g t h is l e t t e r b e c a u s e m y e x - g ir lf r ie n d , C a th y G ib s o n , w h o I a m s t ill c lo s e
f r ie n d s w i t h , e x p la in e d t o m e t h a t a l e t t e r s h e w r o t e o n B e th K a lii's b e h a lf , a b o u t B o K a lii a n d
h is e x - w if e T a m m y K a lii w e r e b a s e d o n h e a r s a y . S h e d o e s n 't k n o w B o w e ll o r e v e r s p e n t t i m e
w i t h h im a n d h is f a m ily in h is h o m e , as I h a v e . H e r s t a t e m e n t a b o u t w h a t K a 'e n a s a id is n o t
t r u e as s h e h a s n e v e r t a lk e d t o K a 'e n a . I w a s p r e s e n t w h e n K a 'e n a a s k e d h e r f a t h e r B o , w h a t
s h e s h o u ld c a ll T a m m y . H is r e s p o n s e w a s , " Y o u c a ll y o u r s is t e r K a te r r i's d a d , P a p a S te v e , y o u
c a n j u s t c a ll h e r M a m a T a m m y . I h a v e a lw a y s b e e n c a lle d U n c le C a s e y b y a ll o f h is c h ild r e n ,
s in c e t h e y w e r e t o d d le r s . I t's a H a w a iia n t h in g . It s a d d e n s m e t h a t C a th y d i d n 't t h i n k h e r
s t a t e m e n t s o u t , b u t I k n o w s h e w a s m is le a d b y h e a rs a y . H e r d e s c r ip t io n s o f B o b e in g a n g r y
a n d in s u lt in g a n d T a m m y b e in g v io le n t a n d h a t e f u l is s o m e t h in g t h a t I h a v e n e v e r s e e n in t h e
3 0 y e a r s I'v e k n o w n t h e m . H o w e v e r , C a th y d id t e l l m e t h a t T a m m y a lw a y s t r e a t e d h e r w i t h
r e s p e c t, n o t e v e n k n o w in g s h e w a s B o 's e x - w if e . C a th y m o v e d t o B o is e , Id a h o o n M a y 1 0 ,
2014.
B o 's h o u s e is a h o m e a n d a n e x c e lle n t e n v ir o n m e n t f o r K a 'e n a 's g r o w t h . H is s o n s a n d
g r a n d c h ild r e n a r e t h e r e m a n y t im e s a w e e k . I c a n s e e K a e n a 's b o n d a n d lo v e f o r h e r f a t h e r .
A n d I a ls o s e e B o s t w o s o n s as c o n s id e r a t e , lo v in g , a n d w e ll r o u n d e d a d u lt s , w h o lo v e t h e i r
fa th e r.
Thank you,
C a s e y C o m s to c k
LM
r, 1
i. -j
14-3-01646-7
DCLR
43323439
09-22-14
A.M
SFP 19 2014
PM.
no.
Petitioner(s),
and
/ / ' S '
~ 7
Declaration of
[Name]
(Optional Use)
(DCLR)______
Respondent(s).
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'______________
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[Date].
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f ii ! 6 k's office
, COUNTY C L E W S u r
Mother Beth
Father John
County
Case No.
Kalii
P IE R C E
(C S W P )
Kalii
14-3-01646-7
F a th e r
M o th e r
$ 4 ,3 5 2 .3 7
$ 2 ,6 6 7 .0 0
$ 4 ,3 5 2 .3 7
$ 2 ,6 6 7 .0 0
$ 3 2 3 .4 6
-
$ 5 .3 5
$ 4 6 .1 0
$ 2 5 4 .1 1
$ 1 9 .8 6
$ 1 2 3 .8 9
$ 3 2 3 .4 6
$ 4 4 9 .3 1
$ 4 ,0 2 8 .9 1
$ 2 ,2 1 7 .6 9
i P
$ 6 ,2 4 6 .6 0
i s m
t i l
i s
$ 8 8 7 .0 0
ip f
6. P ro po rtio na l S hare o f Incom e
(each parents net income from line 3 divided by line 4)
.6 4 5
.3 5 5
6 5 7 2 .V
$ 3 1 4 .8 8
5.00
a. Is c o m b in e d N e t In c o m e L e s s T h a n $ 1 .0 0 0 ? I f y e s , fo r e a c h
p a re n t e n te r th e p re s u m p tiv e $ 5 0 p e r c h ild .
b. Is M o n th lv N e t In c o m e L e s s T h a n S e lf-S u D o o rt R e s e rv e ? If v e s .
fo r th a t p a re n t e n te r th e p re s u m p tiv e $ 5 0 p e r c h ild .
c. Is M o n th ly N e t In c o m e e a u a l to o r m o re th a n S e lf-S u D D o rt
l s I3
R e s e rv e ? I f v e s . fo r e a c h p a re n t s u b tra c t th e s e lf-s u p p o rt
re s e rv e fro m lin e 3. If th a t a m o u n t is le s s th a n lin e 7, e n te r th a t
a m o u n t o r th e p re s u m p tiv e $ 5 0 p e r c h ild , w h ic h e v e r is g re a te r.
9. E a c h p a re n t's b a s ic c h ild s u p p o rt o b lig a tio n a fte r c a lc u la tin g
a p p lic a b le lim ita tio n s . F o r e a c h p a re n t, e n te r th e lo w e s t a m o u n t
fro m lin e 7, 8 a - 8c, b u t n o t le s s th a n th e p re s u m p tiv e $ 5 0 p e r
c h ild .
$ 3 1 4 .8 8
$ 5 7 2 .1 2
10. H e a lth C a re E x p e n s e s
d. C o m b in e d M o n th ly H e a lth C a re E x p e n s e s
(line 10c amounts combined)
M o tH e r
-
/$ 2 3 4 .3 4 '
$ 2 3 4 .3 4
K ill
$ 2 3 4 .3 4
m
*
11. D a y C a re a n d S p e c ia l E x p e n s e s
a. D a y C a re E x p e n s e s
b. E d u c a tio n E x p e n s e s
c .L o n g D is ta n c e T ra n s p o rta tio n E x p e n s e s
d .O th e r S p e c ia l E x p e n s e s (d e s c rib e )
e .T o ta l D a y C a re a n d S p e c ia l E x p e n s e s
(Add lines 11 a through 11 d)
*
SB!
$ 2 3 4 .3 4
Ip S fe l
12. C o m b in e d M o n th ly T o ta l D a y C a re a n d S p e c ia l E x p e n s e s
|g g j
$ 1 5 1 .1 5
$ 8 3 .1 9
$ 7 2 3 .2 7 I \
$ 3 9 8 .0 7
$ 2 3 4 .3 4
-
c. O th e r O rd in a ry E x p e n s e s C re d it (d e s c rib e )
d .T o ta l S u p p o rt C re d its (a d d lin e s 1 6a th ro u g h 1 6 c)
$ 2 3 4 .3 4
,s
(
x
$ 7 2 3 .2 7
;
'
/ /
$ 1 6 3 .7 3
$ 1 ,8 1 3 .0 1
$ 9 9 7 .9 6
$ 1 4 3 .0 3
$ 7 8 .7 2
F a th e r's
H o u s e h o ld
M o th e r's
H o u s e h o ld
a. R e a l E s ta te
b .In v e s tm e n ts
c. V e h ic le s a n d B o a ts
d .B a n k A c c o u n ts a n d C a s h
e. R e tire m e n t A c c o u n ts
f. O th e r: (d e s c rib e )
2 1 . H o u s e h o ld D e b t
(L is t lie n s a g a in s t h o u s e h o ld a s s e ts , e x tra o rd in a ry d e b t.)
a.
b.
c.
d.
e.
f.
2 2 . O th e r H o u s e h o ld In c o m e
a .ln c o m e O f C u rre n t S p o u s e o r D o m e s tic P a rtn e r
(if n o t th e o th e r p a re n t o f th is a c tio n )
Nam e
Nam e
b. In c o m e O f O th e r A d u lts in H o u s e h o ld
N am e
Nam e
c. G ro s s In c o m e fro m o v e rtim e o r fro m s e c o n d jo b s th e p a rty
is a s k in g th e c o u rt to e x c lu d e p e r In s tru c tio n s , p a g e 8
g .O th e r Incom e (describe)
26.
M other's
H ousehold
Father's
H ousehold
O th e r F actors F or C onsideration
/
IN COUNTY CLERK'S OFFICE
09-22-14
14-3*01646-7
43323446
PPP
a .m
SEP 19 2014
p m.
3
4
5
6
7
8
JOHN A. KALII,
NO. 14-3-01646-7
Petitioner,
10
and
11
BETH A. KALII,
(PPP)
Respondent.
12
This parenting plan is a Temporary Plan proposed by the Petitioner, John Kalii.
13
14
15
I. GENERAL INFORMATION
16
17
18
Aae
8
19
20
21
22
2.1
23
GOLDBERG & j o n e s p l l c
LUO WntHke Ave. N Suite TOO
Seattle, Wellington 98109
Tel: ( 204) 44 S-10 I 0 - Fat: ( 206) 448-0736
Email* IS AB IN GO LOBE RGJ ONES.COM
2.2
3
4
3.1
5
6
3.2
School Schedule
Upon enrollment in school, the child shall reside with the Petitioner, except for
7
8
the following days and times when the child will reside with or be with the other parent:
Every weekend except the second weekend of each month from 6:00 p.m. Friday
.10
11
3.3
The child shall reside with the father during winter vacation, except for the
12
13
following days and times when the child will reside with or be with the other parent:
In odd numbered years the child shall be with the mother from end of school to
14
15
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December 25th at noon and the father from December 25th at noon until the start of
classes following the winter vacation. In even numbered years the child shall be with
the father from the end of school until December 25th at noon and with the mother from
December 25th at noon until 7:00 p.m. the day before classes recommence.
17
18
3.4
19
20
21
following days and times when the child will reside with or be with the other parent:
In odd numbered years the child shall spend the mid-winter break with the mother and
the spring break with the father. In even numbered years the child shall spend the
spring break with the mother and mid-winter break with the father. Mid-winter and spring
22
23
break shall begin at the end of school and terminate at 7:00 p.m. the day before school
is scheduled to restart.
3.5
Summer Schedule
Upon completion of the school year, the child shall reside with the father, except
for the following days and times when the child will reside with or be with the other
3
parent:
4
5
3.6
exercised during the summer vacation from school. Notice of the proposed dates for
8
9
10
2014 shall be made by July 15th. For every other year the notice of the proposed dates
of the vacation must be communicated to the other parent on or before May 15th. In the
event of a conflict in dates, mothers dates shall control in even numbered years and the
fathers proposed dates in odd numbered years.
11
12
3.7
13
14
The residential schedule for the child for the holidays listed below is as follows:
With Father
15
16
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18
19
20
21
22
23
With Mother
Even
Odd
Even
Even
Odd
Even
For purposes of this parenting plan, a holiday shall begin and end as follows (set
forth times):
Martin Luther King, Memorial Day, Labor Day shall include Saturday and Sunday
immediately preceding the holiday and shall end at 7:00 p.m.
July 4th shall begin at 9:00 a.m. July 4th and end at noon July 5th.
3
4
3.8
The residential schedule for the child for the following special occasions (for
5
6
Mothers Day
Fathers Day
Mothers Birthday
Fathers Birthday
Kaenas Birthday
8
9
With Father
None
Every
None
Every
Odd
WithMother
Every
None
Every
None
Even
Special occasions shall begin at 6:00 p.m. the day before the special occasion
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11
and shall end at 7:00 p.m. the day of the special occasion.
In the years the mother is not scheduled to have the child on the childs birthday,
12
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the mother shall have a period of up to four hours with the child during one of the seven
days preceding the childs birthday for a birthday celebration.
3.9
15
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order:
Rank the order of priority, with 1 being given the highest priority:
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3.10
23
Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
21
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2 holidays (3.7)
19
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3.11
T ransportation Arrangements
Transportation costs are included in the Child Support Worksheets and/or the
vehicle, the child shall be secured at all times in the safety restraints as provided by
3
4
5
applicable law and any person transporting the child shall have a valid drivers license
and valid liability insurance.
3.12
6
7
Designation of Custodian
The child named in this parenting plan is scheduled to reside the majority of the
time with the father. This parent is designated the custodian of the child solely for
purposes of all other state and federal statutes which require a designation or
8
9
10
determination of custody. This designation shall not affect either parents rights and
responsibilities under this parenting plan.
3.13
11
12
Other
If the mother will be late for, or will be unable to exercise any scheduled period of
residential time with the child, the mother shall notify the father by telephone at least 48
hours prior to the scheduled beginning of the mothers scheduled residential time. If the
13
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15
Mother is unable to provide the 48 hour notice; said notice shall be made as soon as the
mother is aware of the delay/miss of residential time. If the mother complies with this
notice requirement, the mother shall have the right to make-up residential time with the
child as established between the parents. If the mother fails to comply with the notice
16
requirement the mother shall not be permitted make-up time with the child.
17
3.14
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19
20
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.
21
22
23
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
Parenting Plan Proposed by Petitioner
go ldberg
1
2
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).
4
5
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
6
7
8
9
10
11
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.
15
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An objection may be filed by using the mandatory pattern form WPF DRPSCU
07.0700, (Objection to Relocation/Petition for Modification of Custody Decree/Parenting
Plan/Residential Schedule). The objection must be served on all persons entitled to
time with the child.
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The relocating person shall not move the child during the time for objection
unless: (a) the delayed notice provisions apply; or (b) a court order allows the move.
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
21
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there is a clear, immediate and unreasonable risk to the health or safety of a person or
a child.
23
GOLDBERG & j o n e s p l l c
1100 WntUkc Ave. N , Suite 700
Seattle, Waihingtoti 98109
TH: (200) 448-1010 Fax: (206)4484736
Entail- TSABENigGOLDBERGJONES.COM
1
2
4.1
Each parent shall make decisions regarding the day-to-day care and control of
3
4
Day-to-Day Decisions
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
6
7
4.2
Major Decisions
Major decisions regarding each child shall be made as follows:
8
Education decisions
Non-emergency health care
Religious upbringing
Drivers License
Marriage prior to age 18
Entry into military prior to 18
9
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4.3
15
16
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Joint
Joint
Joint
Joint
Joint
Joint
above.
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
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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):
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mediation by Pierce County Center for Dispute Resolution, if this box is checked
and issues of domestic violence or child abuse are present, then the court finds that the
victim requested mediation, that mediation is appropriate and that the victim is permitted
to have a supporting person present during the mediation proceedings, or
23
The cost of this process shall be allocated between the parties as follows:
1
50% Petitioner 50% Respondent.
The dispute resolution process shall be commenced by notifying the other party
3
by written request.
5
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(a)
(b)
Unless an emergency exists, the parents shall use the designated process
counseling or mediation and of each arbitration award and shall be provided to each
9
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party.
(d)
If the court finds that a parent has used or frustrated the dispute resolution
process without good reason, the court shall award attorneys fees and financial
sanctions to the other parent.
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(e)
The parties have the right of review from the dispute resolution process to
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A.
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Each parent shall provide the other with the address and phone number of
Neither parent shall make derogatory comments about the other parent or
allow anyone else to do the same in the children's presence. Neither parent shall allow
or encourage the children to make derogatory comments about the other parent.
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C.
access and unhampered contact and communication between the children and the
other parent, and to promote the emotions of affection, love and respect between the
children and the other parent. Said contact shall include reasonable telephone and
23
email contact with the child while away from the parent at the calling parents expense.
GOLDBERG & j o n e s p l l c
1100 Westlake Ave. N., Suite 700
Seattle, Washington 98109
Td: (WW) 448-1010 Fai: (206)4484736
Email- TSABINQGOLDBEKGJ ON ES.COM
1
2
All telephone calls shall be made between the hours of 5:00 p.m. and 8:00 p.m. Monday
through Friday or 9:00 a.m. and 8:00 p.m., during weekends or days where there is no
school for the child. If a parent calls and is unable to speak with the child, the parent
shall leave a message and the other parent shall ensure that the child calls back as
soon as is possible, but no later than 24 hours thereafter. Neither parent shall listen in
on the telephone conversations between the child and the other parent, except with the
express consent of the calling parent.
6
7
8
D.
All mail and packages sent to the child by a parent shall be given to the
child immediately upon arrival at the other parents residence. The parent at the childs
location shall provide any necessary assistance with opening and/or reading the
contents of the mailing container.
9
10
11
E.
Neither parent shall use the child to request additional or altered time with
that parent. The parenting plan shall be supported by both parents in the presence of
the child. Neither parent shall use the child as a go-between for communication with
the other parent. Neither parent shall discuss with the child or within the childs hearing
12
13
14
any disagreements or pending court actions the parents may have against the other.
F.
Each parent shall have the right to equal access to all the childs medical,
15
16
17
limited to, any records being kept by or maintained by the State of Washington
Department of Social and Health Services, Child Protective Services Division, or any
other agency of Washington or any other state in which the child may reside. Any third
party having or maintain any such records is hereby authorized to release any and all
18
19
20
21
22
23
Go l d b e r g & j o n e s p l l c
1100 Westlake Ave. N., Suite 700
Seattle, Washington 90109
Tel: (105) 448-1010 - Fax: (106)448-0736
Email- [email protected]
1
2
G.
The childs school shall be kept informed of both parents addresses and
home and work telephone numbers, and the school shall be requested to send
information to both parents for such events as either parent requests.
3
4
5
H.
Each parent shall have equal and independent authority to confer with
school, day care and other programs with regard to the childs progress, and each shall
have free access to school, day care and other records. Each parent shall have
authority to give parental consent or permission as may be required concerning school,
6
7
8
day care o other programs for the child while the child is in her or her care.
I. Each parent shall have equal and independent authority to obtain information
regarding the well-being of the child, including but not limited to, copies of report cards,
school meeting notices, vacation schedules, class programs, request for conferences,
9
10
11
results of testing, results of diagnostic tests, notices of activities involving the child,
samples of school work, order forms for school pictures, and all communications from
all schools, regular day care providers, and counselors. Each parent shall notify the
other, as soon as that information becomes known to the parent, of any parent teacher
12
13
14
conferences to be conducted regarding the child, and the other parent shall have the
right to attend any such conference.
J. Each parent shall have equal and independent authority to arrange routine
medical, optical, and dental services for the child, after coordinating with the other
15
16
17
parent, while the child is in his or her care and residence. The parent scheduling any
such services shall provide the other parent with the name, address and office
telephone number of said care provider.
K. If a parent obtains emergency health care for a child, the parent shall notify
18
19
20
the other parent as soon as possible of the fact that such care has been obtained, the
nature of the illness or injury and the contact information for reaching the care provider.
L. Each parent has the duty to respect the parenting style and authority of the
other parent, and neither parent shall attempt to undermine the authority of the other
21
22
23
parent with the child. Neither parent will make plans or arrangements involving the child
which would impinge upon the other parents authority or time with the child, without the
express agreement of the other parent. If a child has a grievance with a parent, the
other parent must encourage said child to discuss any such grievance directly with the
Parenting Plan Proposed by P etitioner
Go l d b e r g & j o n e s p l l c
1 II Westlake Ave. N , Suite 700
Seattle, Washington 98109
Tel: (706) 448-1010 - Fax: (106)448-0736
Email- [email protected]
1
2
parent in question.
M.
adjustment, either party may require that any such agreement be in writing, dated and
signed by both parents. Provided, however, that in order to change or modify the
designation of the parent who is to have primary residential placement of the child, a
petition to modify the Parenting Plan or other similar procedure under applicable state
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.
11
12
13
It is ordered, adjudged and decreed that the parenting plan set forth above is adopted
and approved as an order of this court.
20
21
22
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.
23
Dated:
Judge/Commissioner
2
Presented by:
e QLDBERG JONES
3
4
A '
K fiU r
5
6
7
2 *
Thomas-Rr Sabin, WSBA 7746
Attorney for Petitioner
.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
SCHOOLS WE PROVIDE IS :
A
IN COUNTY S t lR x 'S OFFICE
01646-7
43334214
PPT
A M.
09-24-14
SEP 2 3
2014
P.M.
J
K l5fM irR )!yASHINGTON
KEVIN
stock;
Br----------- C .
C ountyC lerk
DEPUTY
6
7
10
11
JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
12
and
13
BETH A. KALII,
Respondent.
14
15
16
17
18
19
20
Name
Age
KAENA KALII
21
22
23
Under certain circumstances, as outlined below, the court may limit or prohibit a
parent's contact with the child and the right to make decisions for the child.
2.1
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 1 o f 10
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
2.2
2
3
4
5
6
3.1
10
11
3.2
School Schedule
Upon enrollment in school, the child shall reside equally with both parents on the
following schedule:
12
13
The child shall reside with the parents on a rotating and repeating
alternating week on/week off schedule. Exchanges from one home to the
other will be on Fridays after school or at 2:00 p.m. if there is no school.
14
15
16
17
18
3.3
19
20
21
22
23
24
In even numbered years, the mother shall have the child for the first
half of the Winter Vacation. Visitation shall begin the day after
school lets out at 9:00 a.m. until December 27th at 8:00 p.m. In
even numbered years the father shall have the child from
December 27th at 8:00 p.m. through the day before school
resumes at 6:00 p.m.
In odd numbered years, the father shall have the child for the first
half of the Winter Vacation. Visitation shall begin the day after
school lets out at 9:00 a.m. and conclude on December 27th at
8:00 p.m. The mother shall have the child from December 27th 8:00
p.m. through the day before school resumes at 6:00 p.m.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 2 o f 10
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
3.4
2
The child shall reside with each parent during spring break as follows:
3
The first half of Spring Break shall be with the parent who has the child the
prior week under the alternating week schedule (Par. 3.2); the second half
of Spring Break shall be with the parent who has the child the week after
Spring Break under the alternating week schedule (Par. 3.2). The
exchange shall be on Wednesday at 12:00 p.m. unless otherwise agreed
by the parties.
4
5
6
7
3.5
Summer Schedule
8
Upon completion of the school year the child shall reside with each parent as follows:
9
10
11
3.6
12
13
Each parent shall notify the other parent in writing of his or her two weeks
of vacation no later than May 1 of each year. If there is a conflict in
vacation dates the fathers choice will control in odd years and the
mothers choice will control in even years.
14
15
16
17
18
19
20
21
22
23
24
3.7
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 3 o f 10
W P F D R 0 1 . 0 4 0 0 M a n d a t o r y (6/2008)
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
Holidays marked with an asterisk (*) shall be spent with the parent who is entitled to
the preceding weekend under the alternating week schedule.
Unless otherwise noted, Holidays shall be the night before at 6:00 p.m. until the day of
the Holiday at 8:00 p.m.
4
5
July 4th will be from 10:00 a.m. on July 4 until 12:00 p.m. on July 5.
3.8
The residential schedule for the child for the following special occasions (for
example, birthdays) is as follows:
8
9
10
Mothers Day
Fathers Day
Fathers Birthday
Mothers Birthday
Childs Birthday
11
12
13
With Mother
(Specify Year
Odd/Even/Everv)
Every
With Father
(Specify Year
Odd/Even/Everv)
Every
Every
Every
Odd
Even
If the Special Occasion is on a non-school day, the Special Occasion shall be the
night before at 6:00 p.m. until the day of the Special Occasion at 8:00 p.m.
14
15
If the Special Occasion is on a school day, the Special Occasion shall be from after
school on the day of the Special Occasion until the8:00 p.m. on the day of the Special
Occasion.
16
17
18
3.9
Paragraphs 3.31 - 3.8, have priority over paragraphs 3.1 and 3.2, in the following order:
19
20
Rank the order of priority, with 1 being given the highest priority:
4
school breaks (3.4)
2
holidays (3.7)
1
special occasions (3.8)
6
summer schedule (3.5)
vacation with parents (3.6)
3
winter vacation (3.3)
5
21
22
23
24
3.10
Restrictions
Does not apply.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 4 o f 10
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
253-581-0660
1
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.
6
7
8
9
3.12
The child named in this parenting plan are scheduled to reside the majority of the
time with both parents equally. Both parents are designated the custodian of the
child solely for purposes of all other state and federal statutes which require a
designation or determination of custody. This designation shall not affect either
parents rights and responsibilities under this parenting plan.
10
11
12
13
3.13
14
The father shall provide proof of treatment for his alcohol addiction issues.
16
Each parent acknowledges that the other parent spends substantially equal
residential time with the child. For purposes of any future relocation of the child,
neither parent may claim the presumption under RCW 26.09.520 favoring
relocation of the child and both parents are required to give the notice of
relocation under RCW 26.09.430 and .440 when relocating. Based upon the
child's long-term involvement in school, athletics and other extra-curricular
activities, the existence of family and social relationships and the connections to
health care professionals all in the Pierce County area the parties agree that the
child should remain in the Pierce County area if one parent decides to relocate
out of the Pierce County area.
17
18
19
20
21
22
24
Other
Neither parent shall consume non-prescribed drugs or alcohol in excess of the
legal limit to drive while he or she is personally caring for the child.
15
23
Designation of Custodian
3.14
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 5 o f 1 0
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
3
4
5
6
7
8
9
10
11
12
that person shall give notice to every person entitled to court ordered time with
the child.
If the move is outside the childs school district, the relocating person must give
notice by personal service or by mail requiring a return receipt. This notice must
be at least 60 days before the intended move. If the relocating person could not
have known about the move in time to give 60 days notice, that person must
give notice within 5 days after learning of the move. The notice must contain the
information required in RCW 26.09.440. See also form DRPSCU 07.0500,
(Notice of Intended Relocation of A Child).
If the move is within the same school district, the relocating person must provide
actual notice by any reasonable means. A person entitled to time with the child
may not object to the move but may ask for modification under RCW 26.09.260.
Notice may be delayed for 21 days if the relocating person is entering a domestic
violence shelter or is moving to avoid a clear, immediate and unreasonable risk
to health and safety.
If information is protected under a court order or the address confidentiality
program, it may be withheld from the notice.
A relocating person may ask the court to waive any notice requirements that may
put the health and safety of a person or a child at risk.
13
14
15
16
17
18
19
20
21
22
23
24
Failure to give the required notice may be grounds for sanctions, including
contempt.
If no objection is filed within 30 days after service of the notice of intended
relocation, the relocation will be permitted and the proposed revised residential
schedule may be confirmed.
A person entitled to time with a child under a court order can file an objection to
the childs relocation whether or not he or she received proper notice.
An objection may be filed by using the mandatory pattern form WPF DRPSCU
07.0700, (Objection to Relocation/Petition for Modification of Custody
Decree/Parenting Plan/Residential Schedule). The objection must be served on
all persons entitled to time with the child.
The relocating person shall not move the child during the time for objection
unless: (a) the delayed notice provisions apply; or (b) a court order allows the
move.
If the objecting person schedules a hearing for a date within 15 days of timely
service of the objection, the relocating person shall not move the child before the
hearing unless there is a clear, immediate and unreasonable risk to the health or
safety of a person or a child.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 6 o f 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
253-581-0660
4.1
Each parent shall make decisions regarding the day-to-day care and control of
each child while the child is residing with that parent. Regardless of the allocation
of decision making in this parenting plan, either parent may make emergency
decisions affecting the health or safety of the child.
4
5
Day-to-Day Decisions
4.2
Major Decisions
Education decisions
Non-emergency medical and mental health care
Religious upbringing
10
joint
joint
joint
Regarding medical decisions, either parent may take the child for regularly
scheduled appointments with their ordinary physicians, dentists or medical
care providers for check-ups, vaccinations, routine/recurring doctor or
dental appointments or for treatment of mild or seasonal type illnesses
(e.g., cold, flu, allergy, earaches, anti-biotic, short term prescriptions etc.)
without triggering joint decision-making requirements. The parties shall
communicate as much as possible about even these routine medical and
dental decisions to ensure coordination of care and full advice to the
medical professionals caring for the child.
11
12
13
14
15
Joint decision means that the parent seeking to make a major decision
shall notify the other parent of the proposed major decisions he or she .
intends to make and the other parent may object to the decision and/or
propose an alternative within 14 days of notice. If the other parent does
not object or propose an alternative the parents decision shall be final and
he or she may proceed immediately after the expiration of the 14 days.
The parent seeking to make a decision shall not take any irreversible
action in furtherance of a proposed major decision until after 14 days
notice, or, until after an agreement is reached or a court order is issued if
the other parent objects to the decision.
16
17
18
19
20
21
22
23
4.3
V.
24
Dispute Resolution
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
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, if this box is
checked and issues of domestic violence or child abuse are present, then
the court finds that the victim requested mediation, that mediation is
appropriate and that the victim is permitted to have a supporting person
present during the mediation proceedings, or
The cost of this process shall be allocated between the parties as follows:
4
5
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
- R C W 26.09.016, . 1 8 1 ; . 1 8 7 ; . 1 9 4
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
3
4
5
6
7
8
9
10
11
12
13
Both parties shall allow the child to freely communicate with the other party,
including allowing the child to call the other party on the telephone. Both parties
shall have telephone access with the child, excluding the childs calls to that
party, of not less than two calls per week at reasonable times and for reasonable
durations.
To the greatest extent possible, the parents shall communicate with each other
by e-mail. Each parent shall maintain an e-mail account for this purpose and
keep the other party informed of their e-mail address.
Neither party shall discuss the residential schedule with the child except for plans
that have already been agreed to by both parties. Neither party shall provide
information to the child of the status of child support payments or other legal
matters regarding the parties.
Neither parent shall make disparaging remarks about the other parent or any
other remarks that might cause diminishment of the childs respect for the other
parent either to the child or in the presence of the child, nor shall they allow the
child to make disparaging remarks about the other parent.
14
(Only sign if this is a proposed parenting plan.) I declare under penalty of perjury
under the laws of the state of Washington that this plan has been proposed in
good faith and that the statements in Part II of this Plan are true and correct.*V
I.
18
19
20
It is ordered, adjudged and decreed that the parenting plan set forth above is adopted
and approved as an order of this court.
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.
P a r e n tin g P la n (P P P , P P T , P P ) - P a g e 9 o f 10
WPF DR 01.0400 Mandatory (6/2008) - RCW 26.09.016,
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
253-581-0660
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.
If a parent fails to comply with a provision of this plan, the other parents obligations
under the plan are not affected.
4
5
Dated:
sioner
6
7
Presented by:
FAUBIO
8
9
10
11
/)
F t> g sn o tfU Y ;
tv
12
13
Date
alii, Respondent
Date
14
15
IN COUNTY C lI
16
a .m
17
r KS
OFFICE
SEP 2 3 201^
pm
18
19
20
21
22
23
24
P a re n tin g P la n (P P P , P P T , P P ) - P a g e 10 o f 10
W P F D R 01.040 0 M a n d a to ry (6/2008) - R C W 26.09.016, . 1 8 1 ;. 1 8 7 ;. 194
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
253-581-0660
\
l
i
01646-7
43334216
ORSW
09-24-14
IN COUNTY
CLERKS OFFICE
4
am.
SEP 23 2014
p-m-
7
8
9
SUPERIOR COURT OF WASHINGTON
COUNTY OF PIERCE
10
11
No. 14-3-01646-7
JOHN A. KALII,
13
and
14
BETH A. KALII,
15
Respondent.
16
I. Judgment Summary
17
1.1
18
19
1.2
20
II. Basis
21
2.1
Type of Proceeding
22
23
O r d e r o f C h ild S u p p o r t (T M O R S , O R S ) - P a g e 1 o f 13
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P .S .
1
Hearing for temporary child support.
2
2.2
3
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.
4
5
2.3
Other
6
Does not apply.
7
III. Findings and Order
8
It is Ordered:
9
3.1
10
Name (first/last)
KAENA KALII
11
12
13
14
3.2
Age
7
15
9711 Winona ST SW
Lakewood WA 98498
16
17
18
19
20
The obligor parent must immediately file with the court and the Washington
State Child Support Registry, and update as necessary, the Confidential
Information Form required by RCW 26.23.050.
The obligor parent shall update the information required by paragraph 3.2
promptly after any change in the information. The duty to update the
information continues as long as any monthly support remains due or any
unpaid support debt remains due under this order
21
22
For purposes of this Order of Child Support, the support obligation is based upon
the following income:
23
A.
O r d e r o f C h ild S u p p o r t (T M O R S , O R S ) - P a g e 2 o f 13
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P .S .
253-581-0660
1
2
3.3
6 1 1 4 -112th ST SW #54
Lakewood, WA 98498
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.
10
11
12
For purposes of this Order of Child Support, the support obligation is based upon
the following income:
13
A.
14
3.4
Service of Process
Service of process on the obligor at the address required by paragraph 3.2
or any updated address, or on the obligee at the address required by
paragraph 3.3 or any updated address, may be allowed or accepted as
adequate in any proceeding to establish, enforce or modify a child support
order between the parties by delivery of written notice to the obligor or
obligee at the last address provided.
15
16
17
18
3.5
Transfer Payment
19
20
The obligor parent shall pay the following amounts per month for the following
child(ren):
21
Name
22
KAENA KALII_____________________________
$723.27
23
$723.27
O r d e r o f C h ild S u p p o r t (T M O R S , O R S ) - P a g e 3 o f 13
Amount
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P .S .
3
4
5
6
3.6
7
8
Standard Calculation
3.7
9
10
3.8
11
( k </pP{j a/ T
F a FOC t / f
12
3.9
13
Starting Date:
Day(s) of the month support is due:
14
15
3.10
S e PTF0S c /2. S - O /t f
__________ ________________
Incremental Payments
t
16
17
18
19
20
21
3.11
22
23
S:\CASES1\Kalii\DRAFTS\PIeadings\Temporary OrderofChildSupport.doc
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P .S .
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:
4
Washington State Support Registry
P. O. Box 45868
Olympia, WA 98504
Phone:
1-800-922-4306 or
1-800-442-5437
5
6
7
[]
8
Name:
Mailing Address:
BETH KALII
6114 - 1 12th ST SW #54
Lakewood, WA 98498
10
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.
11
12
13
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 child(ren).
14
15
16
3.12
17
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:
18
19
20
3.13
Termination of Support
Support shall be paid:
21
22
23
3.14
S:\CASES1\Kalii\DRAFTS\Pleadings\Temporary OrderofChildSupport.doc
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P.S.
5920 100th S treet SW , Suite 25
L ake w o od , W A 98499
253-581-0660
1
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.
2
3
3.15
4
N
Does not apply because all payments, except medical, are included in the
transfer payment.
The petitioner shall pay 65% and the respondent 35% (each parents
proportional share of income from the Child Support Schedule Worksheet,
line 6) of the following expenses incurred on behalf of the child(ren) listed
in Paragraph 3.1:)
DAO
day care^ UJOdtC &&tA~pcD ^D *-i7V/2
Uoi
T'
educational expenses.
N
long distance transportation e>$nfes. 'p w v to s %finCA/t TU r t& re|
[]
other:
Se r u T f i C w f r O A t N
tJ/?H *
P ee.
Payments shall be made to [ ] the provider of the service [ ] the parent
receiving the transfer payment.
6
7
8
9
10
11
12
13
The obligor shall pay the following amounts each month the expense is
incurred on behalf of the child(ren) listed in Paragraph 3.1:
14
[]
15
[]
16
[]
17
[]
[]
18
19
3.16
20
21
22
Periodic Adjustment
3.17
23
S:\CASES1\Kalii\DRAFTS\Pteadings\Temporary OrderofChildSupport.doc
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P.S.
5920 100th S treet SW , Suite 25
L ake w o od , W A 98499
253-581-0660
1
The parents shall sign the federal income tax dependency exemption waiver.
2
3.18
3
4
Each parent shall provide health insurance coverage for the child(ren) 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.)
6
A.
10
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.
11
OR
12
7
8
13
14
B.
15
[]
16
17
18
19
JOHN KALII
(Parents Name)
[ i
20
21
22
23
[ i
BETH KALII
(Parents Name)
O r d e r o f C h ild S u p p o r t (T M O R S , O R S ) - P a g e 7 o f 13
S:\CASES1\Kalii\DRAFTS]Pieadings\Temporary OrderofChildSupport.doc
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P .S .
1
[ ]
2
3
4
[ ]
5
6
[ ]
7
8
[ ]
[ ]
[ ]
[ ]
10
11
12
13
14
15
16
17
C.
Parties obligations:
Does not apply because A (1) is checked above.
The court makes the following orders:
18
19
20
21
22
23
O rd e r o f C h ild S u p p o rt (TM O R S, ORS) - P age 8 o f 13
W P F D R 0 1 . 0 5 0 0 M a n d a t o r y (06/2014) - R C W 26.09.175; 26.26.132
Kalii, John and Kalii, Beth
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P.S.
5920 100th S treet SW , Suite 25
L akew ood, W A 98499
253-581-0660
1
2
3
4
JOHN KALII
(Parents Name)
[ ]
BETH KALII
(Parents Name)
[ ]
5
6
7
[ ]
8
9
10
11
12
[ ]
[ ]
[ ]
[ 1
13
14
15
16
17
18
[ 1
19
20
21
22
23
[ ]
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P.S.
5920 100th S tre et SW , S uite 25
La ke w o od , W A 98499
253-581-0660
1
2
[ ]
[ ]
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
D.
22
A parent required to provide health insurance coverage must notify both the
O rd e r o f C h ild S u p p o rt (TM O R S, ORS) - P age 10 o f 13
W P F D R 0 1 . 0 5 0 0 M a n d a t o r y (06/2014) - R C W 26.09.175; 26.26.132
Kalii, John and Kalii, Beth
S:\CASES1\Kalii\DRAFTS\Pleadings\Temporary OrderofChildSupport.doc
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P.S.
5920 100th S treet SW , Suite 25
L akew ood, W A 98499
253-581-0660
1
Division of Child Support and the other parent when coverage terminates.
2
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:
3
4
5
7
8
9
10
11
12
13
14
3.19
15
Both parents have an obligation to pay their share of uninsured medical
expenses.
The FATHER shall pay 65% of uninsured medical expenses (unless
stated otherwise, the petitioners proportional share of income from the
Worksheet, line 6) and the respondent shall pay 35% of uninsured medical
expenses (unless stated otherwise, the respondents proportional share of
income from the Worksheet,
line 6).
16
17
18
19
20
3.20
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.
21
22
3.21
23
Unpaid medical support that may be owed is not affected by this order.
Order of Child Support (TMORS, ORS) - Page 11 of 13
WPF DR 01.0500 Mandatory (06/2014) - R C W 26.09.175; 26.26.132
FAUBION, REEDER
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
La kewood, WA 98499
253-581-0660
1
I(a
0 2
u
3
IN COUNTY CORK'S
Other obligations that may be owed are not affected by this order!'
2014 p.m.
Back interest that may be owed is not affected by this order. kevPn S$UNTY Washington
BY
o office
3.23
O ther
f1"; 6
rn
7
8
h
S io
Dated:
Presented by:
FAUBION, REEDER, FRALEY & COOK,
P.S.
r n
({j
ianTeTTTCobk, WSBA #34866
Attorney for Respondent
Cj /TH
______________
__________________ , WSBA #_______
Attorney for Petitioner
(i 12
13
/)s
14
15
Tt>
16
17
BETH KALII
18
[]
19
KALII, PETITIONER
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.)
20
Signature of Party
21
22
23
[]
FAUBION, REEDER
FRALEY & COOK, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
1
2
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
O rd e r o f C h ild S u p p o rt (T M O R S , O R S ) - P a g e 13 o f 13
F A U B IO N , R E E D E R
F R A L E Y & C O O K , P .S .
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
July 03 2014 4:04 PM
KEVIN STOCK
, W 5V C S OFflCfcoUNTY CLERK
IN COUNTY CLERK
N0: 14_3_01646-7
SEP 23 20^ PM
(CSWP)
Father
$4,352.37
Mother
$2,667.00
$4,352.37
$2,667.00
$323.46
-
$19.86
$123.89
$5.35
$46.10
$254.11
$449.31
$323.46
$2,217.69
$4,028.91
$6,246.60
1'
$887.00
,;* "Tj
.645
.355
$572.12
$314.88
| $1,216.00
$314.88
$572.12
Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
10. Health Care Expenses
a.Monthly Health Insurance Paid for Child(ren)
b.Uninsured Monthly Health Care Expenses Paid for Chiid(ren)
c. Total Monthly Health Care Expenses
(line 10a plus line 10b)
d.Combined Monthly Health Care Expenses
(line 10c amounts combined)
11. Day Care and Special Expenses
a. Day Care Expenses
b. Education Expenses
c. Long Distance Transportation Expenses
d. Other Special Expenses (describe)
Father
Mother
$234.34
$234.34
$234.34
; f."!
ci.'S
.
i "
$234.34
$151.15
3.3
$83.19
$723.27 |
$398.07
$234.34
-
$234.34
$723.27
$163.73
$1,813.01
$997.96
$143.03
$78.72
Mother's
Household
_
-_
------------------ -
----------
- __
- ..................................
............. -
..............
................
...................................... ........................
- - -------
............... -
__ _
............ ...............- ^
.............
26.
Mother's
Household
Fathers
Household
- ............... ...
........ ----------------------
SupportCafe 2014
_____
ROBYN A LINDSAY
COURT COMMISSIONER
FILED
a .m .
SEP 2 3 2014 pm
T J a n ie d
R e s j 0 o n d ^ + 'S
p A r w U n a
'
nod
S h a re d
-ft)
e /n A e jr
iD o lc in a
-h >
^4npom n^
e n + er-
S u m v .O D Y - h .
n r ri-e v c d .
siA Q to o rt
S i ^ i /i o r d -
A kO
O r d ' O Y * __ Q - f -
nYY)
C h ild
W\o-Vioo
p la in .
\ tM f\ V 0 Y ~ T \ rL A
)s
_________
For Respondent
For Petitioner
re:
r o o t-'
j U ji ___ C
a re *
__ f J c h o e / n s . ^
L \ry)
*
ID ' 31 awn
7 lS
_____
14-3-01646-7
43335496
09-24-14
AFPT
T /M
'
A .M .
SEP 2 2 2014
P.M.
No.
Petitionert1,
and
/Y
Declaration of
A - K A U I
[Name]
(Optional Use)
(DCLR)
Respondent#).
\fo ^ r fd
^
A <
_________
/ ______________________________________
l T~l
/ Declare:
_______ A g -T A T C -H M S a J t
, [City]
M/ A
[State] on
* 2 -2
^ 0
[Date].
I
APPLE HEALTH FOR KIDS PROGRAM
In Washington State, a program is offered to provide health insurance coverage to children under age 19, and qualification is
based on the family income level. The program is funded by federal tax dollars, and almost all states have taken advantage
of these dollars and developed similar programs.
Qualification for the Apple Heath for Kids program is as shown below:
The Fam ilys Income is:
Up to 200% o f "federal
poverty level"*
Notes:
Free
METUFE DENTAL
WILLAMETTE DENTAL
$ 69.57
$ 66.65
$138:32
$124.25
$138.32
$124.25
$227.12
$124.25
$227.12
$181.45
$227.12
$181.45
Use any Ijcensed dentist.Use of a MetLife:; { j Use.a Willamette Dental Group Provider; ;c
PRO Network dentist may provide additional:
benefits.
;:C^vvcVCf 'V:
$2,250 per calendar year
No maximum benefit, except TMJ
7 f /None V p v p p / p p - p C V p y p p p V V
100% after $10 copay ($30 copay for Specialty
office visit)
V- P;100% aften$10;rapay>pv C p P p p p v p
- VC ;;V v V | p a p p p p V C p C p
i:ViPP -T:P^pPPPp \;p VP/P --PPPPP-PPPP
\.v&
Covere^at 50%p:P?p c f c
Implants
Covered at 50%
^Emergencyfr e a t m e n t ^ v V ^Coveredas anyother^mcejPp ryj; VJp;^Covered after $50 copay, or up to $100 for. oiitp
v
v5V C y C C C V : VV
of-area emefoen&lreatfoentP
50% to $1,000 lifetime maximum (for
dependents to age 26)
iiNot^veredppvp
Orthodontia
Jtmj
,VV/,.
,W Cv- -ViV-JCCC'
' j - V C , P/
s'*
V n
Office visit copays are waived after three consecutive years of being on the Willamette Dental plan (except for Orthodontia).
You must request the waiver of copays: it is not automatic in Willamette's computer system. (Emergency Treatment copays
still apply.)
o Willamette Dental is an exclusive provider network. Benefits are covered under a Willamette Dental group provider. To find
a provider in your area, please visit their website at www.wiiiamettedental.com or call 1.855.433.6825 to speak to a member
services representative.
1.) Beth Kalii has worked an (8) eight hour work day schedule
the entire period of our marriage. In her initial bus route
bidding, she elected to choose a bus route giving her only a (6)
six hour work day, reducing her weekly hours from (40) forty
hours to (30) thirty hours. She is presently recieving pay for (40)
forty hours a week, because by Contract with The Clover Park
School District, she continues to be paid full time until re
bidding (for bus routes) are finalized. The date for re-bid is Oct
7, 2014. If she fails to bid on a route with more hours by that
date, she will be locked into her (30) thirty hour a week work
schedule for the remainder of the school year and be salaried
as such. As it stands now, By Beth bidding on the (30) hours a
week, She has essencially voluntarily reduced her work hours
by (40) forty hours a month, reducing her monthly gross
income by $760.00.
Her reasoning for this move was so that she did not have to
wake our daughter, Ka'ena Kalii, an hour sooner in the morning
on her school days. I believe this move was intended to
i
N
ll
Handbook 2014-2015.
The reason why I consider this Medical Insurance change so
important is that both Beth and I will financially benefit. Both
Beth and Ka'ena will get 100% free coverage under the offered
!'V,;
>
in c o u n t y J
/
a .m .
\ i
"
14-3-01646-7
43345929
09-25-14
TMO
SEP 23 201% PM
3
4
e r k 's o f f ic e
I j
1.! J
l'"U
9
SU PER IO R CO URT OF W A SH IN G TO N
CO UNTY OF PIERCE
10
n
ijj 11
It:
No. 14-3-01646-7
12
JOHN A. KALII,
13
and
14
BETH A. KALII,
Petitioner,
'Tl
Respondent.
15
16
17
18
II. Basis
A motion for a temporary order was presented to this court and the court finds
reasonable cause to issue the order.
21
22
23
24
25
III. Order
It is O rd ered :
3.1
Restraining Order
There are no restraining orders in effect under this cause number and the court is
not entering one now.
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
3.2
Temporary Relief
2
The parties shall comply with the Temporary Parenting Plan signed by the court.
3
O&
Other:
N fi
s p o ils A c
c v /to
1 7 i
70
7
3.3
,
Does not apply.
3.4
R>
As
$ !. O S D
SVPPO/ZZ~ 0 *S L Y
Bond or Security
^
8
9
c o ^ m /e c /y p ^
-Tt?
p ^ V rJr H
S o rro a r
&F
f f /Z
f F / } r r t o i / / ^ T O F # 1 <23-3-7
P i / l Z U / \ ^ T 7> /ME- O to E e
s c /E ^ fi J >
# *
O F C tf/tO
Other
10
11
12
Dated: _
13
14
15
16
17
18
19
Presented by:
FAUBION, REEDER, FRALEY & COOK.
ROBYN A LINDSA
Approvedarra agreed by:
COURT COMMISSIO
N o tice^ p rese n ta tio n waived.
Pa
( jJ
OanuJnJ_______
T
Approved and agreed by:
A signature below is actual notice of this
order.
O fiJ o /
20
21
Date
22
23
24
25
Temp Order (TMO) - Page 2 of 2
W PF DR 04.0250 Mandatory (0&2012) - R C W 26.09.060; .110; .120; .194, .300(2)
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood WA 98499
253-581-0660
14-3-01646-7
43347400
LTRSTC
09-25-14
1 S u p e r io r C o u r t
J
OF THE
S t a t e o f W a s h in g t o n
f o r P ie r c e C o u n t y
SUPERIOR COURT
(253) 798-3654
Daniel N Cook
ATTORNEY AT LAW
5920 100th ST SW Ste 25
LAKEWOOD WA 98499-2751
John Alika Kalii Jr.
9711 Winona ST SW
LAKEWOOD WA 98498
Dear Counsel/Litigant:
This is to confirm the following settlement conference:
Case:
Cause No.:
Before:
Date & Time:
2.
3.
Please remember that failure to supply the settlement judge with appropriate forms in a timely
manner may result in the imposition of sanctions. For complete information regarding settlement
conferences, please refer to the Pierce County Local Rules.
Sincerely,
d iiu s )
}
Judicial Assistant
CC: Pierce County Clerk for Filing
E-FILED
IN COUNTY CLERK'S OFFI<
PIERCE COUNTY, W ASHING
NO: 14-3-01646-7
3
4
5
6
7
9
No. 14-3-01646-7
11
12
13
DECLARATION OF MAILING
Petitioner,
and
BETH ANN KALII,
Respondent.
14
15
16
I, Sally DuCharme, am over the age of 18, and competent to testify in the above
entitled case.
On September 17, 2014, I placed in the U.S. Mail a copy of the following
documents in the above-entitled caption:
17
18
19
20
21
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
September 29,2014
25
^
Declaration Of Mailing
Kalii, John and Kalii, Beth
S:\CASES1\Kalii\DRAFTS\Pleadings\Declaration of Mailing.doc
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING T(
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
10
In re the Marriage of:
11
No. 14-3-01646-7
JOHN A LIK A KALII, JR.
12
Petitioner,
and
13
14
Respondent.
15
I. Motion
16
17
18
19
(Name of requesting party) BETH KALII moves the court for an order directing (name of
other party) JOHN KALII to appear personally before the court and show cause why an
order should not be entered:
1.1
Finding Contem pt
20
The order of child support signed by the court on (date) September 23,
2014, in (county and state) Pierce County, Washington.
21
22
1.2
23
24
25
FAUBION, REEDER,
FRALEY & COOK P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
1
1.3
Granting Sanctions
2
Granting sanctions for contempt, including a forfeiture for each day the contempt of
court continues, and establishing conditions by which the contempt may be purged
and granting any other relief, including reasonable attorney fees and costs and
m ake up residential time, as may be appropriate under Chapter 7.21 RCW ,
Chapter 26.09 RCW , Chapter 26.10 RCW , Chapter 26.26 RCW , and R C W
26.18.040.
3
4
5
1.4
Other
8
Does not apply.
9
10
11
} L(
FA UBIO N, R E E D E R , FR A LEY
12
Daniel N. Cook, W S B A 34866
O f Attorneys for Respondent
13
14
II. Declaration
15
Failure to comply with the provision of the child support order which directed
payment of:
Current child support in the amount of $ 723.27 per month.
19
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
2
3
4
5
6
7
8
9
10
11
12
13
over a trailer that we acquired during our marriage in lieu of paying me child
support.
I knew of two friends who wanted to buy the trailer. Faced with the prospect of no
support from JOHN and the opportunity to sell the trailer and have some cash
available I agreed to JOHNS proposal.
I had no money and owed a balance to my attorney so I did not discuss the matter
with him. JOHN told me that in order to get the trailer I had to sign a document
saying he would not pay child support for six months if he gave me the trailer. I
had no other option and I signed it hoping to sell it and have cash for bills.
Then both potential buyers backed out. I now have a trailer, which was arguably
my separate property to begin with since it was a gift to me during the marriage,
sitting in my driveway and no cash for child support. I need JOHN to begin paying
child support again. I will attempt to sell the trailer and JOHN will receive credit for
one-half of the amount received for the trailer against the back support he owes
but I need child support to be paid at this time. I will not ask for interest on the
back amount due.
John receives approximately $5,000 per month in income. He is retired. He could
work if he wished or if he needed money. But he is happy in retirement living on
his $5,000 per month. That is fine if he wants, but child support needs to be paid.
14
15
16
17
18
I work full-time as a bus driver for the Clover Park School District. I receive net
income of $1,900 per month. I am currently paying $950 for rent each month. My
utilities are $400 per month. Car insurance is $70 per month. My gas expense is
$200 per month. I have monthly prescription medication and regular doctor visits
which cost $50 per month. That is $1,670 per month and only leaves me with
$230 per month for groceries, supplies, personal /toiletries and clothing for KaEna
and me.
It is simply not enough. I have had to borrow lots of money from friends
to simply make ends meet.
19
20
21
22
23
24
25
If JOHN begins paying child support for the month of January 2015 and forward
without requiring a contested hearing then I will not ask for a finding of contempt.
I understand that JOHN stopped paying because he released his interest in the
trailer. But the deal that JOHN forced me to sign under threat of no payment at all
was not fair and should not be maintained. JOHN needs to pay child support. If
JOHN does not pay child support beginning with the month of January 2015 then
he should be held in contempt. He is now on notice that his releasing of his
interest in the trailer is not adequate to offset child support.
JOHN also needs to pay his share of daycare. KAENA spends equal amounts of
time with both parents. She is with me for a week and then with JOHN for a week.
Mot/Dec Ord Show Cause re Contempt (MTSC) - Page 3 of 4
WPF DRPSCU 05.0100 Mandatory (10/2009) - RCW 26.09.160
FAUBION, REEDER,
FRALEY & COOK P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253)581-0660
1
2
3
4
5
6
7
Historically JOHN has watched KAENA before and after school on my weeks
because I am employed and he is retired. He recently told me he would not watch
KAENA on my weeks anymore. That is fine and is his option and I will put
KAENA in a commercial daycare. But the Temporary Order of Child Support
specifically and unambiguously requires JOHN to pay his share of daycare on my
weeks if he does not provide the care. JOHN has told me he will refuse to pay
daycare. If he does not pay daycare he should be held in contempt.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
STATE OF WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
8
Signed at
9
'
on
O
(City)
(State)
10
11
BETH KALII
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Mot/Dec Ord Show Cause re Contempt (MTSC) - Page 4 of 4
WPF DRPSCU 05.0100 Mandatory (10/2009) - R C W 26.09.160
FAUBION, REEDER,
FRALEY & COOK P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
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
DATED:
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
Attorney for Respondent
LAKEWOOD, WA 98499-2751
1 of 1
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
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,CNTP~Contempt
Calendar: Show Cause/Family Law
DATED:
Signed:
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
Attorney for Respondent
LAKEWOOD, WA 98499-2751
1 of 1
to
C2
0
i C O U H * CSOFBCE
3
4
43961564
U-3-0164-7
ORTSC
01-16-15
j . JAH15286 ^
J6
N
7
m
8
IN THE SUPERIO R COURT OF THE STATE OF W ASHINGTON
IN AND FOR THE CO UNTY OF PIERCE
U?
No. 14-3-01646-7
JOHN ALIKA KALII, JR.
Petitioner,
Respondent.
and
t 13
It is O rdered :
16
(Name of nonrequesting party) JOHN KALII 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.
17
18
Date:
Time:
Place:
19
20
21
22
23
February 5, 2015
9:00 a.m.
Pierce County Superior Court
Room/Department: 117, 407 or 2-A as assigned
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.
24
Dated:
' 5
25
Ord to Show Cause re Contempt (ORTSC) - Page 1 of 1
WPF DRPSCU 05.0150 Mandatory (6/2008) - R C W 26.09.160
FAUBION, REEDER,
FRALEY & COOK P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
#- -
i<)
3)
3
4
Presented by:
FAUBION, REEDER, FRALEY & COOK,
P.S.
5
j.6
Ci
7
Li?
'H
;;10
N
\11
0
.12
i3
14
15
16
17
18
19
20
21
22
23
24
25
Ord to Show Cause re Contempt (ORTSC) - Page 2 of 1
WPF DRPSCU 05.0150 Mandatory (6/2008) - R C W 26.09.160
FAUBION, REEDER,
FRALEY & COOK P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
1
i? l
S '
c?
IN COUN^
\AN 20 2015 pW
I
4v
5
6
&
wi
u8
IN THE SUPERIO R COURT OF THE STATE OF W ASHING TO N
IN AND FOR THE C O U N TY OF PIERCE
Ifi
H10
o
r 11
, 12
Petitioner,
Respondent.
and
13
BETH ANN KALII,
14
15
It is Ordered:
16
(Name of nonrequesting party) JOHN KALII 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.
17
18
Date:
Time:
Place:
19
20
21
22
23
February 4, 2015
9:00 a.m.
Pierce County Superior Court
Room/Department: 117, 407 or 2-A as assigned
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.
24
Dated:
25
JAN 2 0 2015
MARY E DICKE
_
. .
COURT COMMISSIONER
(Com m issioner
JudgsCommissi<
FAUBION, REEDER,
FRALEY & COOK P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
<#
-1
;i
VI
"I
3
Presented by:
FAUBION, REEDER, FRALEY & COOK,
P.S.
.6
3!
J:7
9
.0
10
"'in
;\j'n
>3
14
15
16
17
18
19
20
21
22
23
24
25
Ord to Show Cause re Contempt (ORTSC) - Page 2 of 1
WPF DRPSCU 05.0150 Mandatory (6/2008) - R C W 26.09.160
FAUBION, REEDER,
FRALEY & COOK P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
Phone: (253) 581-0660
14-3-01646-7
44047520
AFPT
01-30-15
JAN 2 9 2015
p,A
A-U K &
K A U /
CTA
No.
Petitioners),
and
"7
Declaration of
& ? {{ A H N
K A U I1
ia t
^ cT ) ^
727
CO NTEM P T .
[Name]
(Optional Use)
(DCLR)__________________________
Respondent(s).
Name:
Age:
j 7 2 / c L
/ K -A
1/
s.772^
7? 2 _____________________________
I Declare:
k w iT io H k L ___ A / U P
a a a
h r-T A T C H z ry
M ( 1 < M E ^ f 7 . ______________________________
v
^
Signed at
LA
. [City]
\a)A
<Tofa4 AUKA KALII
vTR
out.
Having been satisfied fo r fo ur (4) m onths concerning th e child
support paym ent, Beth Kalii is now claiming th a t John Kalii is in
co n tem p t fo r non-paym ent.
*
John Kalii does not recieve $5,000 per m onth in income as Beth Kalii
suggests. Prior and current financial disclosures shows John Kalii's net
incom e to be $4,02 8.91 . Beth Kalii and M r. Cook are w ell aw are of this
as th ey both have seen and signed copies of this. A Pension Verification
Letter is provided here, as well as a benefit sum m ary from th e
W ashington State of R etirem ent Systems. Beth Kalii also claims to
recieve a net income o f $1,900 a m onth. According to her signed
financial disclosures, her reported net incom e is $2,217.69. O ther
claims concerning rent ($950), gas ($200) and utilities ($400) are also
subject to question and appear to be clearly inflated. I w ould ask th a t
th e Court require Beth Kalii to o ffer th ree (3) months proof of these
d ifferen t reported figures.
*
r)
M other's care.
John Kalii has never refused to pay child support or child care at
any tim e. Beth Kalii should be held accountable for these statem ents by
h
:i
ACCEPTANCE AGREEMENT
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1/2
STATE OF W ASHINGTON
January 9, 2015
JOHN A. KALII
9711 WINONA ST SW
LAKEWOOD WA 98498
David Nelsen
Assistant Director
Customer & Policy Services
Benefit Summary
1/22/2015
easy to see
y o u r fuiure
360-664-7000 | 800-547-6657
B e n e fit S u m m a ry
Help
T h is s c re e n p re s e n ts in fo rm a tio n a s re p o rte d b y y o u o r y o u r e m p lo y e r a s o f T h u rs d a y , J a n u a ry 2 2 ,2 0 1 5 . If
in fo rm a tio n d is p la y e d is in c o rre c t, p le a s e s e e th e in s tru c tio n s o n h o w to m a k e c h a n g e s .
Membership Details
N am e:
J o h n A K a lii
S y s te m /P la n :
S ta tu s :
R e tire d
Retirement Details
D o w n lo a d P e n s io n V e r ific a tio n L e tte r
D a te :
0 1 /0 1 /2 0 1 3
S e rv ic e C re d it:
T ype:
S e rvice
O p tio n :
S in g le L ife
3 9 6 .0 0 m o n th s o r 3 3 .0 0 ye a rs
1 1 /2 8 /2 0 1 4
1 2 /3 1 /2 0 1 4
G ro s s B e n e fit
$ 4 ,4 0 5 .4 7
$ 4 ,4 0 5 .4 7
(Rate Below):
-3 3 1 .4 3
-3 3 1 .4 3
N e t B e n e fit A m o u n t:
$ 4 ,0 7 4 .0 4
$ 4 ,0 7 4 .0 4
IR S W ith h o ld in g
Beneficiary
1/1
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON
July 03 2014 4:04 PM
KEVIN STOCK
COUNTY-CLERK
N O : 14-3-016 46-7
H
!'")
n
^
W a s h in g t o n S t a t e C h ild S u p p o r t S c h e d u le W o r k s h e e t s
[ ] P roposed b y [ ]
[ ] S tate o f W A [ ] O th e r
O r, [ ] S igned b y th e J u d icia l/R e vie w in g O ffice r. (C S W )
M o t h e r B eth K alii
F a th e r John K a lii
C o u n ty P IE R C E
C a s e N o . 14-3-016 46-7
(C S W P )
F a th e r
$4,3 5 2 .3 7
-
M o th e r
$2,6 6 7 .0 0
-
_
.
$4,3 5 2 .3 7
$2,6 6 7 .0 0
$323.4 6
_
-
$ 1 9.86
$ 1 23.8 9
$5.35
$46 .1 0
$254.11
$32 3 .4 6
$449.31
$ 2 ,2 1 7 .6 9
$4,028.91
$ 6 ,2 4 6 .6 0
6. P ro p o rtio n a l S h a re o f In co m e
(each parents net income from line 3 divided by line 4)
.6 4 5
.355
E-FILED
IN COUNTY CLERI
PIERCE COUNTY, W
February 03 2015
KEVIN STO
COUNTYC.
NO: 14-3-0'
2
3
4
5
6
7
8
9
10
)
)
)
)
Petitioner,
31
and
12
BETH ANN KALII,
13
Respondent.
14
15
16
17
18
19
20
21
22
23
The undersigned declares under penalty o f perjury under the laws o f the State o f
Washington that the following is true and correct.
The declarant is now and at all times herein mentioned was a citizen o f the United
States and a resident o f the State o f Washington, over the age o f 18, not a party to nor
interested in the above-entitled action and competent to be a witness therein:
On the 21st Day O f JANUARY, 2015 at 5:10 PM I served the above-described
documents on JOHN ALIKA KALII, JR, and all other occupants named defendant (s), by then
and there:
Personally delivering ONE (1) true and correct copy(ies) thereof to JOHN ALIKA
KALII, JR, PERSONALLY.
24
The service address is: 9711 Winona Street SW, Lakewood, Pierce County, WA 98498.
25
Dated this 2nd Day O f February, 2015 at Tacoma, Pierce County, WA.
A n d er so n I n v e s t ig a t io n s , L L C
P.O. B ox 7770
Tacoma, W A 98417
Telephone: (253)301-2240
Cost: $70.00
2
3
fichael K. Anderson
Private Investigator, WA Lie. #3317
Process Server
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A nderso n I n v e s t ig a t io n s , LLC
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, W A S H IN G !
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
3
4
5
6
7
8
9
10
11
12
13
No. 14-3-01646-7
Petitioner,
14
and
15
Respondent.
16
I. Motion
17
18
Based upon the declaration below, the undersigned moves the court for a temporary
order and order to show cause.
19
1.1
20
21
22
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 S tre et SW, Ste 25
Lakew ood, W A 98499
253-581-0660
1
The other party should be required to appear and show cause why these
restraints should not be continued in full force and effect pending final
determination of this action.
2
3
1.2
1.3
1.4
10
11
1.5
Other
Does not apply.
12
13
DATED this 3 ^
14
15
Daniel N. Cook, W S B A ^ 8 6 6
AttOrney for Respondent '
16
17
II. Declaration
18
19
20
2.1
Injury to be Prevented
The ex parte restraining order requested in paragraph 1.1 and 1.2 above is to
prevent the following injury (define the injury):
21
22
23
24
25
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
2.2
Not only would I lose my job if JOHN KALII continues to spread untrue
rumors about me that I would drink on the job, but this could affect my
ability to get other jobs driving or working with children in the future.
5
6
2.3
2.4
12
2.5
14
16
17
18
19
11
15
10
13
2.6
Was notice of this request for an emergency order given to the other party or
lawyer?
Yes. Explain what efforts have been made to give written or oral notice
to the other party or other partys lawyer:
JOHN KALII WILL BE SERVED WITH THIS MOTION AT THE PARTIES
SHOW CAUSE HEARING ON FEB. 3 AND NOTIFIED THE EX PARTE
RESTRAINING ORDER WILL BE SOUGHT.
20
21
22
23
I declare under penalty of perjury under the laws of the state of Washington that the
foregoing is true and correct.
Signed at (city)
QU O >
(state) (/- ^ i
on (date)
2~ 3
24
25
Beth Kalii
M tn /D e c l fo r E x P a rte R e s tra in in g O rd (M T S C ) - P a g e 3 o f 4
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
1
2
3
4
5
6
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
^po
For Petitioner
For Respondent
RE:
/y g ^ r m o ^ r -
.....r^ Q
-So-^r
< ^ ie ^
~K?
00^1
? s
n.
Show Cause
ROBYN LINDSAY
Clerk:
Courtroom number: 117
Calendar:C2 - SHOW CAUSE/FAMILY LAW
^ ^,
^-0^6-7 4*07813'
tprotsc
02-0&-15
A M
FEB
2015
p m.
6
7
8
9
10
11
12
13
No. 14-3-01646-7
JOHN ALIKA KALII, JR.
Petitioner,
and
14
15
16
17
18
19
21
22
20
23
24
25
It is Ordered the petitioner 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 far the following date, time and place:
Date:
Time:
Room/Department: TBD
9:00 a.m.
F A U B IO N , R EEDER, F R ALEY
& C O O K , P.S.
5920-100 S treet SW, Ste 25
LakewoOd, W A 98499
253-581-0660
1
2
3
4
5
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 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 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.
Failure to appear may result in a Temporary Order being entered by the court that
grants the relief requested in the motion without further notice.
9
10
II. Basis
A motion for a temporary restraining order without written or oral notice to the petitioner
or that party's lawyer has been made to this court.
11
12
13
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 W P F DR 04.0150) as its
findings, except as follows:
14
15
16
IV. Order
It is Ordered:
4.1
Restraining Order
Violation of a Restraining Order in paragraph 4.1 with actual notice of its
terms is a criminal offense under Chapter 26.50 RCW and will subject the
violator to arrest. RCW 26.09.060.
17
18
19
20
21
Going onto the grounds of or entering the work place of the other party.
22
23
24
25
[]
Clerks Action. The clerk of the court shall forward a copy of this order, on or
before the next judicial day, to (name of the appropriate law enforcement
agency) SO U TH S O U N D 911 which shall enter this order into any computerbased criminal intelligence system available in this state used by law
enforcement agencies to list outstanding warrants. (A law enforcement
F A U B IO N , REEDER, FR A LE Y
& C O O K , P.S.
Lakewood, W A 98499
253-581-0660
25
1
2
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.
3
4
5
6
7
4.2
10
11
12
4.3
13
14
4.4
Expiration Date
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.
15
16
4.5
Waiver of Bond
17
18
4.6
IN COUNTY
Other
a m
19
20
Dated:
at
vt
23
. F E B 0 4 2015
pm
^rr^p.m.
21
22
CLERKS OFFICE
Judge/C
Presented by:
FAUBIOti-EEEDER, FRALEY & COOK, P.S.
Copy received:
A signature below is actual notice of
this
24
25
Petitioner
Pro se
'
F A U B IO N , REEDER, F R A L E Y
& C O O K , P.S.
5 920-1 0 0 th S tre e t S W , S te 25
Lakewood, W A 98499
253-581-0660
44076140
02-05-15
orcnt
! 4-3-01646-7
I N T H E S U P E R IO R C O U R T O F T H E S T A T E O F W A S H IN G T O N F O R P IE R C E C O U N T Y
no.
D o tt/O
k^R U l
j , fZ.
O R D E R RE: C O N T IN U A N C E T O
A P P L Y F O R C O U R T A P P O IN T E D
ATTO RNEY
R espondent/D efendant
ORCNT
T H IS M A T T E R having com e on regularly fo r hearing, and the C ourt having found th a t the
P etitioner/R espondent is a t substantial risk o f incarceration, it is now th erefore,
ORDERED,
th a t
ADJ
this
m a tte r
hereby
continued
to :
___________ , a t 0 9 : 0 0 AM
1:30 PM in
such Room as posted, Pierce C ounty C dlirthouse, C ounty-C ity Building, 930 Tacom a Avenue South,
Tacom a, WA
98402.
This m a tte r is continued to allow the P etitioner/R espondent to obtain
representation th ro u g h th e D epartm ent o f Assigned Counsel, b u t only in th e event the
Petitioner/R espondent financially qualifies fo r said representation. To a pp ly fo r legal representation
you m ust co nta ct the fo llo w in g o ffice w i t h i n 3 d a y s o r Y O U W IL L BE D E E M E D T O H A V E W A IV E D
Y O U R R IG H T T O C O U N S E L :
P r e t r ia l S e rv ic e s :
N O T IC E :
S E T F O R T H A B O V E I S M A N D A T O R Y A N D S H O U L D T H E P E T IT IO N E R /R E S P O N D E N T F A IL T O
A P P E A R , T H E C O U R T W I L L IS S U E A B E N C H W A R R A N T F O R H I S / H E R A P P R E H E N S IO N A N D
I C A N BE H E A R D .
C O N F IN E M E N T I N J A IL U N T IL S U C H T IM E A S T H E M A T T E R
_day o f
, 20.
c o u r t c o m m is s io n e r
ROBYN A LINDSAY
COURT COMMISSIONER
Respondent
C<%>
ORDER RE: CONTINUANCE TO APPLY FOR COURT APPOINTED ATTORNEY - Page 1 o f 1 (updated 0 1 /07 /1 5 )
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
JO H N A L IK A KALII JR
No. 14-3-01646-7
Petitioner(s),
N O TE FO R C O M M IS S IO N E R 'S C A LE N D A R
vs.
BETH A N N KALII
R espondent(s)
Phone:
Petitioner
P lease ta ke notice th a t an issue o f law in this case w ill be heard on the date and tim e show n below:
Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
Show Cause
Nature of Hearing:
C hild Support, C on te m p t
9:00 AM
DATED:
F ebruary 5, 2015.
Signed:
/s / D aniel N C ook
NAME:
D aniel N C ook
Phone:
(253) 581-0660
WSBA#:
For:
34866
ADDRESS:
A tto rn e y fo r R esp o nd e n t
1 of 1
E-FILED
IN COUNTY CLERK'S OFFICI
PIERCE COUNTY, W A S H IN G T
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-7
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JOHN A. KALII,
No. 14-3-01646-7
Petitioner,
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and
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BETH A. KALII,
Return of Service
(Optional Use)
(RTS)
Respondent.
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I Declare:
1.
lam over the age of 18 years, and I am not a party to this action.
2.
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3.
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Address:
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The date, time and place of service were (if by mail refer to Paragraph 4 below);
4.
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R e tu rn o f S e rv ic e (R T S ) - P a ge 1 o f 2
W P F D R P S C U 0 1 . 0 2 5 0 (07/2013) - C R 4(g), R C W 4.28.080(15)
S :\C A S E S l\K a lii\D R A F T S \P le a d in g s \R e tu r n o f S e r v ic e .d o c
F A U B IO N , REEDER,
F R A L E Y & C O O K , P.S.
5920 100th S treet SW, Suite 25
Lakew ood, W A 98499
Phone: (253) 581-0660
1
5.
2
Does not apply.
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6.
Other:
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5
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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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.
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o f S e r v ic e , d o c
F A U B IO N , R E E D E R ,
F R A L E Y & C O O K , P .S .
E-FILED
IN CO UNTY CLERK'S OFF
PIERCE COUNTY, WASHIN
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646-'
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No. 14-3-01646-7
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DECLARATION OF MAILING
Petitioner,
and
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I, Sally DuCharme, am over the age of 18, and competent to testify in the above
entitled case.
On February 9, 2015, I placed in the U.S. Mail a copy of the following
documents in the above-entitled caption:
1. Note for Commissioners Calendar on March 24, 2015
2. Order Re: Continuance to Apply for Court-Appointed Attorney.
Said documents were addressed to:
John Kalii
9711 Winona STSW
Lakewood WA 98498I
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
February 9, 2015
^
25
Declaration Of Mailing
Kalii, John and Kalii, Beth
S:\CASES1\Kalii\DRAFTS\Pieadings\Dedaration of Mailing.doc
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
NO: 14-3-01646-7
IN T H E S U P E R IO R C O U R T O F T H E STA TE O F W A S H IN G T O N
IN A N D F O R T H E C O U N T Y O F PIE R C E
IN RE
)
)
JOHN KALII, JR,
)
)
PETITIONER
CAUSE NO. 14 - 3 - 0 1646-7
)
vs
)
L IM IT E D N O T IC E O F
)
A
PPEARANCE
)
BETH ANN KALII,
C O N T E M PT H E A R IN G S
)
RESPONDENT
)
)
TO:
P IE R C E C O U N T Y S U P E R IO R C O U R T C L E R K
YOU AND EACH OF YOU will please take notice that ROSE EBERHART
herewith enters a lim ited notice of appearance for and on behalf of the Petitioner, JOHN
KALII, JR nam ed above, in connection w ith the contem pt show cause hearing and any
subsequent review hearings only. Please direct any further notices concerning the
above-referenced contem pt hearing, except for original process, to the attorney at the
address given below. All other notices related to this action should be directed to the
Petitioner at his address of record.
ROSE EBERHART, # 38 737
40 09 BRIDGEPORT WAY W, STE. E -1
UNIVERSITY PLACE, WA 98466
( 2 53 ) 686-980 2
DATED this 11 th day of FEBRUARY, 2 0 15 .
Respectfully submitted:
_______________ / / s / / ___________
JANENE GORE, WSBA #18918
Department of A ssigned Counsel
E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, W ASHING TO N
The case(s) listed above were previously assignedto Department 20 Judge K. A. VAN DOORNINCK. Judge
GRETCHEN LEANDERSON has assumedthis case. Unless otherwise notified, your trial date and case schedule, if set,
remain unchanged.
If the case is resolved, call Department 15 at (253) 798-3966 or e-mail to: [email protected]
If you are an attorney and have withdrawn fromthis case, contact the Clerk's office.
Frank E. Cuthbertson
Presiding Judge
rast-0007.pdf
E-FILED
IN CO UNTY CLERK'S C
PIERCE COUNTY, WASH
NO: 14-3-01646
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No. 14-3-01646-7
Amended Response to
Motion/Declaration for an
Order to Show Cause re
Contempt
Petitioner,
and
Beth Ann Kalii,
Respondent.
15
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I. Response
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1.1
[]
Admitted
[x]
Denied
[]
Lacks Information
24
1.2
Admitted
[X]
Denied
[]
Lacks Information
1.3
[]
Admitted
[X]
Denied
[]
Lacks Information
25
26
ROSE M. EBERHART
Response to Mot/Dec Ord Show Cause re Contempt - Page 1
WPF DRPSCU 05.0100 Mandatory (6/2008) - RCW26.09.160
ATTORNEYATLAW
4009Bridgeportwayw.steE-l
UniversityPlace,WA. 98466
(253)686-9802
Each allegation of the petition that is denied is denied for the following reasons (List separately):
1
2
1.1
1.2
1.3
4
5
6
7
8
that this recent effort by Mrs. Kalii to accuse me of contempt is in retaliation of me confronting her with
9
10
11
my concerns and issues about her drinking and driving her vehicle with our daughter, Ka'ena Kalii, on
board. This issue is what initiated our breakup in 2006 when Mrs. Kalii, while in her third trimester,
12
continued to drink and smoke throughout the entire pregnancy despite my objections. Other matters
13
concerning Ka'ena's hygiene, sleeping habits, and schoolwork while in her mother's care are also in
14
question when she is dropped off at my home during the school week.
15
Since March of 2014, Mrs. Kalii and I have primarily communicated through text message. If I
16
17
18
bullied her, she would be able to prove it. If you read through all the texts I have supplied, you will see
that Mrs. Kalii is constantly calling me names and being borderline verbally abusive to me.
19
Unfortunately our daughter broke the phone I had been using during that time. Mrs. Kalii is aware of
20
21
I believe I am not delinquent, but current on my child support payments from October 2014
22
23
24
25
through February 2015. Proof of this current support status is documented by the attached Acceptance
Agreement involving a trailer that I had purchased during our marriage. See Exhibit A. This transfer was
signed and notarized by both of us on October 9, 2014. Mrs. Kalii and I were in total agreement, with the
26
ROSE M. EBERHART
Response to Mot/Dec Ord Show Cause re Contempt - Page 2
WPF DRPSCU 05.0100 Mandatory (6/2008) - RCW26.09.160
ATTORNEYATLAW
4009Bridgeportwayw.STEE-l
UniversityPlace,WA. 98466
(253)686-9802
understanding that everything was legal and binding. She even brought the notary because she wanted it
1
binding.
2
3
4
In her declaration Mrs. Kalii states that in October or November that I told her that I would not
pay the court ordered child support. This is not true, as I have never stated that I would not pay child
support. I did contact Mrs. Kalii in the first week of October 2014 through phone text that I was
financially struggling to make ends meet. This is when the transfer of our community travel trailer was
brought up, by her. 1referenced this in a text I sent her on January 9, 2015, and she did not dispute that it
was that Mrs. Kalii would take possession of the trailer to be sold by her, as satisfaction of child support
10
11
payments through Februaiy, 2015. She gave me the ultimatum that it was to be just through February or
not at all. I agreed. Additionally, it was also a demand of Beth that an agreement letter be drawn up,
12
signed and notarized, along with the signing over of the transfer of title. She had the notary there at the
13
14
15
exchange. I signed both the agreement and the title. See Exhibits A and B. As for her claim that the
trailer was her separate party, please note that it was solely in my name. Also please note that she is well
16
aware that the trailer is community property and reference it as such. See Supplied Text messages pg 16.
17
Following the signing, Beth was very happy, voicing her satisfaction and informing me that she had
18
buyers for the trailer. She also expressed her gratitude to me for delivering it to her home. 1would guess
19
that she was expecting to receive more than the child support amount. A copy of the NADA guideline is
20
21
provided and outlines the current value of the travel trailer. See exhibit C. It is in very good condition,
inside and out. Only after her buyer back out and waiting for four (4) months in matters concerning the
22
payment of child support, it is now Mrs. Kalii's contention that I am in contempt for non-payment.
23
24
25
26
Please read the supplied text messages, they show Mrs. Kaliis intentions and her bad faith.
I do not receive $5,000 per month in income as Mrs. Kalii claims. Current and prior financial
disclosures show that for the last two (2) years, my service retirement income to be $4,028.91. See
ROSE M. EBERHART
Response to Mot/Dec Ord Show Cause re Contempt - Page 3
WPF DRPSCU 05.0100 Mandatory (6/2008) - RCW26.09.160
ATTORNEYATLAW
4009Bridgeportwayw.STEE-l
UniversityPlace,WA. 98466
(253)686-9802
Exhibit D. Mrs. Kalii and her attorney, Mr. Cook is well aware of this as they have both seen and signed
1
2
3
4
Mrs. Kalii also claims to receive a net income of $1,900 a month. According to her last signed
financial disclosures, her reported net income is $2,217.69. rent ($950), gas ($200) and utilities ($400)
are also subject to question and I would ask the court to have her provide three (3) months proof of
In matters concerning Mrs. Kalii's claim that I need to pay for my share of daycare: There is none
8
and has never been any daycare involving our daughter. I have, from day one (1) to present, personally
9
10
II
provided parental "daycare" for our daughter, Ka'ena. This is and has been inclusive to every week that
Ka'ena spends during her mother's week of care. Previously Mrs. Kalii had agreed to pay me $75 a month
12
to take care of our child during her residential time, since I am paying her child support. See Supplied
13
Text messages pg 4. I did say that she would need to pay someone else that money if she was not going
14
to follow through with our agreement. Id at 6. Her response is to threaten to go to HR about me and call
15
me evil. Id. She even states at one point that You made me mad 1 am honoring that agreement. Id. pg
16
17
10. I was unsure as to which agreement she was referencing, but its clear that she acts out at me in anger
against our childs best interest.
18
19
Historically, I have always been the primary caregiver while our family was together and even
20
more so now, during this ongoing divorce. I have always provided pre-school and after-school care for
21
Ka'ena, even during my career as a firefighter for the Tacoma Fire Dept. (1980-2013) because of my
22
23
24
1oday Ka'ena continues to spend the majority of her time with me, which includes care twice
25
a day, (every school day) amounting to thirty (30) hours a month that she is supposed to be in her
26
mother's care.
ROSE M. EBERHART
Response to Mot/Dec Ord Show Cause re Contempt - Page 4
WPF DRPSCU 05.0100 Mandatory (6/2008) - RCW26.09 160
ATTORNEYATLAW
4009BRIDGEPORTWAYWSTEE-1
UniversityPlace,WA. 98466
(253)686-9802
Lastly, as a final note, therewas no issue about child support payments for four (4) monthsuntil
Mrs. Kalii was confrontedabout recent concerns by me, about her drinking and driving habits involving
our daughter Ka'ena and other childrenin her vehicle.
I declare under penalty of perjury under the laws of the stateof Washington that the foregoing is
true and. correct
Date
John Kalii
RoseEberiiart/WSBA 38737
ATTORNEYATLAW
4009Bridgeportwayw.STE-1
UniversityPlace,WA. 98466
(253)686-9802
Exhibit A
ACCEPTANCE AGREEMENT
'
Child Support payments and that any remaining funds to be kept solely
by Beth Ann Kalii.
U
My Commission E ipira:____
el
|o / /
& * * * * *
Exhibit B
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1/24/2015
AUTOS
CLASSICCARS
RVS MANUFACTUREDHOMES
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$ 4 ,6 8 0
$85
$100
O ptions: (channel
110 Vot - 15,000 BTU (Roof Mount)
$60
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$420
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$240
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1/2
Exhibit D
STATE OF WASHINGTON
January 9, 2015
JOHN A. KALII
9711 WINONA ST SW
LAKEWOOD WA 98498
SSN: XXX-XX-5489
David Nelsen
Assistant Director
Customer & Policy Services
1/220015
Benefit Sunnmary
W A S H IN G T O N S TA TE D E P A R T M E N T O F R E T IR E M E N T S Y S T E M S
360-664-7000 |800-547-6657
B enefit Sum m ary
Help
This screen presents information as reported by you or your employer as of Thursday, January 22,2015. If
information displayed is incorrect, please see the instructions on how to m a k e changes.
Membership Details
Name:
Systeni/Plan:
Status:
John A Kalii
Law Enforcement Officers' and Firefighters' Retirement System Plan 2
Retired
Retirement Details
Download Pension Verification Letter
Date: 01/01/2013
.
Type: Service
: ..
Monthly Payment
11/28/2014
12/31/2014
Gross Benefit
_
_____
$4,405.47 ___
$4,405.47
IRS Withholding ( R a t e B e l o w ) : w w : U . i L - W ' a u n i> iM .............................................i
-331.43
imr
>s 1
1. n i. r i- n ! . -331.43
- iv
m
m
im
n
____________________Net Benefit Amount:_________________ $4,074.04__________________$4,074.04
IRS Withholding Rate: Married - 3 Allowances established 01/2013
Payment Delivery Method: Electronic Funds Transfer (EFT) to Harborstone Cu effective 12/2012.
Paper Benefit Statement Delivery: If Change Is Made Aid End Of Year_________________________________
mi
B eneficiary
https^/fartress.'Aa(|oVdrs/drsorlinesso/Merrtr/BenEfitSumnaryl1
1/1
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In re
John Kalii Jr.
Petitioner
V.
No. 14-3-01646-7
Declaration re: Electronic
Signature Page
21
22
23
1. My name is Rose Eberhart. I am the attorney for the above named Petitioner. I
24
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make this affidavit concerning the electronic signature of John Kalii, my client, on a document
26
m9 bA
J twlvwT tee-i
UniversityPlace,WA. 98466
(253)686-9802
1
2
fax machine at (253 ) 507 5766 [x] via my e-mail at [email protected]. The entire
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ROSE M. EBERHART
Declaration re: Electronic Signature Page - Page 2
ATTORNEYATLAW
4009Bridgeportwayw.STEE-l
UniversityPlace,WA. 98466
(253)686-9802
E-FILED
IN COUNTY CLERK'S C
PIERCE COUNTY, WASH
March 03 2015 2:15
KEVIN STOCK
COUNTY CLERK
NO: 14-3-01646
2
3
4
5
6
7
10
And
Beth Ann Kalii
No. 14-3-01646-7
Cover Sheet: Supplied Text
Messages
Respondent.
11
12
13
14
15
16
Messages from Beth Ann Kalii are aligned to the left and are
lightly shaded.
17
20
DATED:
21
22
Cover Sheet:
ROSE M. EBERHART
ATTORNEYATLAW
4009Bridgeportwayw.STEE-l
UniversityPlace,WA. 98466
(253)686-9802
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aaa Beth
::
. ..
iPSH i
11mm%isiw:m m m is
i
t
!(
m B
No you will get half of the
value of the trailer off but
no one wants to buy it1
have been trying itto old
Itold m y lawer ifanything
happens to m y property
you look at T a m m y Ihave
proof and an eye
witness..
mM
**o o o Sprint ^
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3:54 PM
aaa
B e th
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3:54 PM
aaa Beth
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*oo Sprint
3:55 PM
O'
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* 0 0 Sprint -=?
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3:55 PM
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B e th
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3:55 PM
aaa
B e th
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3:55 PM
aaa
B e th
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3:56 PM
aaa Beth
Kaena..
Iwould like to know why
she wasn't in school
please and would like to
talk to her thanks
Iwould not do this to you I
deserve to know what's
wrong with her
53%
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3:56 PM
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B e th
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3:56 PM
aaa Beth
6:00 tomorrow
please....thank you
t 63% * ;:>
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3:56 PM
aaa Beth
O $ 53%
WD
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3:57 PM
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aaa Beth
* 'I I 1:5
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3:57 PM
aaa Beth
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3:57 PM
aaa
B e th
LEAVE M E ALONE.,,
No No that's you...
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3:57 PM
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aaa Beth
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B e th
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M essages
3:58 PM
aaa
B e th
N O N O IHAVE NEVER
GIVEN H E R COFFEE. ..!!!
Call her
D ln n c o R o / i f l t 5 r
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3:58 PM
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B e th
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3:59 PM
aaa Beth
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IM .IIM M *
I did not give her coffee
but have permission to
give it to one of my friends
child
i Send
o o Sprint
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3:69 PM
aaa
B e th
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