Jennifer Kay Shipman vs. Jason William Shipman

E-FILED
IN COUNTY CLERK'S OFFICE

PIERCE COUNTY, WASHINGTON
March 15 2010 3:07 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY

CASE COVER SHEET / DOMESTIC & PROBATE CASES
JENNIFER KAY SHIPMAN VS. JASON
Case Title W_TTI AA1 STTTP1M1ANT______________
Case Number 10-3 -096 1-1__________
Atty/Litigant_____________________________
Bar # 28960
Phone (253) 770-0808
Address 4115 S. MERIDIAN, SUITE B_______

City PUYALLUP
State WA
Zip 98 373
Please check one category that best describes this case for indexing purposes.
I f you cannot determine the appropriate category, please describe the cause o f action below. This will create a
Miscellaneous cause which is not subject to PCLR1, and does not require a Track Assignment Request Form.
DOMESTIC RELATIONS
ADOPTION / PATERNITY
DISSOLUTION
_f__ Of Marriage with Child (DIC 3) FAM LAW
___ Of Marriage without Child (DIN 3) FAM LAW
___ Of Domestic Partnrshp w Child (DPC 3)FAM LAW
___ Of Domestic Prtnrshp w/o Child (DPN3)FAM LAW
LEGAL SEPARATION
___ Of Marriage with Children (LSC 3) FAM LAW
___ Of Marriage without Children (LsN 3)FAM LAW
___ Of Domestic Partnership w Child (SPDC 3)FAM LAW
___ Of Domestic Prtnrshp w/o Child (SPD 3)FAM LAW
Adoption (ADP 5) Non PCLR

Confidential Intermediary (MSC 5) REV 4
Paternity (PAT 5) REV 9
URESA / UIFSA (PUR 5) REV 9
Relinquishment (REL 5) Non PCLR
Terminate of Parent-Child Relation (TER 5) Non PCLR
Vulnerable Adult Petition (VAP 5) Non PCLR
Misc (MSC 5) REV 4
____Invalidity (INV 3) FAM LAW

___ Invalidity Domestic Partnership (INP 3) FAM LAW
___ Child Custody (CUS 3) CUSTODY
___ Parenting Plan / Child Support (PPS 3) FAM LAW
Absentee (ABS 4) REV 4

Disclaimer (DSC 4) Non PCLR
Estate (EST 4) RE 12
Foreign Will (FNW 4) RE 12
Guardianship (GDN 4) REV 4
Limited Guardianship (LGD 4) REV 4
Minor Settlement with Guardianship (MST 4) REV 4
Non-Probate Notice to Creditors (NNC 4) Non PCLR
Will Only (WLL 4) Non PCLR
Misc (MSC 4) REV 4
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
Mandatory Wage Assignment (MSC 3) Non PCLR
Out of State Custody (MSC 3) Non PCLR
MISCELLANEOUS
PROBATE / GUARDIANSHIP
E-FILED
March 15 2010 3:08 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR PIERCE COUNTY
JENNIFER KAY SHIPMAN
No. 10-3-00961-1
Petitioner(s)
ORDER ASSIGNING CASE TO DEPARTMENT
vs.
JASON WILLIAM SHIPMAN

Respondent(s)
In accordance with PCLR 40(b), this case is hereby assigned to Department 12, Judge STEPHANIE A. AREND.
Notice to Petitioner:
Once the case has been filed, the petitioner shall serve a copy of this Order Assigning Case to Department on the
respondent with the summons and petition. Provided, however, that in those cases where service is by
publication the petitioner shall serve a copy of this Order Assigning Case to Department within five (5) court days
of service of the respondent's first response/appearance. If the case has not been filed, but an initial pleading is
served, a copy of this Order Assigning Case to Department shall be served within five (5) court days of filing.
PCLR 1(b).
Trial Date:
A trial date may be obtained pursuant to PCLR 40(d) by filing a 'Note of Issue' for assignment of a trial date by
noon at least six (6) court days prior to the date fixed for assignment of the trial date. PCLR 40(d)
If a trial date is not obtained pursuant to PCLR 40(d), failure to appear on this date will result in dismissal of
the case by the Court. PCLR 40(d)
Assignment to Set Trial Date
Friday, July 16, 2010 9:00 AM
At that time the Court will provide you with a Case Schedule which shall include the trial date. Failure to
appear on this date will result in dismissal of the case by the Court. PCLR 40(d).
Certificate of Completion of Mandatory Parenting Seminar due from both parties by 05/17/2010. See
PCLSPR 94.05(c) & (4)(i). http:\\wwwxo.pierce.wa.us\pc\services\lawjust\parentingseminars.htm
Uncontested Dissolutions/Settlements:
If this case is agreed upon by both petitioner and respondent, you are not required to wait for the trial date in
order to settle your case. If you settle your case and the appropriate time requirements have been met, you may
file a Note for Commissioner's Calendar' to appear before a Court Commissioner for entry of final papers.
DATED: March 15, 2010

Judge STEPHANIE A. AREND
Department 12
astsup-0003.pdf
E-FILE
IN COUNTY CLEI
PIERCE COUNTY
March 15 201(
KEVIN ST
COUNTY C
NO: 10-3-C
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Superior Court of Washington

County of Pierce
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In re the Marriage of:
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No.
Petitioner,
and
Petition for Dissolution

of Marriage
(PTDSS)
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Respondent.
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I. Basis
1.1
Identification of Petitioner
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Name: Jennifer Shipman,
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Last known residence Pierce County, WA
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.2
Birth date February 16, 1974
Identification of Respondent
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Name: Jason Shipman,
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Last known residence Pierce County, WA
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.3
Birth date August 20, 1972
Children of the Marriage Dependent Upon Either or Both Spouses
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The husband and wife are both the parents of the following dependent children:
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Name: TS
Age 15
'ETITION FOR DISSOLUTION

)F MARRIAGE
and
Name: HS
Age 8
LA W OFFICES OF GREENE & LLOYD, PLLC

Street Address: 4115 S. Meridian
Mailing Address: P.O, Box 731063
Puyallup, Washington 98373
(253) 770-0808, Fax (253) 770-0259
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This marriage isirretrievably broken.

1.5
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Date and Place of Marriage

Tire parties were married on April 24, 1994 in North Bend, WA.
1.6
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Allegation Regarding Marriage
Separation
Husband and wife separated on February 27, 2010.
1.7
Jurisdiction
This court has jurisdiction over the marriage.
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This court has jurisdiction over the respondent because:
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The respondent is presently residing in Washington.
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Tire petitioner and respondent lived in Washington during their marriage

and the petitioner continues to reside in this state.
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The petitioner and respondent may have conceived a child while within
Washington.
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1.8
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Property
There is community or separate property owned by the parties. The court should make a
fair and equitable division of all the property.
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The division of property should be determined by the court at a later date.
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1.9
Debts and Liabilities
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The parties have debts and liabilities. The court should make a fair and equitable
division of all debts and liabilities.
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The division of debts and liabilities should be determined by the court at a

later date.
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Each party shall pay their debts incurred since separation.

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/
//
PETITION FOR DISSOLUTION
OF MARRIAGE
2 of 6

Mailing Address: P.O. Box 731063
(253) 770-0808, Fax (253) 770-0259
1.10
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Spousal maintenance should not be ordered.

1.11
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Continuing Restraining Order

Does not apply
1.12
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Spousal Maintenance
Protection Order
Does not apply
1.13
Pregnancy
The wife is not pregnant.
Note: Under RCW 26.26.116. the husband is the presumed father. If

husband or wife believes the husband is not the father, this presumption may
be challenged up to two years after the birth of the child or as otherwise
provided in RCW 26.26.500 through 26.26.625.
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1.14
Jurisdiction Over the Children
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This court has jurisdiction over the children for the reasons set forth below.
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This state is the home state of the children because:
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the children lived in Washington with a parent or a person acting as a
parent for at least six consecutive months immediately preceding the
commencement of this proceeding.
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any absences from Washington have been only temporary.

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The children and the parents or the children and at least one parent or person
acting as a parent, have significant connection with the state other than mere
physical presence; and substantial evidence is available in this state concerning
the children's care, protection, training and personal relationships; and
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1.15
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Child Support and Parenting Plan for Dependent Children

Support for the dependent children listed below, should be set pursuant to the
Washington State Child Support Schedule.
/
//
OF MARRIAGE
3 of 6

(253) 770-0808, Fax (253) 770-0259
Name of
Child
Mother's
Name
Father's
Name
Jennifer Shipman
Jennifer Shipman
Jason Shipman
Jason Shipman
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TS
HS
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4
The petitioner's proposed parenting plan for the children listed above:
is attached and is incorporated by reference as part of this Petition.
(The following information is required only for the children who are included in the
petitioner's proposed parenting plan.)
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During the last five years, the children have lived:
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in no place other than the State of Washington and with no person other than the
petitioner or the respondent.
Claims to custody or visitation:
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The petitioner does not know of any person other than the respondent who has
physical custody of, or claims to have custody or visitation rights to, the children.
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Involvement in any other proceeding concerning the children:

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The petitioner has not been involved in any other proceeding regarding the
children.
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Other legal proceedings concerning the children:
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The petitioner does not know of any other legal proceedings concerning the
children.
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1.16
Other
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There are no other provisions
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II. Relief Requested
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The petitioner Requests the Court to enter a decree of dissolution and to grant the relief below.
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Approve the petitioner's proposed parenting plan for the dependent children listed
in paragraph 1.14.
OF MARRIAGE
4 of 6
u . W OFFICES OF GREENE & LLOYD, PLLC

(253) 770-0808, Fax (253) 770-0259
Determine support for the dependent children listed in paragraph 1.14 pursuant to
the Washington State Child Support Schedule.
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Change name of wife to: Jennifer Kay Lund.
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Order payment of day care expenses for the children listed in paragraph 1.14.
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Order payment of Vi of attorney fees, other professional fees and costs
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J j v i s i o n o f p r o p i f v f j } d t i f f e tb v j. iicJb'i ( ik lS
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Dated this 10th Day of March 2010
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arfothy M] Greene, WSBA #17499

SomeylofePentioner
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I declare under penalty of perjury under the laws of the State of Washington that the foregoing is
true and correct.
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Signed at Puyallup, WA on March 10, 2010

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OF MARRIAGE
5 of 6
u . W OFFICES OF GREENE & LLOYD, PLLC

(253) 770-0808, Fax (253) 770-0259
Joinder
I, Jason William Shipman, join in the petition. I understand that by joining in the petition, a
decree or judgment and order may be entered in accordance with the relief requested in the
petition, unless prior to the entry of the decree or judgment and order a response is filed and
served.
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[ ] I waive notice of entry of the decree.
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[ ] I demand notice of all further proceedings in this matter. Further notice should be
sent to the following address [You may list an address that is not your residential address
where you agree to accept legal documents]:
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Any time this address changes while this action is pending, you must notify the
opposing parties in writing and file an updated Confidential Information Form
(WPF DRPSCU 09.0200) with the court clerk.
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Dated:______________________
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______________________
Jason Shipman, Respondent
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OF MARRIAGE
6 of 6
W OFFICES OF GREENE & LLOYD, PLLC

(253) 770-0808, Fax (253) 770-0259
E-FILE
IN COUNTY CLEI
PIERCE COUNTY,
March 15 201(
KEVIN S'
COUNTY C
NO: 10-3-C
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County of Pierce
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Petitioner,
and
No.
Summons
(SM)
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Respondent.
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To the Respondent: JASON WILLIAM SHIPMAN
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1.
The petitioner has started an action in the above court requesting that your marriage be
dissolved.
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Additional requests, if any, are stated in the petition, a copy of which is attached to this
summons.
2.
You must respond to this summons and petition by serving a copy of your written
response on the person signing this summons and by filing the original with the clerk of the
court. If you do not serve your written response within 20 days (or 60 days if you are served
outside of the State of Washington) after the date this summons was served on you, exclusive of
the day of service, the court may enter an order of default against you, and the court may, without
further notice to you, enter a decree and approve or provide for the relief requested in the
petition. In the case of a dissolution of marriage, the court will not enter the final decree until at
least 90 days after filing and service. If you serve a notice of appearance on the undersigned
person, you are entitled to notice before an order of default or a decree may be entered.
3.
Your written response to the summons and petition must be on form WPF DR 01.0300,
Response to Petition (Domestic Relations). This form may be obtained by contacting the clerk of
Summons
1 of 2
LAW OFFICES OF GREENE c LLOYD, PLLC

(253) 770-0808, Fax (253) 770-0259
the court at the address below, by contacting the Administrative Office of the Courts at (360)
705-5328, or from the Internet at the Washington State Courts Homepage:
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http ://www.courts.wa.gov/forms
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4.
If this action has not been filed with the court, you may demand that the petitioner file
this action with the court. If you do so, the demand must be in writing and must be served upon
the person signing this summons. Within 14 days after you serve the demand, the petitioner must
file this action with the court, or the service on you of this summons and petition will be void.
5.
If you wish to seek the advice of an attorney in this matter, you should do so promptly so
that your written response, if any, may be served on time.
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6.
One method of serving a copy of your response on the petitioner is to send it by certified
mail with return receipt requested.
This summons is issued pursuant to Superior Court Civil Rule 4.1 of the state of Washington.
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DATED THIS 10,h day of March 2010

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thy M. fjfeene, WSBA# 17499

Attorney' fo/P eti ti oner
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File original o f your response with

the clerk of the court at:
Clerk of the Court
Pierce County Superior Court
930 Tacoma Avenue South
Room 110
Tacoma WA 98402
Serve a copy o f your response on:

Petitioner's Lawyer:
Timothy M. Greene
Law Offices of Greene & Lloyd, PLLC
P.O.Box 731063
4115 So. Meridian E.
Puyallup, WA. 98373
253-770-0808, (fax) 253-770-0259
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Summons
2 of 2
LAW OFFICES OF GREENE & LLOYD, PLLC

(253) 770-0808, Fax (253) 770-0259
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
March 15 2010
KEVIN STO
COUNTY CL
NO: 10-3-0)
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County of Pierce
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In re: the marriage of:
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No.
Petitioner,
Financial Declaration
[X] Petitioner
(FNDCLR)
And
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Respondent.
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Name: Jennifer Kav Shipman
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I. Summary of Basic Information

Declarant's Total Monthly Net Income tfrom 5 3.3 below)
Declarant's Total Monthly Household Expenses tfrom 5.9
Declarant's Total Monthly Debt Expenses tfrom 5.11 below)
Declarant's Total Monthly Expenses tfrom 5 5.12 below)
Estimate of the other party's gross monthly income (from 3.1g
below)
II. Personal Information
2.1 Occupation: Registered Nurse
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Date of Birth: February 16.1974

S4.285.14
S4.228.96
$522.00
$4,750.96
[X]
$4,855.00
[ ]
Unknown
2.2
The highest year of education completed: 14
2.3
Are you presently employed?

Yes
a. If yes: (1) Where do you work. Employer's name and address must be listed
on the Confidential Information Form.
(2) When did you start work there? (month/year) 8 / 2008
b. If no: (1) When did you last work? (month/year) n/a
(2) What were your gross monthly earnings?
(3) Why are you presently unemployed?
n/a
1 of 5

Mailing Address: P.O, Box 731063
Puyallup, Washington 983 73
(253) 770-0808, Fax (253) 770-0259
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III. Income Information

If child support is at issue, complete the Washington State Child Support Worksheet(s),
skip Paragraphs 3.1 and 3.2. If maintenance, fees, costs or debts are at issue and child
support is Not an issue this entire section should be completed. (Estimate of other party's
income information is optional.)
3.1 Gross Monthly Income
If you are paid on a weekly basis, multiply your weekly gross pay by 4.3 to determine
your monthly wages and salaries. If you are paid every two weeks, multiply your gross
pay by 2.15. If you are paid twice monthly, multiply your gross pay by 2. If you are paid
once a month, list that amount below.
Jennifer Shipman Jason Shipman
a. Imputed Income
$4,855.00
b. Wages and Salaries
$5,957.50
c. Interest and Dividend Income
d. Business Income
e. Spousal Maintenance Received From
f.
Other Income
g. Total Gross Monthly Income
$5,957.50
$4,855.00
(add lines 3.1a through 3.1e)
h. Actual Gross Income (Year-to-date)
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3.2
Monthly Deductions From Gross Income
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h.
a. Income Taxes
b. FICA/Self-employment Taxes
c. State Industrial Insurance Deductions
d. Mandatory Union/Professional Dues
e. Pension Plan Payments
f.
Spousal Maintenance Paid
g. Normal Business Expenses
Total Deductions from Gross Income
(add lines 3.2a through 3.2g)
Jennifer Shipman
$1,185.50
$446.80
Jason Shipman
$812.55
$371.41
$40.06
$62.06
$1,672.36
$1,246.02
$4,285.14
$3,608.98
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3.3 Monthly Net Income (Line 3.1f minus line

3.2h
3.4 Miscellaneous Income
a. Child support received from other relationships
b. Other miscellaneous income
(list source and amounts)
Income of current spouse
Income of children
Income from assistance programs
Non-recurring income
Other Income:
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(253) 770-0808, Fax (253) 770-0259
c. Total Miscellaneous Income

(add lines 3.4a through 3.4b)
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3.5
Income of Other Adults in Household
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3.6 If the income of either party is disputed, state monthly income you believe is
correct and explain below:
Husband income of 4,855.00 based on 2009 Joint income tax return
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IV. Available Assets
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4.1
4.2
4.3
4.4
Cash on hand
On deposit in banks
Stocks and bonds
Cash value of life insurance
Other liauid assets:
$20.00
$1,530.00
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V. Monthly Expense Information

Monthly expenses for me and 2 dependents are: (Expenses should be calculated for the
future, after separation, based on the anticipated residential schedule for the children.)
5.1 Housing
Rent, 1st mortgage or contract payments
Installment payments for other mortgages or
encumbrances
Taxes & insurance (if not in monthly payment)
Total Housing
$1,670.69
$1,670.69
5.2 Utilities
Heat (gas & oil)
Electricity
Water, sewer, garbage
Telephone
Cable
Other: internet
Total Utilities
$100.00
$100.00
$90.00
$230.00
$85.00
$48.00
$653.00
5.3 Food and Supplies

Food for persons
Supplies (paper, tobacco, pets)
Meals eaten out
Other:
Total Food Supplies
$700.00
5.4 Children
Day Care/Babysitting
150.00
$400.00
$50.00
$250.00
3 of 5
la

(253) 770-0808, Fax (253) 770-0259
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Clothing
Tuition (if any)
Other child-related expenses
Total Expenses Children
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5.5 Transportation
Vehicle payments or leases
Vehicle insurance & license
Vehicle gas, oil, ordinary maintenance
Parking
Other transportation expenses
Total Transportation
$356.55
$75.67
$225.00
$657.22
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5.6 Health care (Omit if fully covered)

Insurance
Uninsured dental, orthodontic, medical, eye
care expenses
Other uninsured health expenses
Total Health Care
5.7 Personal Expenses (Not including children)
Clothing
Hair care/personal care expenses
Clubs and recreation
Education
Books, newspapers, magazines, photos
Gifts
Other:
Total Personal Expenses
$40.00
$100.00
$65.00
$10.00
$150.00
$365.00
5.8 Miscellaneous Expenses

Life insurance (if not deducted from income)
Other: ID Guard
Other:
Total Miscellaneous Expenses
5.9
$175.55
$7.50
$183.05
Total Household Expenses (The total of Paragraphs 5.1 through 5.8)
$4,228.96
5.10 Installment Debts Included in Paragraphs 5.1 Through 5.8

Creditor/Description of Debt Balance
Month of Last Payment
none
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(253) 770-0808, Fax (253) 770-0259
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5.11 Other Debts and Monthly Expenses not Included in Paragraphs 5.1 - 5.8
Creditor/Descrintion of
Balance
Month of Last
Amount of
Debt
Payment
Monthly Pa
Alaska Credit Union /
$20,000.00
$356.00
April, 2010
auto loan
Red Canoe Bank
$3,000.00
April, 2010
$90.00
Sallie Mae / student loans
$8,000.00
January, 2010
$76.00
Total Monthly Payments for Other Debts and Monthly
Expenses
$522.00
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5.12
Total Expenses (Add Paragraphs 5.9 and 5.11)
$4,750.96
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VI. Attorney Fees
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6.1
Amount paid for attorney fees and costs to date:
6.2
The source of this money was: Loan from Red Canoe Bank
6.3
Fees and costs incurred to date:
6.4
Arrangements for attorney fees and costs are:
$1,780.00
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$1,780.00
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6.5
Other:
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I declare under penalty of perjury under the laws of the state of Washington that the
foregoing is true and correct.
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Signed at Puyallup, Washington on March 9, 2010
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(
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jk m
Jennifer Kay Shipman

Signature of Declarant
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The following financial records are being provided to the other party and filed separately
with the court.
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Financial records pertaining to myself:
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Joint Tax returns for 2009

Pay stubs for the dates of Feb 20, 2010.
5 of 5
law
OFFICES OF GREENE & LLOYD, PLLC

(253) 770-0808, Fax (253) 770-0259
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, '
March 15 201C
mam
KEVIN ST
COUNTY C
NO: 10-3-0
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4
5
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County Pierce
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Petitioner,
and
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No.
Parenting Plan
[XX] Proposed (PPP)
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Respondent._____________________________
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This parenting plan is proposed by Petitioner Jennifer K. Shipman.
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It Is Ordered, Adjudged and Decreed:
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I. General Information
This parenting plan applies to the following children:
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Name Age
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TS
HS
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8
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II. Basis for Restrictions
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Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contact with the children and the right to make decisions for the children.
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PARENTING PLAN
PROPOSED (PPP)
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LA WOFFICES OF GREENE < LLOYD, PLLC

(253) 770-0808, Fax (253) 770-0259
2.1
Parental Conduct (RCW 26.09.191(1), (2))

Does not apply
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2.2
Other Factors (RCW 26.09.191(3))

Does not apply
III. Residential Schedule
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The residential schedule must set forth where the children shall reside each day o f the year,
including provisions for holidays, birthdays o f family members, vacations, and other special
occasions, and what contact the children shall have with each parent. Parents are encouraged
to create a residential schedule that meets the developmental needs o f the children and
individual needs o f their family. Paragraphs 3.1 through 3.9 are one way to write your
residential schedule. I f you do not use these paragraphs, write in your own schedule in
Paragraph 3.13.
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3.1
Schedule for Children Under School Age
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There are no children under school age.
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3.2
School Schedule
Upon enrollment in school, the children shall reside with the mother, except for the
following days and times when the children will reside with or be with the other parent:
From:
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3.3
Friday 7 pm
to
Sunday 7 pm
every other week
Schedule for Winter Vacation
15
16
The children shall reside with the mother during winter vacation, except for the
the winter vacation shall be split equally between the parents.
17
18
3.4
same as 3.3 above
19
20
21
22
Schedule for Other School Breaks
3.5
Summer Schedule
Upon completion of the school year, the children shall reside with the mother, except for
the following days and times when the children will reside with or be with the other parent:
Same as school year schedule.
PARENTING PLAN
PROPOSED (PPP)

(253) 770-0808, Fax (253) 770-0259
3.6
Vacation With Parents

each parent shall be entitled to spend two consecutive weeks vacation time with the
children each year, schedule with the other parent, in writing, by the first day of March.
2
3
3.7
Schedule for Holidays
4
The residential schedule for the children for the holidays listed below is as follows:
5
With Mother
(Specify Year
Odd/Even/Every)
6
7
New Year's Day

Presidents' Day
Easter
Memorial Day
July 4th
Labor Day
Thanksgiving Day
Christmas Eve
Christmas Day
New Years Eve
8
9
10
11
12
Holidays which fall on a Friday or a Monday shall include Saturday and Sunday.
14
[ ]
15
17
18
EVEN
EVEN
EVEN
ODD
EVEN
ODD
EVEN
EVEN
ODD
ODD
For purposes of this parenting plan, a holiday shall begin at 8 a.m. and end at 10 p.m.
13
16
ODD
ODD
ODD
EVEN
ODD
EVEN
ODD
ODD
EVEN
EVEN
With Father
(Specify Year
Odd/Even/Every)
3.8
Other:
Schedule for Special Occasions
The residential schedule for the children for the following special occasions (for example,
birthdays) is as follows:
With Mother
With Father
(Specify Year
(Specify Year
Odd/Even/Every)
Odd/Even/Every)
19
20
21
22
Mother's Day
Mother Birthday
Father's Day
Fathers Birthday
TSs Birthday
HSs Birthday
PARENTING PLAN
PROPOSED (PPP)
EVERY
EVERY
NEVER
NEVER
EVEN
EVEN
NEVER
NEVER
EVERY
EVERY
ODD
ODD

(253) 770-0808, Fax (253) 770-0259
3.9
If the residential schedule, paragraphs 3.1 - 3.8, results in a conflict where the children are
scheduled to be with both parents at the same time, the conflict shall be resolved by priority
being given as follows:
Priorities Under the Residential Schedule
Rank the order of priority, with 1 being given the highest priority:
1
2
3
4
5
6
7
6
7
8
9
3.10
school schedule (3.1,3.2)

winter vacation (3.3)
school break(s) (3.4)
summer schedule (3.5)
vacation with parents (3.6)
holidays (3.7)
special occasions (3.8)
Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2
10
11
3.11
Transportation Arrangements
12
Transportation costs are included in the Child Support Worksheets and/or the Order of
Child Support and should not be included here.
13
Transportation arrangements for the children between parents shall be as follows:
the receiving parent shall provide the transportation to the exchange point
14
15
3.12
Designation of Custodian
16
18
The children named in this parenting plan are scheduled to reside the majority of the time
with the mother. This parent is designated the custodian of the children solely for purposes of
all other state and federal statutes which require a designation or determination of custody. This
designation shall not affect either parents rights and responsibilities under this parenting plan.
19
3.13
17
20
21
22
Other
there are no other provision
3.14
Summary of RCW 26.09.430 - .480, Regarding Relocation of a Child

This is a summary only. For the full text, please see RCW 26.09.430 through 26.09.480.
PARENTING PLAN
PROPOSED (PPP)

(253) 770-0808, Fax (253) 770-0259
If the person with whom the child resides a majority of the time plans to move, that
person shall give notice to every person entitled to court ordered time with the child.
2
3
4
5
6
7
8
If the move is outside the child's school district, the relocating person must give notice by
personal service or by mail requiring a return receipt. This notice must be at least 60 days before
the intended move. If the relocating person could not have known about the move in time to give
60 days' notice, that person must give notice within 5 days after learning of the move. The notice
must contain the information required in RCW 26.09.440. See also form DRPSCU 07.0500,
(Notice of Intended Relocation of A Child).
If the move is within the same school district, the relocating person must provide actual
notice by any reasonable means. A person entitled to time with the child may not object to the
move but may ask for modification under RCW 26.09.260.
Notice may be delayed for 21 days if the relocating person is entering a domestic violence
shelter or is moving to avoid a clear, immediate and unreasonable risk to health and safety.
9
10
11
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.
12
Failure to give the required notice may be grounds for sanctions, including contempt.
13
14
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.
15
16
17
18
19
A person entitled to time with a child under a court order can file an objection to the
child's relocation whether or not he or she received proper notice.
An objection may be filed by using the mandatory pattern form WPF DRPSCU 07.0700,
(Objection to Relocation/Petition for Modification of Custody Decree/Parenting Plan/Residential
Schedule). The objection must be served on all persons entitled to time with the child.
The relocating person shall not move the child during the time for objection unless: (a)
the delayed notice provisions apply; or (b) a court order allows the move.
20
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
PARENTING PLAN
PROPOSED (PPP)

(253) 770-0808, Fax (253) 770-0259
IV. Decision Making
4.1
Each parent shall make decisions regarding tire day-to-day care and control of each child
while the children are residing with that parent. Regardless of the allocation of decision making
in this parenting plan, either parent may make emergency decisions affecting the health or safety
of the children.
Day-to-Day Decisions
5
4.2
Major Decisions
6
Major decisions regarding each child shall be made as follows:
7
[ ] mother
[ ] father
[XX] joint
Non-emergency health care: [ ] mother
[ ] father
[XX] joint
Religious upbringing:
[ ] father
[XX] joint
Education decisions:
8
9
[ ] mother
10
4.3
Restrictions in Decision Making
11
Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2 above
12
V. Dispute Resolution
13
The purpose o f this dispute resolution process is to resolve disagreements about carrying out this
14
15
16
17
parenting plan. This dispute resolution process may, and under some local court rules or the
provisions o f this plan must, be used before filing a petition to modify the plan or a motion for
contempt for failing to follow the plan.
Disputes between the parties, other than child support disputes, shall be submitted to
mediation by Pierce County Center for Dispute Resolution
18
The cost of this process shall be allocated between the parties as follows:
19
As determined in the dispute resolution process.
20
21
22
The dispute resolution process shall be commenced by notifying the other party by
written request via certified mail, return receipt.
In the dispute resolution process:
PARENTING PLAN
PROPOSED (PPP)

(253) 770-0808, Fax (253) 770-0259
(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.
4
5
(c)
mediation and of each arbitration award and shall be provided to each party.
6
7
A written record shall be prepared of any agreement reached in counseling or
(d)
If the court finds that a parent has used or frustrated the dispute resolution process
without good reason, the court shall award attorneys' fees and financial sanctions to the other
parent.
8
9
(e)
The parties have the right of review from the dispute resolution process to the
superior court.
10
VI. Other Provisions
11
There are no other provisions.
12
VII. Declaration for Proposed Parenting Plan
13
14
declare under penalty of peijury under the laws of the State of Washington that this plan
has been proposed in good faith and that the statements in Part II of this Plan are true and correct.
15
16
17
Date this 10th day of March 2010 at Puyallup, WA.

( J P A Iu lL A s d h lp M A L '
.Jennifer Shipman, Mother/Peti
Mother/Petitioner
18
19
20
21
22
VIII. Order by the Court

IT IS ORDERED, ADJUDGED AND DECREED that the parenting plan set forth above is
adopted and approved as an order of this court.
WARNING: Violation of residential provisions of this order with actual knowledge of its terms
is punishable by contempt of court and may be a criminal offense under RCW 9A.40.060(2) or
PARENTING PLAN
PROPOSED (PPP)
7 OF 8

(253) 770-0808, Fax (253) 770-0259
2
3
4
5
9A.40.070(2). Violation of this order may subject a violator to arrest.

When mutual decision making is designated but cannot be achieved, the parties shall make a
good faith effort to resolve the issue through the dispute resolution process.
If a parent fails to comply with a provision of this plan, the other parents obligations under the
plan are not affected.
6
7
Date this____ day o f____________ 2010

Judge/Commissioner
8
9
10
Presented by: Approved for entry:
11
12
Jason Shipman
Signature of Party
13
14
15
16
17
18
19
20
21
22
PARENTING PLAN
PROPOSED (PPP)

(253) 770-0808, Fax (253) 770-0259
E-FILED
March 15 2010 3:08 PM
COUNTY CLERK
NO: 10-3-00961-1
Washington State Child Support Schedule Worksheets

[XX] Proposed by Mother, Jennifer Shipman [ ] State of WA [ ] Other
] Signed by the Judicial/Reviewtng Officer. (CSW)
Mother Jennifer Kay Shipman
County of Pierce
, (CSWP) Or, [
Father Jason William Shipman

Case No. ____
Child Support Order Summary Report
This section must be completed for all Worksheets signed by the

__________________ judicial/reviewing officer.
A. The order does not replace a prior court or administrative order.
B. The Standard Calculation listed on line 17 of the Worksheet for the paying
parent is: $891.
C. The Transfer Amount ordered by the Court from the Order of Child Support
is: $891 to be paid the father
D. The Court deviated (changed) from the Standard Calculation for the following
reasons:
Does not apply
E. Income for the father is imputed
Income for the mother is actual income.
Income was imputed for the following reasons: father income is based on 2009
Joint tax return
F. If applicable: [ ] All health care, day care and special child rearing expenses are
included in the worksheets in Part III.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 10/2009 Page 1 of 5
W orksheets
Children and Ages: TSage15
and
HS age 8
Part I: Income (see Instructions, page 6)

1. Gross Monthly Income
a. Wages and Salaries
b. Interest and Dividend Income
c. Business Income
d. Maintenance Received
e. Other Income
f. Imputed Income
g. Total Gross Monthly Income (add lines 1a through 1f)
2. Monthly Deductions from Gross Income
a. Income Taxes (Federal and State)
b. FICA (Soc.Sec.+Medicare)/Self-Employment Taxes
e. Mandatory Pension Plan Payments
f. Voluntary Retirement Contributions
g. Maintenance Paid
h. Normal Business Expenses
i. Total Deductions from Gross Income
(add lines 2a through 2h)
3. Monthly Net Income (line 1g minus 2i)
4. Combined Monthly Net Income
(add fathers and mothers monthly net incomes from line 3)
Father
Mother
$5,957
$4,855
$4,855
$
$5,957
$813
$371
$1,186
$447
> \
($40 ) bO
"T
$
$
$
$62
$
$
$
$
$1,246
$3,609
$1673
$4,284
$7,893
5. Basic Child Support Obligation (enter total amount in box -*)

TS
$946
HS $767
6. Proportional Share of Income

(each parents net income from line 3 divided by line 4)
$1,713
.457
.543
Part II: Basic Child Support Obligation (see Instructions, page 8)

7. Each Parents Basic Child Support Obligation without consideration
of low income limitations. (Multiply each number on line 6 by line 5.)
$782.84
$930.16
$783
$930
8. Calculating low income limitations: (Complete those that apply.)

Self-Support Reserve: (125% of the Federal Poverty Guideline.)
a. Combined Net Income Less Than $1,000: If line 4 is less than
$1000, then for each parent enter the presumptive $50 per child.
b. Monthly Net Income Less Than Self-Support Reserve: If a
parents monthly net Income on line 3 is less than the self-support
reserve, then for that parent enter the presumptive $50 per child.
c. Monthly Net Income Greater Than Self-SuDDort Reserve: For
each parent subtract the self-support reserve from line 3. If that
amount is less than line 7, then enter that amount or the
presumptive $50 per child, whichever is greater.
9. Each parents basic child support obligation after calculating
applicable limitations. For each parent, enter the lowest amount
from line 7, 8a, 8b or 8c.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 10/2009 Page 2 o f 5
Part III: Health Care, Day Care, and Special Child Rearing Expenses (see Instructions, page 8)
10. Health Care Exoenses
a. Monthly Health Insurance Premiums Paid for Child(ren)
b. Uninsured Monthly Health Care Expenses Paid for Child(ren)
c. Total Monthly Health Care Expenses (line 10a plus line 10b)
Father
$
$
$
d. Combined Monthly Health Care Expenses

(add fathers and mothers totals from line 10c)
11. Day Care and Special Child Rearing Expenses
a. Day Care Expenses
Mother
$
$
$85.65
$
$150
b. Education Expenses
c. Long Distance Transportation Expenses

d. Other Special Expenses (describe)
$
$
e. Total Day Care and Special Expenses

(add lines 11a through 11 d)
$
$
$150
12. Combined Monthly Total Day Care and Special Expenses (add
fathers and mother's day care and special expenses from line 11e)
13. Total Health Care, Day Care, and Special Expenses (line 10d plus
line 12)
$150
$236
14. Each Parents Obligation for Health Care, Day Care, and Special
Expenses (multiply each number on line 6 by line 13)
$108
$128
$891
$1,058
Part IV: Gross Child Support Obligation

15. Gross Child Support Obligation (line 9 plus line 14)
Part V: Child Support Credits (see Instructions, page 9)
16. Child Support Credits
a. Monthly Health Care Expenses Credit
b. Day Care and Special Expenses Credit
$
$150
c. Other Ordinary Expenses Credit (describe)
$
d. Total Support Credits (add lines 16a through 16c)
$
$150
Part VI: Standard Calculation/Presumptive Transfer Payment (see nstructions, page 9)

17. Standard Calculation (line 15 minus line 16d or $50 per child
whichever is greater)
$908
$891
Part VII: Additional Informational Calculations

18. 45 % of each parents net income from line 3 (.45 x amount from
line 3 for each parent)
19. 25% of each parents basic support obligation from line 9 (.25 x
amount from line 9 for each parent)
Part VIII: Additional Factors for Consideration (see Instructions, page 9)

20. Household Assets
Fathers
(List the estimated present value of all major household assets.)
Household
a. Real Estate
$
b. Investments
$
Mothers
Household
$
$
c. Vehicles and Boats
d. Bank Accounts and Cash
e. Retirement Accounts
f. Other (describe)
$
$
$
$
$
$
21. Household Debt

(List liens against household assets, extraordinary debt.)
22. Other Household Income

a. Income Of Current Spouse or Domestic Partner
(if not the other parent of this action)
Name
Name
b. Income Of Other Adults In Household
Name
Name
c. Gross income from overtime or from second jobs the party is
asking the court to exclude per Instructions, page 10
d. Income Of Child(ren) (if considered extraordinary)
Name
Name
e. Income From Child Support
Name
Name
f. Income From Assistance Programs
Program
Program
g. Other Income (describe)
23. Non-Recurring Income (describe)
Judicial/Reviewing Officer
Date
This worksheet has been certified by the State of Washington Administrative Office of the Courts.
Photocopying of the worksheet is permitted.
e - f il e :
IN COUNTY C L E :
PIERCE COUNTY, \
March 16 2010
KEVIN ST
COUNTY C
NO: 10-3-0
3
4
5
6
SUPERIOR COURT OF WASHINGTON

COUNTY of PIERCE

9
Jennifer Kay Shipman,
Petitioner,
and,
10
NO. 10-3-00961-1
RETURN OF SERVICE
(OPTIONAL USE)
(RTS)
11
12
Jason William Shipman,

Respondent.
13
I, SHAD CHAPMAN, DECLARE:
14
I am over the age of 18 years, I am not a party to this action, and I am competent to testify
at trial.
15
16
2.
[XX]
[XX]
[XX]
[XX]
17
18
19
I served Jason Shipman with the following documents:
3.
summons and petition in this action

parenting plan or residential schedule
financial declaration
child support worksheets
The date, time, and place of service was;
20
Date:
March 15,2010
21
Address:
9403 - 355th Street
22
Time: 5:00 p.m.
McKenna, WA 98558
RETURN OF SERVICE
1 OF 2

(253) 770-0808, Fax (253) 770-0259
4.
Service was made pursuant to Civil Rule 4(d):
by delivery to the person named in paragraph 2 above.
5.
Other:
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is
true and correct.
5
Signed at Puyallup, WA, on March 16, 2010
6
7
8
Shad Chajlman, Declarant
9
10
11
12
13
14
15
16
17
18
19
20
21
22
RETURN OF SERVICE
2 OF 2
law
OFFICES OF GREENE & LLOYD, PLLC

(253) 770-0808, Fax (253) 770-0259
E-FILE
IN COUNTY CLEI
PIERCE COUNTY
March 23 2010
KEVIN S'
COUNTY C
NO: 10-3-C
3
4
5
6

IN AND FOR THE COUNTY OF PIERCE

9
JENNIFER SHIPMAN,
Petitioner,
Case No.: 10-3-00961-1
10
11
And,
COVER SHEET:
PROOF OF PARENTING CLASS
12
JASON SHIPMAN,
____________Respondent.
13
To the above named Court
14
Attached please find the Certificate of Completion for the parenting seminar attended by
15
the Petitioner, Jennifer Shipman,
16
17
Respectfully Submitted this 23th day of March 2010
18
19
20
Dennis Elliott, Legal Assistant to

Timothy M. Greene, WSBA 17499
21
22
COVER SHEET:
1 of 1
LA WOFFICES OF GREENE & LLOYD, PLLC

(253) 770-0808, Fax (253) 770-0259
/ ^ - 3 -
/ -
q q
Cause Number
3 ra \n X c -r
Case names:
S hvonw v
Petitioner
S h ip m a rt
Respondent
To All Those To Whom This Letter May Come
The Institute for Childrens Advocacy

Is pleased to announce that:
Jennifer SWip man

Has successfully completed a Four Hour workshop
Dont Forget the Kids

And, having such distinction and perspicacity in regard
to the course, is hereby granted this
Certificate of Completion
Dated this 16th day of March, 2010
In the City of Tacoma, State of Washington
Instructors: Susan O eftom e, M

.T .d.
S o h n M k n Stines, 9 A.S.
-4 /1 /2 8 -te m ? %
FILED
A.M.
10-3-00961-1
34043916
3 1 2010
P.M.

KEVIN STOCK, C ounty C lerk
BV__________________ DEPUTY
04-01-10
RSP
MAR
*-1

County of
No. 10-3-00961-1
Response to Petition
(Marriage)
Petitioner,
(RSP)
Check box if petition is attached for:
[ ] O rder for protection DV (PTORPRT)
[ ] O rder for protection UH (PTORAH)
and
Jason W. Shipman
________________________ Respondent.
To the Above-Named Petitioner:
I. Response
1.1
Admissions and Denials

The allegations of the petition in this matter are Admitted or Denied as follows (check only
one for each paragraph):
Paragraph of the Petition
u
1.2
1.3
1.4
1.5
1.6
1.7
1.8
[x]
[X)
[X]
[X]
[X]
[X]
[Xj
[]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
u
[]
[]
[]
[]
[]
[]
[x]
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Response to Petition (RSP) - Page 1 o f 3

WPF DR 01.0300 Mandatory (&2008) - R C W 26.Q9.O3Q0
u
[]
f]
[]
[]
[]
[]
[]
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
8372
1.9
1.10
[x]
[x]
1.11
M2
[X]
1.13
1.14
1.15
1.16
[X]
[X]
[X]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
[]
[]
[]
[}
[]
[]
[x]
Denied
Denied
Denied
Denied
Denied
Denied
[]
[]
[]
[}
[]
[]
1128338
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Denied
[]
Lacks Information
[3 Denied
[]
[*] Admitted
Each allegation of the petition that is denied, is denied for the following reasons (List separately):
1.8 Is denied for the following reasons,
Respondent would prefer mediation for the property division instead of a court proceeding.
1.15 is denied for the following reasons,
The summer schedule in the parenting plan should be modified, The parenting plan should be modified to
allow travel for work.
1.2
1.3
Notice of Further Proceedings

Notice of all further proceedings in this matter should be sent to the address below.
P.O. Box 167McKenna Wa 98558
Other
II. Request for Relief

Modify petitioners parenting plan, providing six weeks of summer visitation with respondent.
Suspend visitation as needed to allow respondent to travel for work.
It should be ordered that child support covers all expenses to support the children including daycare.
It should be ordered that Attorney fees incurred by each party be paid by each party, as per 1.9 o f the petition. Each
party shall pay their debts incurred since separation.
The court should order the petitioner to stop using the respondents personal checking account.
Child support worksheet should be modified to fathers actual income.
Response to Petition (RSP) - Page 2 of 3

WPF D R 01.0300 Mandatory (6/2008) - R C W 26.09.0300
3^1^2818
*
9 3 72
JS1Z3337
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
Does not apply.

The respondent requests the court to grant the relief requested below.
Enter a decree.
Provide reasonable maintenance for the [ ] husband [ ] wife.
Approve my parenting plan for the dependent children.
Determine support for the dependent children pursuant to the Washington State Child
Support Schedule.
Approve the separation agreement.
Dispose of property and liabilities.
Change name of wife to (first, middle, last):___________________________ .
Change name of husband to (first, middle, last):___________________________ .
Protection Order:
[]
[]
There is a protection order between the parties filed in case number_____________ ,

court_____________________, which expires on (date)___________________ .
The court should grant the [ ] domestic violence [ ] antiharassment petition for order for
protection:
[ ] attached to this response.
[ ] filed separately under [ ] this case number [ ] case number___________________ .
If you need immediate protection, contact the clerk/court for RCW 26.50 Domestic
Violence forms or RCW 10.14 Antiharassment forms.
D a te d :
[]
[)
[]
Enter a continuing restraining order.

Order payment of day care expenses for the children.
Award the tax exemptions for the dependent children as follows:
[]
[]
Order payment of attorney fees, other professional fees and costs.

Other:
3- 30-
3 .0 ( 0
Signature of Respondent or Lawyer/WSBA No,

Notice to party: You may list an address that is
not your residential address where you agree to
accept legal documents. Any time this address
changes while this action is pending, you must
notify the opposing parties in writing and file
an updated Confidential Information Form
(WPF DRPSCU 09.0200) with the court clerk.
Response to Petition (RSP) - Page 3 of 3

WPF DR 01.Q30Q Mandatory (6X008) - R C W 26.09.0300
S hfpyyt
0 4S>*>**
Print or Type Name
po
Bo*(Address)
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To All Those To Whom These Letters May Come

Family Education And Support Services
Is Pleased To Annouce That
Jason Shipman
Has Successfully Completed the 4 Hour Training
Consider the Children

And Having Shown Such Distinction
In Regard To The Course Is Hereby Granted This
Certificate of Completion
In the City of Olympia, State of Washington, 4/21/2010
Family Education
& Support Services
Marji Mitchell
1-'
Walt Barfield
E-FILEb
IN COUNTY CLEF
PIERCE COUNTY, W
June 04 2010 8
KEVIN STO
COUNTY CL
NO: 10-3-03
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County of Pierce
In re the Marriage o f:
Petitioner(s),
and
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Respondent(s).
No. 10-3-00961-1
Declaration of
(PCLR Modified)_______
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I Declare:
That I am Jennifer Kay Shipman, I am competent, and I am a party to this action.
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P arenting Plan:
We have separated since February 27, 2010. To date, we have worked out parenting
informally (I have been the primary residential parent and Jason has had visitation with
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the children every other weekend). However, Jason has issues with the summer visitation
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that I propose: In his Response, which was filed on March 31, he is requesting that the
court Modify petitioner s parenting plan, providing six weeks of summer vacation with
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respondent. Suspend visitation as needed to allow respondent to travel for work (emphasis
added).
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Street: 4115 S. Meridian
Mailing: P.O. Box 7310G3
(253) 770-0808, Fox (253) 770-0259
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My parenting plan allows each parent to have two weeks of vacation with the children.
With our situation, it would be impractical to give Jason six weeks with the children.
Primarily, although the children would be on vacation the whole time, Jason would not.
Jason would be working during the day, thereby leaving a nine year old child at home with
a fifteen year old. Second, Jason often has to travel on his job, as he has conceded in his
response.
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Child Support:
Since we have been separated, Jason has been paying a form of child support informally.
However, again, we need an order, both for the protection of the children, and because we
have disagreement on some issues. I also have to modify the drafted child support
worksheets which I had submitted on March 15, 2010, to cover some issues, such as
daycare and health insurance, which were not covered in the initial proposed worksheets.
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Regarding daycare, I am paying $ 150 a month for daycare for our child HS. I am proposing
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that Jason pay 50% of that. The boys are active in sports, I am proposing that Jason pay
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50% of the expenditures for the boys participation, which would be $ 130 plus the cost of
uniform, equipment, and pictures annually for baseball, and $ 160 plus the cost of uniform,
equipment, and pictures annually for football. Health insurance is provided for the boys by
Jasons employer at no charge (no formal premiums are paid). I would propose, however,
that each parent be formally obligated by a proportionate share of our incomes for any
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extraordinary health care or dental expenses not covered by insurance. In particular, our
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children need glasses and orthodontic care.
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To date, Jason has been paying me directly for the support. However, I believe it is both of
our best interests, to avoid any problems in the future, that the Division of Child Support
be enlisted to provide enforcement and collection services.
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Mailing: P.O. Box 731063
(253) 770-0808, Fax (253) 770-0259
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R estraining Order re: Community Property: There needs to be a restraining order

enjoining Jason from transferring, removing, encumbering, concealing, or in any way
disposing of any property. Within two to three weeks of our separation, Jason sold our 91
Ford F-150 and 86 or 87 Toyota 4 Runner, and kept the $ 6,100 he earned from those
deals. I am especially upset about this sale because, two years prior, Jason had badgered
me to cash out what retirement I had at that time so that we could buy the 4 Runner.
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Jason had also received the refund from our 2009 joint tax return, which was
$ 12,281.oo , and only gave me $ 790.45 from the proceeds.
Jason should be enjoined from selling any further property. Further, in case any of the
proceeds of the sale of the vehicles referenced above, or from the 2009 income tax are left,
he should be enjoined from spending or disposing of those funds.
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A u th orizes F am ily Home to be O ccupied By P etitioner: We separated by Jason

moving out of the family home on February 27, 2010. He has never attempted to move
back in as the permanent occupier. However, he still enters at will, disregarding my
privacy rights. This doesnt happen often, but it should not happen at all. Ive changed the
locks but he has entered, riffled through my mail and taken video and pictures of
documents and items in the house, presum ably to avoid asking me for copies and
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lists of community property documents and items .
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I dont want a restraining order, but I want a court order indicating that Jason may not
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enter the family home without my permission, and that Jason must give me the master
code for the homes security system.
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(253) 770-0808, Fax (253) 770-0259
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Signed at Puyallup, Washington on May 28, 2010..
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Jennifer Shipman
Print or Type Name
Do not attach financial records, personal health care records or confidential
reports to this declaration. Such records should be served on the other party and
filed with the court using one of these cover sheets:
1) Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
2) Sealed Personal Health Care Records (WPF DRPSCU 09.0260) for health records
3) Sealed Confidential Report (WPF DRPSCU 09.270) for confidential reports
If filed separately using a cover sheet, the records will be sealed to protect your
privacy (although they will be available to all parties in the case, their attorneys,
court personnel and certain state agencies and boards.) See GR 22(
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(253) 770-0808, Fax (253) 770-0259
E-FILED
IN COUNTY CLERK
PIERCE COUNTY, W
June 04 2010 3
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KEVIN STO
COUNTY C .
NO: 10-3-0)
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County of Pierce
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No. 10-3-00961-1
Petitioner,
Motion and Declaration for

Tem porary O rder
(MTAF)
and
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Respondent.
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I.
Motion
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Based on the declaration below, the undersigned moves the court for a temporaiy order which:
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[]
[x]
[X]
[]
[X]
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[]
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[]
orders temporary maintenance.

orders child support as determined pursuant to the Washington State child support statutes,
approves the parenting plan which is proposed by the [ ] petitioner [x ] respondent,
approves the Temporary Residential Time re Military Parents proposed by the [ ] petitioner
[ ] respondent pursuant to RCW 26.09.260(11), (12).
restrains or enjoins the [X ] petitioner [ X] respondent from transferring, removing, encumbering,
concealing or in any way disposing of any property except in the usual course of business or for the
necessities of life and requiring each party to notify the other of any extraordinary expenditures
made after the order is issued.
restrains or enjoins the [ ] petitioner [ ] respondent from disturbing the peace of the other party or of
any child.
restrains or enjoins the [ ] petitioner [ ] respondent from going onto the grounds of or entering the
home, work place or school of the other party or the day care or school of the following named
children:
restrains or enjoins the [ ] petitioner [ ] respondent from knowingly coming within or knowingly
remaining within (distance)__________________of the home, work place or school of the
other party or the day care or school of the following children:
Motion and Declaration

for Temporary Orders
1 of 3

Street Address: 4115 Meridian So., Ste. B
Ph.: (253) 770-0808, Fax (253) 770-0259
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[]
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[]
[X ]
[]
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[X]
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[X ]
[X ]
[X ]
[X ]
[X]
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restrains or enjoins (name)_______________________ from molesting, assaulting,

harassing, or stalking (name)___________________________ . (If the court orders this
relief and the parties are intimate partners as defined under federal law, the restrained person will
be prohibited from possessing a firearm or ammunition under federal law for the duration of the
order. An exception exists for law enforcement officers and military personnel when carrying
department/govemment-issued firearms. 18 U.S.C. 925(a)(1).)
restrains or enjoins the [ ] petitioner [ ] respondent from removing any of the children from the
state of Washington.
restrains or enjoins the [X ] petitioner [X ] respondent from assigning, transferring, borrowing,
lapsing, surrendering or changing entitlement of any insurance policies of either or both parties
whether medical, health, life or auto insurance.
(If this box is checked clear and convincing reasons for this request must be
presented in the declaration below.)
requires the [ ] petitioner [ ] respondent to surrender any deadly weapon in his or her immediate
possession or control or subject to his or her immediate possession or control to the sheriff of the
county having jurisdiction of this proceeding, to his or her lawyer or to a person designated by the
court.
makes each party immediately responsible for their own future debts whether incurred by credit
card or loan, security interest or mortgage.
divides responsibility for the debts of the parties.
authorizes the family home to be occupied by the [X ] petitioner [ ] respondent.
orders the use of property.
requires the [ ] petitioner [X] respondent to vacate the family home.
requires the [ ] petitioner [X] respondent to pay temporary attorney fees, other professional fees and
costs in the amount of $ 1,000 to: Petetioner
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appoints a guardian ad litem on behalf of the minor children.
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other:
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Dated:
? 2 - 0 ] O ___________
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______ _____
S^gnatufaof Requesting Party or Lawyer/WSBA No.
Timothy M'/Greene. WSBA # 17499
Print or Type Name
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M otion a n d D e c la ra tio n
fo r T em p o ra ry O rd ers

Ph.: (253) 770-0808, Fax (253) 770-0259
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II. Declaration
Tem porary relief is required because:
Declaration filed separately
I declare under penalty o f perjury under the laws o f the state o f W ashington that the foregoing is true and
correct.
Signed at Puyallup, W ashington on April 6, 2010.
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Signature o f Requesting Party
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Jennifer Shipman
Print or Type N am e
Do not attach financial records, personal health care records or confidential reports to
this declaration. Such records should be served on the other party and filed with the
court using one of these cover sheets:
If filed separately using a cover sheet, the records will be sealed to protect your privacy
(although they will be available to all parties in the case, their attorneys, court personnel
and certain state agencies and boards.) See GR 22(C)(2).
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M otion an d D e c la ra tio n
fo r T em p o ra ry O rd ers
3 of 3

Ph.: (253) 770-0808, Fax (253) 770-0259
E-FILED
June 04 2010 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
NOTE FOR COMMISSIONER'S CALENDAR
vs.

Respondent(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:
Name: ROBERT D. LLOYD

Address: 4115 S. MERIDIAN, SUITE B PUYALLUP, WA 98373
Phone: (253) 770-0808

Attorney for Plaintiff/Petitioner
Name: JASON WILLIAM SHIPMAN

Address: PO BOX 167 MCKENNA, WA 98558
Phone:
Respondent
Please take notice that an issue of law in this case will be heard on the date and time shown below:
P ierce C o u n ty S u p e rio r C o u rt, C o u n ty -C ity B uilding - 930 T a c o m a A v e S - T aco m a , W A 9840 2
Motion - Modify Temp Order

Calendar: Show Cause/Family Law
CALENDAR DATE: Tuesday, July 13, 2010 9:30 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 W O C O U R T D A YS P R IO R T O H E A R IN G
DA TED :
June 3, 2010.
S ign ed :
/s/ TIMOTHY M. GREENE
NA M E:
TIMOTHY M. GREENE
Phone:
(253) 770-0808
W SBA#:
17499
A D D R E S S : 4115 S MERIDIAN
PO BOX 731063
PUYALLUP, WA 98373
Note for Commissioners Calendar (3/2010)
For:
1 of 1
E-FILED
June 04 2010 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1

Petitioner(s),
vs.
NO. 10-3-00961-1
NOTICE OF APPEARANCE

_______________ Respondent(s)
TO: Clerk of the Court
AND TO: ROBERT D. LLOYD, attorney for Petitioner, JENNIFER KAY SHIPMAN, TYLER
SHIPMAN, HUNTER SHIPMAN
PLEASE TAKE NOTICE that CLINT P. JOHNSON, appears herein on behalf of the
Respondent(s) JASON WILLIAM SHIPMAN and requests that all further pleadings and paper,
except original process, be served upon said attorney at the address listed below.
DATED: June 03, 2010
ntaprsup-0001.pdf
/s/ CLINT P. JOHNSON

CLINT P. JOHNSON, #14794
Attorney for Respondent(s)
Faubion, Johnson, Reeder & Fraley PS

5920 100th St SW Ste 25
LAKEWOOD, WA 98499-2751
(253) 581-0660
E-FILED
July 12 2010 1:30 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)

Phone: (253) 770-0808

Name: CLINT P. JOHNSON

Address: 5920 100th St SW Ste 25 LAKEWOOD, WA 98499-2751
Phone: (253) 581-0660

Attorney for Respondent
Motion - Temporary Order

CALENDAR DATE: Tuesday, August 24, 2010 9:30 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 W O C O U R T D A YS P R IO R T O H E A R IN G
DA TED :
July 12, 2010.
S ign ed :
NA M E:
TIMOTHY M. GREENE
Phone:
(253) 770-0808
W SBA#:
17499
A D D R E S S : 4115 S MERIDIAN
PO BOX 731063
PUYALLUP, WA 98373
Note for Commissioners Calendar (ntc.rptdesign)
For:
1 of 1
3349
IN THE SUPERIOR COURT, PIERCE COUNTY, WASHINGTON

Cause Number: 10-3-00961-1

Petitioner(s)
MEMORANDUM OF JOURNAL ENTRY
vs.
Page 1 of 2

Respondent(s)
Judge/Commissioner: STEPHANIE A. AREND
Court Reporter: Smart Court
Judicial Assistant/Clerk: Denese Overhulse
SHIPMAN, JENNIFER KAY
ROBERT D. LLOYD
SHIPMAN, JASON WILLIAM
CLINT P. JOHNSON
SHIPMAN, TYLER
SHIPMAN, HUNTER
Proceeding Set: Assignment to Set Trial Date

Proceeding Outcome: Held
Outcome Date: 07/16/2010 9:03
Resolution:
Clerk's Scomis Code:MTHRG

Proceeding Outcome code: HELD
Resolution Outcome code:
Amended Resolution code:
Report run date/time: 07/16/10 2:35 PM
Ixcalcivii.pbl,d_cMIJoumal_rvport_cover
QS43
T382SZ


MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner:
STEPHANIE A. AREND
________________________________ MINUTES OF PROCEEDING__________________

Judicial Assistant/Clerk: Denese Overhulse
Start Date/Time: 07/16/10 9:45 AM
July 16, 2010 09:45 AM This matter comes before the Court on an assignment to set a trial
date. Attorney Johnson appears on behalf of the Respondent.
Court/counsel colloquy.
Court generates a case schedule setting a trial date of July 25, 2011 at 9:00 am and
provides 2 copies to Atty. Johnson. Court is at recess on this matter.
End Date/Time: 07/16/10 9:50 AM
JUDGE/COMMISSIONER: STEPHANIE A. AREND Year 2010
Confirmation of Service
12/06/10
Set Settlement Conference Date with Judge/Com m issioner ELIZABETH M AR TIN (S ee PCLR 3(c) 2(b ) &
94 .04 (f
02/21/11
Plaintiffs/Petitionefs Disclosure of Primary W itnesses
03/07/11
Defendanfs/Respondents Disclosure of Primary W itnesses
04/04/11
Disclosure of Rebuttal W itnesses
04/25/11
Deadline for Filing Motion to Adjust Trial Date
05/09/11
Discovery Cutoff
06/13/11
Exchange of W itness and Exhibit Lists and Documentary Exhibits
06/27/11
Joint Statem ent of Evidence
06/27/11
Week Of 07/11/11
Settlement Conference (To be held)
07/25/11 9:00
Trial
.Unless otherwise instructed, ALL Attorneys/Parties shall report to the trial court at 9:00 AM
on the date of trial.
NOTICE TO PLAINTIFF/PETITIONER
If the case has been filed, the plaintiff shall serve a copy of the Case Schedule on the defendant(s) with the summons and
complaint/petition: Provided that in those cases where service is by publication the plaintiff shall serve the Case Schedule
within five (5) court days of service of the defendants first response/appearanee. If the case has not been filed, but an
initial pleading is served, the Case Schedule shall be served within five (5) court days of filing. See PCLR 1.
NOTICE TO ALL PARTIES
All attorneys and parties shall make themselves familiar with the Pierce County Local Rules, particularly those relating to
case scheduling. Compliance with the scheduling rules is mandatory and failure to comply shall result in sanctions '
appropriate to the violation. If a statement of arbitrability is filed, PCLR 1 does not apply while the case is in arbitration.
Judge Stephanie A. Arend

Department 12 (253) 798-7562
S349
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No. 10-3-00961-1
ORDER AMENDING
CASE SCHEDULE
Petitioner(s)
vs.
Respondent(s)
CC:
Type of Case:
Estimated Trial (days):
Track Assignment:
Assigned Department:
Docket Code:
CLINT P. JOHNSON, Atty

ROBERT D. LLOYD, Atty
Page 2 of 2
DIC
Dissolution
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ORACS
o84cv
7 /2 8 /2 0 3 /0 .-S30Z7S


Petitioners)
vs.
Page 1 of 2

Respondent(s)
Judge/Commissioner: Mark L Gelman
Judicial Assistant/Clerk: Jennifer Allyn
ROBERT D. LLOYD
CLINT P. JOHNSON
SHIPMAN, TYLER
SHIPMAN, HUNTER
Proceeding Set: Exparte Action

Outcome Date: 07/16/2010 9:18
Resolution:
Cleric's Scomis Code: MTHRG

Report run date/time: 07/16/10 9:23 AM
Ixcatcivil, pbl. d_civilJoumal_mport_co ver


MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner:
Mark L Gelman
____ ___________________________ MINUTES OF PROCEEDING___________

Court Reporter:Smart Court
July 16, 2010 09:22 AM
Attorney Tim Greene comes before the court to present an agreed temporary order. Court
declines to sign order. Order to list full names of children and to be on mandatory pattern
form.
JUDGE/COMMISSIONER: Mark L Gelman Year 2010
3Z7
10-3-00961-1
34756054
PPT
iS /2 ^ 2 8 i
1278383
00-02-10
FILED
IN COUNTY CLERKS OFFICE
JUL 3 0
2010
p.m.
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BY ---------------------- .DEPUTY
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County of Pierce
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No. 10-3-00961-1
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Petitioner,
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and
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Parenting Plan
[x ] Temporary (PPT)
Respondent.
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This parenting plan is:
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pC ]
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A temporary parenting plan signed by the court, and agreed to by the parties to
be an interim order until the hearing on temporary orders in this matter,
presently scheduled for August 24, 2010.
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Name
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Age
Tyler Shipman
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Hunter Shipman
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Parenting Plan (PPP, PPT, PP) - Page 1 of 7

WPF DR 01.0400 Mandatory (6/2008) RCW 26.09.016, .181; .187; .194

Street: 4115 S. Meridian, Ste. B
(253) 770-0808, Fax (253) 770-0259
9127
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11. Basis for Restrictions
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Under certain circumstances, as outlined below, the court may limit or prohibit a parent's contact with
the children and the right to make decisions fo r the children.
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2.1

Does not apply
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2.2
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Does not apply
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111. Residential Schedule

The residential schedule must set forth where the children shall reside each day o f the year, including
provisions for holidays, birthdays offamily members, vacations, and other special occasions, and what
contact the children shall have with each parent. Parents are encouraged to create a residential
schedule that meets the developmental needs o f the children and individual needs o f theirfamily.
Paragraphs 3. J through 3.9 are one way to write your residential schedule. I f you do not use these
paragraphs, write in your own schedule in Paragraph 3.13.
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3.1
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3.2
School Schedule
Upon enrollment in school, the children shall reside with the mother, except for the following
days and times when the children will reside with or be with the other parent:
From: Friday 7:00 pm to Sunday 7:00 pm every other week; starting the weekend of July 9,
2010 (Friday).
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The children shall reside with the mother during winter vacation, except for the following days
and times when the children will reside with or be with the other parent:
No schedule until further temporary orders are entered at the hearing presently scheduled
for August 24, 2010 or a permanent parenting plan is entered.
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3.4

same as 3.3 above

WPF DR 01.0400 Mandatory (6/2008) R C W 26.09.016, .181; .187; .194
(253) 770-0808, Fax (253) 770-0259
9127
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3.5
Upon completion of the school year, the children shall reside with the mother, except for the
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Same as school year schedule.

3.6

Each parent shall be entitled to spend two consecutive weeks vacation time with the children
each year, to be scheduled with the other parent, in writing, by the first day of March, or
otherwise arranged through the attorneys of the parents.
This interim order is entered without prejudice to fathers request for more vacation time as
entered in his response.
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Summer Schedule
3.7
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No holidays until further temporary orders are entered at the hearing presently scheduled
for August 24, 2010.
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3.8
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The residential schedule for the children for the following special occasions (for example,
No special occasions until further temporary orders are entered at the hearing presently
scheduled for August 24,2010.
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3.9

Does not apply.
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3.10
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Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2
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(253) 770-0808, Fax (253) 770-0259
127
9 1 2 ? S /2 /2 8 1 B
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3.11
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Transportation costs are included in the Child Support Worksheets and/or the Order of Child
Support and should not be included here.
Transportation arrangements for the children between parents shall be as follows:
The parents shall exchange the children at the Fred Meyer parking lot at 176thand
Meridian between the Baskin-Robbins store and the Umpqua Bank at the beginning and
end of each visitation period. Each parent must be present for exchange, and neither
parent may substitute another person.
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3.12
The children named in this parenting plan are scheduled to reside the majority of the time with
the mother. This parent is designated the custodian of the children solely for purposes of all other state
and federal statutes which require a designation or determination of custody. This designation shall not
affect either parent's rights and responsibilities under this parenting plan.
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3.13
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Other
there are no other provision
3.14
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This is a sum m ary only. For the full text, please see RCW 26,09.430 through 26.09.480.
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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 child's school district, the relocating person must give notice by
personal service or by mail requiring a return receipt. This notice must be at least 60 days before the
intended move. If the relocating person could not have known about the move in time to give 60 days'
notice, that person must give notice within 5 days after learning of the move. The notice must contain
the information required in RCW 26.09.440. See also form DRPSCU 07.0500, (Notice of Intended
Relocation of A Child).
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If the move is within the same school district, the relocating person must provide actual notice by
any reasonable means. A person entitled to time with the child may not object to the move but may ask
for modification under RCW 26.09.260.
Notice may be delayed for 21 days if the relocating person is entering a domestic violence shelter
or is moving to avoid a clear, immediate and unreasonable risk to health and safety.
If information is protected under a court order or the address confidentiality program, it may be
withheld from the notice.
Parenting Plan (PPP, PPT, PP) * Page 4 of 7
WPF DR 01,0400 Mandatory (6/2008) R C W 26.09.016, .181; .187; .194
(253) 770-0808, Fax (253) 770-0259
912?
1271
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A relocating person may ask the court to waive any notice requirements that may put the health
and safety of a person or a child at risk.
If no objection is filed within 30 days after service of the notice of intended relocation, the
relocation will be permitted and the proposed revised residential schedule may be confirmed.
A person entitled to time with a child under a court order can file an objection to the child's
relocation whether or not he or she received proper notice.
The relocating person shall not move the child during the time for objection unless: (a) the
delayed notice provisions apply; or (b) a court order allows the move.
If the objecting person schedules a hearing for a date within 15 days of timely service of the
objection, the relocating person shall not move the child before the hearing unless there is a clear,
immediate and unreasonable risk to the health or safety of a person or a child.
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TV. Decision Making

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4.1
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Each parent shall make decisions regarding the day-to-day care and control of each child while
the children are residing with that parent. Regardless of the allocation of decision making in this
parenting plan, either parent may make emergency decisions affecting the health or safety of the children.
4.2
Major Decisions
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Education decisions:
[ ] mother
[ ] father
[XX] joint
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Non-emergency health care:
[ ] mother
[ ] father
[XX] joint
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Religious upbringing:
[ ] mother
[ ] father
[XX] joint
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Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2 above
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W PF D R 01.0400 Mandatory (6/2008) R C W 26.09.016, .181; .187; .194

(253) 770-0808, Fax (253) 770-0259
912?
8^2>201B
1 2 .7 0
1
2
3
4
The purpose o f this dispute resolution process is to resolve disagreements about carrying out this
parenting plan. This dispute resolution process may, and under some local court rules or the provisions
o f this plan must, be used before filing a petition to modify the plan or a motion for contempt for failing
to follow the plan.
5
6
Disputes between the parties, other than child support disputes, shall be submitted to mediation
by Pierce County Center for Dispute Resolution
As determined in the dispute resolution process.
8
9
The dispute resolution process shall be commenced by notifying the other party by written
request via certified mail, return receipt.
10
11
(a)
12
(b)
13
(c)
14
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.

15
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(d)
without good reason, the court shall award attorneys' fees and financial sanctions to the other parent.
17
(e)
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The parties have the right of review from the dispute resolution process to the superior
court.
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(253) 770-0808, Fax (253) 770-0259
912 7
B /2 /2 R 1 8
127
1*
1
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
6
7
When mutual decision making is designated but cannot be achieved, the parties shall make a good faith
effort to resolve the issue through the dispute resolution process.
8
If a parent fails to comply with a provision of this plan, the other parent's obligations under the plan are
9
not affected.
10
11
Date this____ day of______ 2010

Judge/Commissioner
12
13
14
Date this 23rd day of July 2010
15
Presented by:
16
Approved for entry. Notice of

Presentation Waived
FAUBION, JOHNSON & REEDER
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18
Clint P. Johnson, WSBA #14794

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(253) 770-0808, Fax (253) 770-0259
9127
S V 2 /2 616
12 7 B 3 9 0
IT IS ORDERED, ADJUDGED AND DECREED that the parenting plan set forth above is adopted and
approved as an order of this court.
WARNING; Violation of residential provisions of this order with actual knowledge of its terms is
punishable by contempt of court and may be a criminal offense under RCW 9A40.060(2) or
9A.40.G70(2). Violation of this order may subject a violator to arrest
If a parent fails to comply with a provision of this plan, the other parent's obligations under the plan are
not affected.
Date this
day
2010
ft | tr-EO
m m is s io n e r
,N COUNTY CLERK'S OFFICE
P.M.
P 'E COUNTY, WASHINGiTON
^KEVIN STOCK, County (IIfork
Date this 23rt day of July 2010

Presented by:
tr
Approved for entry. Notice of
Presentation Waived ^
Cunt P, Johnson,
Attorney for Respond
#14794
Parenting Plan (PPP* PPT, PP) - Page 7 of 7

WPF DR 01.0400 Mandatory (6/2008) RCW 26.09.016,. 181; . 187; .194
Leiyi Offices of Greene &Lloyd, PLLC

Puyallup, 'Washington 98373
(253) 770-0808, Pax (253) 770-0259
0 iPUTY
9356
8 / 16,'20 18
888B9
08-16-10
10-3-00961-1
2
L0UNTY CLERKS OFFICE
am.
AUG is 2010 PM
4
-----t y deputv
5
6
7

County of Pierce
In re the Marriage o f:

9
No. 10-3-00961-1
Petitioner(s),
and
10
n

Respondents).
12
Supplemental Declaration of
Re: Motion for
Temporary Orders
(DCLR Modified)
13
14
/ Declare:
That I am Jennifer Kay Shipman, I am competent, and I am a party to this action.

15
16
17
18
19
I wish to supplement my Declaration, filed June 4, 2010 in support of my Motion for

Temporary Orders, also filed June 4, 2010, as follows:
F inancial D eclaration
The Financial Declaration which I filed on March 15, 2010, is still true and correct,
with the exception of the following:
(a) My Alaska Credit Union loan, listed at $ 20,000 in the Financial Declaration, is
20
now $ 35,000. The original loan was for a 2002 Mercedes, which had recently had
21
electrical problems and transmission problems that would cost $ 8,000 to $ 9,000
to repair, at the time that my Mercedes was only worth $ 16,000.1 accordingly
22
23
purchased a used 2004 Cadillac Escalade, with the $ 35,000 Alaska Credit Union
loan.
(253) 770-0808, Fax (253) 770-0259
9356
8 ^ 1 6 /2 6 1 8
The monthly payments on the Escalade are $ 200 more a month, or $ 556.00.
1
2
(b) I had to take out a Home Depot credit card and borrow $ 800 on that
3
credit card in order to remove black mold in our home.
4
Division o f Debts:
5
6
7
I am requesting that Jason either agree to, or be ordered to, pay half of the unpaid
community related bills that accrued before he left the community home. These are bills
related to the Verizon cell phone, cable, water, garbage, house phone, and auto insurance.
I will have the bills itemized immediately for my attorney to present to Jasons attorney.
8
9
10
Signed at Puyallup, Washington on August 10, 2010..

11
12
13
14
15
16
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18
iu iik
fer Shipman
Lture of Declarant
k L ,_________

filed with the court using one o f these cover sheets:
I f filed separately using a cover sheet, the records will be sealed to protect your
19
20
21
22
23
(253) 770-0808, Fax (253) 770-0259
E-FILED
August 18 2010 10:59 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
4
5
6

7
8

JENNIFER KAY SHIPMAN,
Petitioner,
10
11
12
NO. 10-3-00961-1
REPLY DECLARATION OF
JASON SHIPMAN
vs.
JASON WILLIAM SHIPMAN,
Respondent.
13
14
15
16
17
This declaration is made under penalty of perjury of the laws of the State of
Washington.
This declaration is made in response to Jennifers declaration of June 2, 2010.
18
Parenting plan.
19
20
21
I generally agree with the proposed plan, but I objected in my Response to the
summer schedule and I requested flexibility in the schedule due to my travel for work.
22
There is no reason I should not have the boys for half the summer. Jennifer states
23
I would be leaving a nine year old child alone with a fifteen year old. Yet the boys have
24
25
been home alone at her house all summer. On one occasion she left Hunter (the nine year
old) home alone while she was getting her car repaired. Tyler is now sixteen and capable
REPLY DECLARATION
OF JASON SHIPMAN - 1
FAUBION, JOHNSON, REEDER & FRALEY, P.S.
Attorneys at Law
5920 100th Street S.W., S uite 25
Lakewood, WA 98499
(253)581-0660
of watching his brother. If this is acceptable at her home, why not at mine? I am with the
children every weekend they are at my home. She has them at friends homes most of the
weekends they are with her. In fact, when I was still living in the family home, Tyler had
gone to a friends home. When Jennifer and I picked him up we had a conversation
regarding the residence and location. We decided he should not go there anymore
because it just was not a good place. There was no parental supervision. However, after I
moved out Jennifer herself began to let Tyler do whatever he wanted without
supervision, including returning to that home.
About three weeks ago my brother saw Tyler walking on Portland Avenue in
Tacoma after 10:00 p.m. My brother called Jennifer to let her know about this. Jennifer
said it was all right because Tyler was staying with a friend. It turned out to be the
place we said he should not be. I got a call from the police at about 1:30 a.m. They had
arrested Tyler for shoplifting. The police could not reach his mother; she was not home
and would not answer her cell phone. Tylers friends mother, who was supposed to be
supervising the boys, was so drunk she could not hold a conversation with police. The
police asked me if it was all right to release Tyler to my parents.
When our sons stayed with me for a week, I made sure they had proper parental
supervision while I was at work, they were either with me or with friends whose parents
were capable of watching them. I am currently not traveling for my job because, among
other antics, Jennifer called my workplace making false accusations that I stole my
employers property and it was in the garage. This ended up involving the owner of the
REPLY DECLARATION
A ttorneys
at
Law
S.W., Suite 25
Lakewood , WA 98499
59201 00th S treet
(253) 581-0660
company, human resources, my boss, and the company attorney. Then when they
planned to come and get the allegedly stolen property, Jennifer said, Oh, never mind, I
changed my mind. There was no stolen property, but now my employer will always
question whether I am a thief.
In addition, Jennifer has keyed my work van, called 911 and fabricated a story
saying I hurt her, attempted to get an unnecessary restraining order, and caused a lot of
problems for me at work. I have a security clearance and am in the P.R.P. program. I
have to explain to my employer all these things that Jennifer is doing. I am on very thin
ice and have been demoted to the testing department. I am no longer traveling (see
attached letter from my employer). There should be no more concern as to me watching
our children in the summer.
Now that my travel for work has been eliminated, I have filed a Proposed
Parenting Plan providing me with more time with my two sons. In addition to sharing
the summer, I am proposing alternating weekends from Friday at 7:00 p.m. to Monday
morning (return to school) and a regular weeknight visit. I do have concerns with
Jennifers ability to care for the boys full time. She seems to be taking out her anger on
Tyler. See the police report filed under seal.
Child support.
Jennifer and I agreed informally I would pay her $175.00 a week to help support
the boys. That is what I have been paying. I have given her forms to have the money
directly deposited to her account, but she refuses to do so.
REPLY DECLARATION
Attorneys at Law
5920 100th Street S.W., Suite 25
Lakewood, WA 98499
(253) 581-0660
Hunter has not been going to daycare. Tyler watches him. Again, she states in her
document that I cannot see the boys because I will leave them alone, yet that is exactly
what she does and now she wants additional money for daycare.
The sports she refers to are activities she signs them up for without consulting
me. I do not ask her to pay for extracurricular activates they participate in when they are
with me. If I am expected to participate in paying for activities, I should consent to them
first and not pay for Jennifers unilateral decisions.
Jennifer is upset I bought a motorcycle, yet we discussed the purchase and she
agreed to it. She even took me to Renton to buy it and sat there while I did the
paperwork. Now she says I spent the money frivolously.
My earnings statements are filed under seal. My child support worksheets are
based on my regular year-to-date earnings. I no longer receive per diem since I do not
travel. According to this worksheet, my monthly support obligation should be $780.02.
Restraining order re Community Property,
I sold the Ford truck a week or two before I left for $200. It was not drivable and
would have cost a lot of money to fix. I also sold the 4Runner before I left because it was
not practical. I got $2,000 for it and I put the money down on a 2002 Toyota truck that
was better for the family, so for both vehicles I received $2,200, not $6,100.1bought the
truck before I left. Jennifer traded in our very nice 2007 Chevy 2500 diesel truck for a
Mercedes Benz. I had begged her not to do this. I told her if it broke she could never
REPLY DECLARATION
FAUBiON, JOHNSON, REEDER & FRALEY, P.S.
Attorneys at Law
Lakewood, WA 98499
(253) 581-0660
afford to fix it. That is exactly what happened. Now she has a newer Cadillac Escalade!
These are very expensive vehicles. I bought a simple older Toyota truck. I fail to see why
she can buy and sell all these costly high-end vehicles but I am called to task when I sell
a 1985 4Runner to get 2002 Toyota truck.
As far as badgering her to cash out her retirement, I do take offense at that.
Jennifer got fired from her job and did not go back to work for a long time. She lived off
her retirement money. We traded my truck and her car to get her a brand new truck when
she went back to work. This left me with no vehicle so we got the 4Runner. Again she
got a $35,000 truck; I got a 1985 truck that barely functioned.
As far as the tax return, 1 paid off several of bills with the money, giving Jennifer
half of what was left. I paid two months5power bills; a house payment; a personal loan
from a friend; and the Home Depot, Chase, and Frontier credit cards (see spreadsheet
attached). The credit cards were run up in part because Jennifer was not paying bills. (I
would get calls from bill collectors while working out of town and have to pay them. She
had the power shut off on her once. After that 1 had all bill collectors just call me and I
paid them.) We also remodeled the bathroom, which was very expensive. Jennifer knows
how I spent that money, just as she knows I used the money from the 4Runner to make a
down payment on the truck. I gave her a copy of the spreadsheet. She is just angry and
being vindictive. We only have one debt now and that is her student loan, ft was the debt
with the lowest interest rate so it was the last thing to pay off.
REPLY DECLARATION
A ttorneys at Law

Lakewood , WA 98499
(253)581-0660
1
2
3
Occupation of the family home.
I have no problem not going to the home, but it is my house, too. I offered to put
5
6
the home in my name. I went to the bank and got approval. Jennifer told me to do that so
she could move out. Then when I got approval she got mad and told me she was keeping
7
8
9
the house and I needed to move out. I have always done what she has asked. I think she
should put the home in her name or sell it. She said she was going to stop making the
10
house payment to ruin my credit. I have a text on my work phone that says, im not
11
making the house payment this is war. All of Jennifers statements are false or
12
exaggerated. Jennifer kicked me out of the home and is still punishing me for it. She uses
13
the children as a tool to hurt me. She does not pay bills, which she knows causes me
14
damage. She even tried to get me fired. She has made me go without seeing the children
15
16
17
18
for over six weeks more than once. Even after setting up a time and place with my
attorney, she has not shown up.
Jennifer has not made a house payment since May, even though she earns over
19
$70,000 per year, and receives child support from me. Yet she just bought a very nice
20
car and added $15,000 to her total debt. She should be ordered to resume the mortgage
21
payments and promptly cure the arrears, or immediately refinance the home in her name.
22
Signed at Lakewood, Washington, on August 17, 2010.
23
24
25
REPLY DECLARATION
A ttorneys at Law
Lakewood, WA 98499
(253)581-0660
2009 Tax Return
beginning $
funds spent on
Frontier credid card
Chase credit card
Home depot card
Frenchie personal loan from a friend
House Payment
Power bills for 2 months
Divided in 2 giving Jen half ($790.45)
$ spent
$3,320.27
$2,075.11
$1,147.82
$2,000.00
$1,603.14
$553.77
$1,580.89
$12,281,00
Balance
$8,960.73
$6,885.62
$5,737.80
$3,737.80
$2,134.66
$1,580.89
$0
2720 South J Street Tacoma, WA 98409

Phone: (253) 627-3794 email: (davis@evergreenfire.com Fax: (253) 572-9315
Date: August 13,2010

Jason Shipman
Re: Employment Verification for Jason Shipman

DOH: 06/12/2006
As of July 26,2010, Jason Shipman has been re-assigned to a permanent position with our Federal
Fire Alarm Program in Washington State. Jason is a Senior Low Voltage Journeyman and will work
on or around Ft. Lewis Washington. Please contact me if you need additional information.
Thank you,
Human Resources Director

Evergreen Fire and Security
Cc: Employee File
Fire Alarm intrusion Detection CCTV Access Control Mass Notification
Page 1 of 1
Zoom:
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N E G O T IA B L E
Bills I paid for Jennifer she owes me for
Puget Sound Energy
Progressive insirance
I transferred service it was a final bill after the $553.77 tax return
$159.28 payment
She took me off the policy but it was still in my name so I had to pay
$95.97 final bill
House Payment fo march, $ 1603.14 + 2
She lives there but I paid this with tax return money; half should be
$801.57 reimbursed to me for fair split of return funds
Qwest phone
She paid her phone bill with my checking info from child support
checks. Along with several other of her bills I had charges reversed at
$146.02 my bank on all the others.
Qwest Phone
Overdraft fees $35.00 x 2
TOTAL
$5.13 another final Qwest bill for her phone

$70.00 Fees due to her using my account to pay her bills.
$1,277.97
C u s to m e r
PUGET SOUND ENERGY
JASON W SHIPMAN
The Energy To Do Great Things
Page 1 o f 3
Account No.
STATEMENT SUMMARY AS OF MAR 12, 2010

Balance as of last billing
Thank you for your payments)
Deposit Applied
Deposit Interest Applied
Balance Forward
994-232-498-0
Account Balance
$338.90
$553.77C R
$135,00C R
____________$.13CR
$350.00C R
Current Charges
Deposit Charges
$159,28
$350.00
CURRENT TOTAL AS OF MAR 12, 2010
$159.28
Statement Due Date Apr 01, 2010

Electric Detail:
Rate/
Dates
07E
02/13/10
02/13/10
02/13/10
02/13/10
02/13/10
02/ 13/10
02/13/10
Meter
Number
AMOUNT DUE THIS STATEMENT
9306 116TH ST E, PUYALLUP

Pres
Read
Prev
Read
Pres
Date
Prev
Date
U096608456 66962 66665

02/26
02/12
02/26/10 Basic C h arge
02/26/10 Energy C h arge
02/26/10 Electric Conservation Program Charge
02/26/10 Power Cost A djustm ent
02/26/10 Energy Exchange Credit
02/26/10 W ind Power Production Credit
02/26/10 M e rg e r C redit
KWH
(Usage)
Mult
1
297
297
297
297
297
297
297
KWHS
KWHS
KWHS
KWHS
@
@
@
@
kw hs @
KWHS @
Bill
Demand
KVAR
Hours
Code
Amou nt
ACTL
$.084786 Per KWH
$.002833Per KWH
$.00 Per KWH
$.007269CR Per KWH
$.001684CR Per KWH
$.000374CR Per KWH
$7.00
$25.18
$.84
$.00
$2.16CR
$.50CR
$.11CR
Current Electricity Charges

$30.25
This is the final charge for your current electric service at this address.
A late fee of 1% will apply to overdue charges, if any. Please see the reverse side for details on
late payment charges.
A 3.873% state utility tax is included in electric rates charged.
Description of One-Time Charges
Reference #
Amount
Late Pay Fee
9942324906752
$.79
Total of One-Time Charges
$.79
For information, emergencies, to report an outage or for changes to your account, please call 1-888-225-5773.
When paying in person, please present both portions. When matting remittance, please maif'to Puget Sound Energy, BOT-01H, P.O. Box 91269, Bellevue, WA 98009-9269
Customer
PUGET SOUND ENERGY
JASON W SHIPM AN
The Energy To Do Great Things
Page 1 o f 2
Account No.
Account Balance
$47.09
$47.09CR
$.00
STATEMENT SUMMARY AS OF JUN 11, 2010

Thank you for your payment(s)
Balance Forward
Current Charges
Budget Amount
$39.73
CURRENT TOTAL AS OF JUN 11, 2010
$39.73
17E
$147.00
AMOUNT DUE THIS STATEMENT
$39.73
$39.73
Current Charges
Balance, as of JUN 11, 2010
$147.00
Amount
$.00
$.00
$.00
$147.00
$147.00
Budget Amount
Budget Payment Due
9403 355TH ST S, ROY
Meter
Number
H096185718
05/12/10 06/10/10
05/12/10 06/10/10
05/12/10 06/10/10
05/ 12/ 1006 / 10/10
05/12/10 06/10/10
05/12/10 06/10/10
05/12/10 06/ 10/10
05/12/10 06/10/10
$.00
Summary of Electric Budget Payment Plants)

Amount
Budget Balance
$.00
Payments Applied
$.00
$.00
Balance Forward
Actual Balance
Payments Applied
Balance Forward
Rate/
Dates
$.00
$147.00
Statement Due Date Jul 01, 2010
Electric Detail:
994*232-498-0
Amount to Pay
$47.09
$47.09CR
Pres
Read
42822
Prev
Read
42433
Pres
Date
06/10
Prev
Date
05/11
Basic Charge
Energy Charge
Electric Conservation Program Charge
Power Cost Adjustment
Energy Exchange Credit
Wind Power Production Credit
Merger Credit
Regulatory Asset Tracker
KWH
(Usage)
Mult
1
Bill
Demand
KVAR
Hours
Code
ACTL
389
389 KWHS
389KWHS
389 KWHS
389 KWHS
389 KWHS
389 KWHS
389 KWHS
@
@
@
@
@
@
@
Amount
$.085544 Per KWH

$.004617 Per KWH
$.00 Per KWH
$.007269CR Per KWH
$.001684CR Per KWH
$.000374CR Per KWH
$.002684 Per KWH
$7.25
$33.28
$1.80
$.00
S2.83CR
$.66CR
S.15CR
$1.04
Current Electricity Charges

$39.73
Current Budget Amount
$147.00
A late fee of 1% will apply to overdue charges, if any. Please see the reverse side for details on
late payment charges.
A 3.873% state utility tax is included in electric rates charged.
For information, emergencies, to report an outage or for changes to your account, please call 1-880-225-5773.
When paying in person, please present both portions. When mailing remittance, please mail to Puget Sound Energy, BOT-01H, P.O. Box 91269, Bellevue, WA 98009-9263
PROGRESSIVE
P.O, BOX 31260
TAMPA, FL 33631
PRO G RESSIVE'
DIRECT
015717
JASON W SHIPMAN
Policy Number: 66988055-4

Underwritten by:
Progressive Direct Insurance Co
Date of Mailing: March 21, 2010
Policy Period: Dec 6, 2009 - Jun 6, 2010
JASON W SHIPMAN
9306 116TH STE
PUYALLUP, WA 98373
Page 1 of 1
Online Service
progressive.com
Customer Service
1-800-776-4737
Final Bill
Please note that you no longer have insurance with us, effective February 28, 2010.
Your policy canceled because we did not receive your payment by its due date. However, there is still a balance due on
your canceled term. Please see your payment summary below for more information. Please know that your payment will
satisfy the amount that is past due, but it will not reinstate your policy. Failure to pay the amount owed by the due date
may result in your referral to a collections agency.
Total
Total amount paid
Total amount due
Due date :
If you have any questions, please call Customer Service.
$324.00
-228.03
$95.97 f a (
Y: ^ U p o n receipt
E-
ijl,
.
/ ^
Q w e s t.- ^ S p i r i t o1 S e r v i c e *
Confirmation Number:
Qwest
P.0, BOX 2619
Omaha NE 68103-2560
Confirm Notice
10031512573
March 15, 2010
253-845-2268-373
AB 01 007522 62892 H 28 B
JENNIFER SHIPMAN
PO BOX 167
MCKENNA WA 98558-0167
0075221/1
CONFIRMATION NOTICE
Thank you for using the Qwest Electronic Funds Transfer Payment option.
On March 15, 2010 you authorized Qwest to automatically withdraw funds in the amount of $150.02
from your financial institution's checking account. This authorization includes a $146.02
payment that w ill be credited to your Qwest telephone account number 253-845-2268-373,
and a $4,00 convenience fee.
If you have any questions regarding this information, please call our Customer Service Center at
1-800-244-1111.
Revised Closing
Statement
Qwesc
S p irit o f Service
i'i:!<::
Previous BUI Mar 17, 2010
Account Number; 253 845-2268F 373R

Bill Date:
April 1,2010
Customer Service; 1 800-423-8994
1 800-573-1311
Repair:
Online:
qwest.com
INCLUDED IN YOUR STATEMENT
Phone
Service
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Important Message
This statement reflects additional charges or credits not previously billed to your account A summary of these charges and
credits is provided in this statement.
= Total Amount
Due
$5.13
Due Upon Receipt
Please fold, tear here and return the portion below with your payment.
0363141/2
JASON SHIPMAN
E-FILED
August 18 2010 10:59 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
WASHINGTON STATE CHILD SUPPORT SCHEDULE WORKSHEETS

[ X]Proposed by [ X ] JASON WILLIAM SHIPMAN [ ] State of WA [ ] O ther____________________ .(CSWP)
Or, [ ]Signed by the Judicial/Reviewing Officer, (CSW)
MOTHER
COUNTY

PIERCE
FATHER
CASE NO.

10-3-00961-1
CHILD SUPPORT ORDER SUMMARY REPORT

judicial/reviewing officer.
A. The order [ ] does [ X ] does not replace a prior court or adminstrative order.
B. The STANDARD CALCULATION listed on line 17 of the Worksheet for the paying parent is: $780.02.
C. The TRANSFER AMOUNT ordered by the Court from the Order of Child Support
is: $780.02 to be paid by the [ ] mother [ X ] father.
D. The Court deviated (changed) from the STANDARD CALCULATION for the following reasons:
[X ] Does not apply
[ ] Nonrecurring income
[ 3 Sources of income and tax planning
[ ] Split custody
[ ] Residential schedule (including shared custody)
[ ] Children from other relationships for whom the parent owes support
[ ] High debt not voluntarily incurred and high expenses for the child(ren)
[ ] Other (please describe):
E. Income for the Father is [ ] imputed [ X ] actual income.

Income for the Mother is [ ] imputed [ X ] actual income.
Income was imputed for the following reasons:
F. If applicable: [ ] All health care, day care and special child rearing expenses are included in the worksheets in
Part III.
WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2010 page 1 of
Original

8/18/2010
9i10AM
WORKSHEETS
Children and Ages: Hunter 9, Tyler 16
{child ages calculated using August 18, 2010)
Part I: in co m e (See Instructions, page 6)
Father
Mother
$4,299.00
$6,192.00
$0.00
$0.00
c. Business Income
$0,00
$0.00
$0.00
$0.00
e. Other Income
$0,00
$0.00
f. Imputed Income
$0.00
$0.00
$4,299.00
$6,192,00
$670.65
$1,002.09
b. FICA (Social Security plus Medicare)/Self-Employment Taxes
g. Total Monthly Gross Income (add lines 1a through 1f)

$328.87
$473.69
$5.00
$0.00
d. Mandatory Union/Professiona! Dues
$54.00
$80.00
$0.00
$0.00
$0,00
$0.00
g. Maintenance Paid
$0.00
$0.00
$0.00
$0.00
$1,058,52
$1,555.78
$3,240.48
$4,636.22
i. Total Deductions from Gross Income (add lines 2a through 2h)

3. Monthly Net Income (line 1g minus line 2i)
(add parent's monthly net incomes from line 3)
5. Basic Child Support Obligation (enter total amount in box -->)

Hunter
$848
Tyler
$1,048
(presumptive)
41.14%

(each parent's net income from line 3 divided by line 4)
58.86%
Part II: B asic C hild S u p p o rt O b lig a tio n (See instructions, page 7)
7. Each Parents Basic Child Support Obligation without consideration of

low income limitations. (Multiply each number on line 6 by line 5)
$780.02
$1,115.98
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$780.02
$1,115.98
8. Calculating low income limitations: Fill in only those that apply.

Self-Support Reserve: (125% of the Federal Poverty Guideline)
a. Is Combined Net Income Less than $1.000?
enter the presumptive $50 per child.
If ves. for each parent
b. Is Monthly Net Income Less Than Self-suDDort Reserve? If ves, for that
parent enter the presumptive $50 per child.
c. Is Monthly Net Income Greater Than Self-support Reserve? If ves, for each
parent subtract the self-support reserve from line 3. If that amount is less than
line 7, enter that amount or the presumptive $50 per child, whichever is greater
9. Each parent's basic support obligation after calculating applicable limitations.
For each parent enter the lowest amount from line 7, 8a - 8c. but not less than
the presumptive $50 per child.
Part III: Health Care, Day Care, and Special Child Rearing Expenses
(See instructions, page 8)

Father
10 Health Care Expenses
Mother
$0,00
$0.00
$0,00
$0.00
c. Total Monthy Health Care Expenses (line 10a plus line 10b)
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00

(add parents's totals from line 10c)
$0.00
$0.00
$0.00
$0.00
$0.00
$780.02
$1,115,98
$0.00
$0.00
$0.00
$0.00
e. Total Day Care and Special Expenses (add lines 11a through 11 d)
12. Combined Monthly Total of Day Care and Special Expenses
(add parent's day care and special expenses from line 11 e)
1
13. Total Health Care, Day Care, and Special Expenses
(line 10d plus line 12)
14, Each Parent's Obligation for Health Care, Day Care, and Special Expenses
(multiply each number on line 6 by line 13)
Part IV: Gross C hild Support O bligation

Part V: Child Support C redits

$0.00
$0.00
$0.00
$0.00
Part VI: Standard C alculation/P resum ptive Transfer Payment (See instructions, page 9)
17. Standard Calculation (line 15 minus 16d or $50 per child whichever is greater)
$780.02
$1,115,98
$1,458.22
$2,086,30
$195.01
$279.00
Part VII: A dditional Inform ational C alculations

18. 45% of each parent's net income from line 3
19. 25% of each parents basic support obligation from line 9
Part VIII: Additional Factors fo r C onsideration (See Instructions, page 9)

20. Household Assets (List the estimated present value of all major household assets.)
a. Real Estate
b. Investments
f. Other (describe)
21, Household Debt (List liens against household assets, extaordinary debt)

a. Income of Current Spouse or Domestic Partner (if not the other parent of this action.)
Name
Name
b. Income of Other Adults in Household
Name
Name
c. Gross income from overtime or second jobs the party is
asking the court to exclude per instructions, page 10
d. Income of Children (If considered extraordinary)
Name
Name
Name
Name
Program
Program
Fathers
Household
Mothers
Household
24. Child Support Owed Monthly, for Biological or Legal Child(ren)
Father's
Household
Mothers
Household
25. Other Children Living In Each Household (First names and ages)
26. Other Factors For Consideration (attach additional pages as necessary)

Mother's income based on 2009 W-2.
Father's income based on YTD as of 8/8/10, divided by 31 weeks, X 52 weeks, divided by 12 months.
Signature and Dates

I declare, under penalty of perjury under the laws of the State of Washington, the information
contained in these Worksheets is complete, true and correct.
Father's signature
Mother's signature
Date
Date
City
Judge/Reviewing Officer
City
Date
2001 -10 THOMAS E. JAFFE
E-FILED
August 18 2010 10:59 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3- 30961-1

NO. 10-3-00961-1
Petitioner,
PARENTING PLANPROPOSED (PPP)
vs.
Respondent.
GENERAL INFORMATION
1.1

proposed by Respondent Father
IT IS HEREBY ORDERED, ADJUDGED AND DECREED:

1.2

Name
Age
TYLER
16
HUNTER
9
II. BASIS FOR RESTRICTIONS
2.1
PARENTAL CONDUCT (RCW 26.09.191(1), (2)).

Does not apply.
PARENTING PLAN - PROPOSED

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

.
'
Attorneys at Law
Lakewood, WA 98499
(253)581-0660
2.2
OTHER FACTORS (RCW 26.09.191(3)).

Does not apply.
III. RESIDENTIAL SCHEDULE

3.1
SCHEDULE FOR CHILDREN UNDER SCHOOL AGE.

3.2
SCHOOL SCHEDULE.
Upon enrollment in school, the children shall reside with the mother, except for
the following days and times when the children will reside with or be with the
other parent:
From 5:00 p.m. Friday to 7:00 p.m. Sunday every other weekend, beginning the
weekend of August 27, 2010.
3.3
SCHEDULE FOR WINTER VACATION.

The winter vacation shall be split equally between the parents, with the father
having the first half in even-numbered years and the mother having the first half
in odd-numbered years.
3.4
SCHEDULE FOR OTHER SCHOOL BREAKS.

Same as 3.3.
3.5
SUMMER SCHEDULE.
Upon completion of the school year, the children shall reside with the mother,
except for the following days and times when the children will reside with or be
with the other parent:
Father shall have, in addition to the residential time described in paragraph 3.2,
five weeks residential time during the summer break. Father shall notify mother
by March 1 of each year which five weeks, which may or may not be
consecutive, he selects.

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

A ttorneys at Law

Lakewood , WA 98499
(253)581-0660
3.6
VACATION WITH PARENTS.

The schedule for vacation with parents is as follows:
Each parent shall be entitled to two consecutive weeks vacation time with the
children each year, scheduled by notifying the other parent of the selected vacation time
in writing by March 1.
3.7
SCHEDULE FOR HOLIDAYS.
With Mother
(Specify whether
Odd/Even/Every)
New Years Day
Martin Luther King Day
Presidents Day
Easter
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
New Years Eve
With Father
(Specify whether
Odd/Even/Every)
ODD
EVEN
ODD
ODD
EVEN
ODD
EVEN
ODD
ODD
ODD
EVEN
EVEN
EVEN
ODD
EVEN
EVEN
ODD
EVEN
ODD
EVEN
EVEN
EVEN
ODD
ODD
For purposes of this parenting plan, a holiday shall begin at 8:00 a.m. and end at
10:00 p.m.
3.8
SCHEDULE FOR SPECIAL OCCASIONS.
The residential schedule for the children for the following special occasions is as
follows:

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

Attorneys at Law
Lakewood, WA 98499
(253)581-0660
With Mother
(Specify whether
Odd/Even/Every)
2
3
4
5
cO
7
Mothers Day
EVERY
Fathers Day
Mothers Birthday
EVERY
Fathers Birthday
Childrens Birthdays
EVEN
*Fathers work schedule permitting.
9
3.9
11
13
14
16
17
18
3.10
20
22
23
PRIORITIES UNDER THE RESIDENTIAL SCHEDULE.
1.
2.
3.
4.
5.
6.
7.
15
21
EVERY*
ODD*
If the residential schedule, paragraphs 3.1 - 3.8, results in a conflict where the
children are scheduled to be with both parents at the same time, the conflict shall
be resolved by priority begin given as follows, with 1 being given the highest
priority:
12
19
EVERY
10:00 p.m.
10
With Father
(Specify whether
Odd/Even/Every)
school schedule (3.1, 3.2)

school breaks (3.4)
holidays (3.7)
RESTRICTIONS.
Does not apply because there are no limiting factors in paragraphs 2.1 or 2.2.
3.11
TRANSPORTATION ARRANGEMENTS.
Transportation costs are included in the Child Support Worksheets and/or the
Order of Child Support and should not be included here.
Transportation arrangements for the children between parents shall be as
follows:
Receiving parent shall provide transportation to the exchange point.
nI
WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194
A ttorneys at Law
Lakewood, WA 98499
(253)581-0660
3.12
DESIGNATION OF CUSTODIAN.
The children named in this parenting plan are scheduled to reside the majority of
the time with the mother. This parent is designated the custodian of the children
solely for purposes of all other state and federal statutes which require a
designation or determination of custody. This designation shall not affect either
parents rights and responsibilities under this parenting plan.
3.13
OTHER
a.
It is the responsibility of the parent scheduled to have the children to

arrange suitable alternative care, if necessary, and pay for the needed
care.
b.
Each parent shall notify the other at least forty-eight (48) hours in
advance if he or she is unable to comply with the regular schedule.
c.
Each parent shall keep the other apprised of his or her current residence
address and residence telephone number.
d.
Both parents shall have unlimited access to the childrens school, day
care, and medical records. Neither parent may revoke this provision by
telling the providers to disobey this court order.
e.
Telephone Access
The children shall have reasonable telephone privileges with the parent
with whom the children are not then residing, without interference of the
residential parent.
f.
Participation in Childrens Events

1.
The children shall be accompanied by the parent with whom the
children are residing at the time of a given social event. The other parent
shall not be limited from attendance at that event, providing said
attendance by the non-residential parent is not disruptive to the other
participants.
2.
Each parent shall be responsible for keeping themselves advised
of school, athletic, and social events in which the children participate.
Both parents may participate in school activities for the children, such as
an open house, attendance at an athletic event, etc.

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194
Attorneys at Law
Lakewood, WA 98499
(253)581-0660
3.14 SUMMARY OF RCW 26.09.430 - .480, REGARDING RELOCATION OF A

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.)
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 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.
childs relocation whether or not he or she received proper notice.
(Objection to Relocation/Petition for Modification of Custody Decree/Parenting
WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194
Attorneys at Law
Lakewood, WA 98499
(253) 581-0660
Plan/Residential Schedule). The objection must be served on all persons entitled to time
with the child.

the objection, the relocating person shall not move the child before the hearing unless
there is a clear, immediate and unreasonable risk to the health or safety of a person or a
child.
WARNING: VIOLATION OF THE RESIDENTIAL PROVISIONS OF THIS
ORDER WITH ACTUAL KNOWLEDGE OF ITS TERMS IS PUNISHABLE BY
CONTEMPT OF COURT, AND MAY BE A CRIMINAL OFFENSE UNDER RCW
9A.40.070(2). VIOLATION OF THIS ORDER MAY SUBJECT VIOLATOR TO
ARREST.
IV. DECISIONMAKING
4.1
DAY TO DAY DECISIONS.

Each parent shall make decisions regarding the day-to-day care and control of
each child while the child is residing with that parent. Regardless of the
allocation of decision making in this parenting plan, either parent may make
emergency decisions affecting the health or safety of the children.
4.2
MAJOR DECISIONS.
Education decisions
Non-emergency health care
Religious upbringing
4.3
joint
joint
joint
RESTRICTIONS IN DECISION MAKING.

Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2
above.
V. DISPUTE RESOLUTION
Disputes between the parties, other than child support disputes, shall be
submitted to:

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26,09,016;.187; .194
Attorneys at Law
Lakewood, WA 98499
(253)581-0660
mediation by Pierce County Center for Dispute Resolution.

based on each partys proportional share of income from line 6 of the child
support worksheets.
The counseling, mediation, or arbitration dispute resolution process shall be
commenced by notifying the other party by written request, certified mail/return
receipt.
(a)
(b)
(c)
(d)
(e)

Unless an emergency exists, the parents shall use the designated process
to resolve disputes relating to implementation of the plan, except those
related to financial support.
A written record shall be prepared of any agreement reached in
counseling or mediation and of each arbitration award and shall be
provided to each party.
If the court finds that a parent has used or frustrated the dispute resolution
process without good reason, the court shall award attorneys fees and
financial sanctions to the other parent.
The parties have the right of review from the dispute resolution process to
the superior court.
VI.
OTHER PROVISIONS

VII.
DECLARATION FOR 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.
Date and Place of Signature

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

Attorneys at Law
Lakewood, WA 98499
(253)581-0660
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August 24, 2010 9:30 AM
(o;
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For Respondent
For Petitioner
RE:
4 a B .W b
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\T T \ g / 0 | VA <L_________
|0 w
*ovcf*\
^Sfju vc)
Motion - Temporary Order

DIANAi LYNN KIESEL
n
Clerk:
Courtroom number: 117
Calendar:C2 - SHOW CAUSE/FAMILY LAW
Run date/time 08/24/10 8:32
txcrtrpt.pbt dJoumai_entry_showcause_report
>
9524
8 /2 5 /2 3 1 8
-00961-1
34896172
OB-25-10
PPT
5
IN THE SUPERIOR COURT OF THE STATE OF WASHING"
7
8
9

Petitioner,
10

Respondent.
13
14
15
PARENTING PLAN
-TEMPORARY (PPT)
vs.
11
12
NO. 10-3-00961-1
GENERAL INFORMATION
1.1
16
proposed by Respondent Father
17
18
19
IT IS HEREBY ORDERED, ADJUDGED AND DECREED:

1.2
20
Name
Age
21
TYLER
16
22
HUNTER
23
II. BASIS FOR RESTRICTIONS
24
25
2.1
PARENTAL CONDUCT (RCW 26.09.191(1), (2)).

Does not apply.
PARENTING PLAN TEMPORARY - 1

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

Attorneys at Law
5920 100th Street S.W., Sure 25
Lakewood, WA 98499
(253) 581-0660
9524
I
2
3
2.2
OTHER FACTORS (RCW 26.09.191(3)).

Does not apply.
5
III.
3.1
8
9
RESIDENTIAL SCHEDULE
SCHEDULE FOR CHILDREN UNDER SCHOOL AGE.

3.2
10
SCHOOL SCHEDULE.
Upon enrollment in school, the children shall reside with the mother, except for
the following days and times when the children will reside with or be with the
other parent:
11
12
From 5:00 p.m. Friday to 7:00 p.m. Sunday every other weekend, beginning the
weekend of Awgust-27, 2010. ^
mu
V b cxd loJU
13
14
3.3
^
*
h> ( K <
SCHEDULE FOR WINTER VACATION1
r^
15
The winter vacation shall be split equally between the parents, with the father
having the first half in even-numbered years and the mother having the first half
in odd-numbered years.
16
17
18
3.4
19
20
21
22
SCHEDULE FOR OTHER SCHOOL BREAKS.

Same as 3.3.
3.5
SUMMER SCHEDULE.
Upon completion of the school year, the children shall reside with the mother,
except for the following days and times when the children will reside
23
24
25
*t Father shall have, in -addition to tho rocidontiul time desuibcd in naragrapkA^.

a r m five
( weeks residential time during the summer break. Father shall notify mother^
L j) by March-1 of each year which five weeks, Which may ui iriqy nut be
.consecutive, hp
H** 5 W
lc S<^M XuU .
du&A *\>V
CfXv'i'Oi'V
( -fW m ty b u j
PARENTING PLAN TEMPORARY - 2 S o\^ (J m U s \v JL
L gy,***
WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194
FAUBION, JOHNSON, REEDER & FRALEY, P.S
U
scu x A
s ivJX vJ)
0uiJ(
..
I V t C
, -Ft*.
Uj U ^
A ttorneys at Law

j .
Lakewood, WA 98499
HaMjs'
7/
v i> |
9524
I
2
3
Tfcr^ÛATATlON WITH PA1
f t
The schedjiie-foi vacnTTon with parents is as follows:
(V I
Each parent shall be entitlecftoTWo-eengeeutive weeks vacation time with the

ch ild re n each veai>^diudHllid liv noli fvinlfffie other parent of the selected vacation time
in writing by Rafch-k
3.7
SCHEDULE FOR HOLIDAYS.
10
With Mother
(Specify whether
Odd/Even/Every)
11
With Father
(Specify whether
Odd/Even/Every)
12
13
14
15
16
17
18
19
New Years Day

Presidents Day
Easter
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christmas Eve
Christmas Day
New Years Eve
20
ODD
EVEN
ODD
ODD
EVEN
ODD
EVEN
ODD
ODD
ODD
EVEN
EVEN
EVEN
ODD
EVEN
EVEN
ODD
EVEN
ODD
EVEN
EVEN
EVEN
ODD
ODD
10:00 p.m.
21
22
23
3.8
24
The residential schedule for the children for the following special occasions is as
follows:
25
SCHEDULE FOR SPECIAL OCCASIONS.

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

A tto rne ys a t L aw
5920 100th Street S.W., SurrE 25

LAKEWOOD, WA 98499
(253) 581-0660
1
With Mother
(Specify whether
Odd/Even/Every)
3
4
5
6
With Father
(Specify whether
Odd/Even/Every)
EVERY
Mothers Day
Fathers Day
EVERY
Mothers Birthday
Fathers Birthday
EVEN
Childrens Birthdays
^Fathers work schedule permitting.
EVERY
EVERY*
ODD*
10:00 p.m.
9
10
3.9
11
If the residential schedule, paragraphs 3.1 - 3.8, results in a conflict where the
children are scheduled to be with both parents at the same time, the conflict shall
be resolved by priority begin given as follows, with 1 being given the highest
priority:
12
13
14
1.
2.
3.
4.
5.
6.
7.
15
16
17
18
19
3.10
20
21
22
23
24
25
PRIORITIES UNDER THE RESIDENTIAL SCHEDULE.
school schedule (3.1, 3.2)

school breaks (3.4)
holidays (3.7)
RESTRICTIONS.
3.11
TRANSPORTATION ARRANGEMENTS.
Transportation costs are included in the Child Support Worksheets and/or the
Order of Child Support and should not be included here.
Transportation arrangements for the children between parents shall be as
follows:

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

5920 100th S tr e e t S.W ., S uite 25

La k e w o o d , W A 98499
(253) 581-0660
9524
8 ^ 2 5 2 :2 0 1 :3
1
2
3
3.12
DESIGNATION OF CUSTODIAN.
The children named in this parenting plan are scheduled to reside the majority of
the time with the mother. This parent is designated the custodian of the children
solely for purposes of all other state and federal statutes which require a
designation or determination of custody. This designation shall not affect either
parent's rights and responsibilities under this parenting plan.
5
6
7
3.13
OTHER
a.
It is the responsibility of the parent scheduled to have the children to

arrange suitable alternative care, if necessary, and pay for the needed
care.
b.
Each parent shall notify the other at least forty-eight (48) hours in
advance if he or she is unable to comply with the regular schedule.
c.
Each parent shall keep the other apprised of his or her current residence
address and residence telephone number.
d.
Both parents shall have unlimited access to the childrens school, day
care, and medical records. Neither parent may revoke this provision by
telling the providers to disobey this court order.
e.
Telephone Access
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The children shall have reasonable telephone privileges with the parent
with whom the children are not then residing, without interference of the
residential parent.
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f.

1.
The children shall be accompanied by the parent with whom the
children are residing at the time of a given social event. The other parent
shall not be limited from attendance at that event, providing said
participants.
2.
Each parent shall be responsible for keeping themselves advised
of school, athletic, and social events in which the children participate.
Both parents may participate in school activities for the children, such as
an open house, attendance at an athletic event, etc.

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

A t to r n e ys a t Law
5920 100th S t r eet S.W., S uite 25

L a k e w o o d , WA 98499
(253) 581-0660
9bZ4
t t ^ b z . 2 g ; l 'i
1
2
3
4
3.14 SUMMARY OF RCW 26.09.430 - .480, REGARDING RELOCATION OF A

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 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.)
notice by any reasonable means. A person entitled to time with the child may not object
to the move but may ask for modification under RCW 26.09.260.
Notice may be delayed for 2 1 days if the relocating person is entering a domestic
violence shelter or is moving to avoid a clear, immediate and unreasonable risk to health
and safety.
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22
If no objection is filed within 30 days after service of the notice of intended relocation,
the relocation will be permitted and the proposed revised residential schedule may be
confirmed.
23
24
25
childs relocation whether or not he or she received proper notice.
(Objection to Relocation/Petition for Modification of Custody Decree/Parenting
Plan/Residential Schedule). The objection must be served on all persons entitled to time
WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

Attorneys at Law
Lakewood, WA 98499
(253) 581-0660
3 L- Z 4
H /Z b /Z B lfl
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with the child.
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the objection, the relocating person shall not move the child before the hearing unless
there is a clear, immediate and unreasonable risk to the health or safety of a person or a
child.
WARNING: VIOLATION OF THE RESIDENTIAL PROVISIONS OF THIS
ORDER WITH ACTUAL KNOWLEDGE OF ITS TERMS IS PUNISHABLE BY
CONTEMPT OF COURT, AND MAY BE A CRIMINAL OFFENSE UNDER RCW
9A.40.070(2). VIOLATION OF THIS ORDER MAY SUBJECT VIOLATOR TO
ARREST.
11
IV. DECISIONMAKING
12
13
4.1
Each parent shall make decisions regarding the day-to-day care and control of
each child while the child is residing with that parent. Regardless of the
allocation of decision making in this parenting plan, either parent may make
emergency decisions affecting the health or safety of the children.
14
15
16
17
DAY TO DAY DECISIONS.
4.2
MAJOR DECISIONS.
18
19
Education decisions
20
21
4.3
joint
joint
joint
RESTRICTIONS IN DECISION MAKING.
22
23
24
25
Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2
above.
V. DISPUTE RESOLUTION
Disputes between the parties, other than child support disputes, shall be
submitted to:
WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

Attorneys at Law
Lakewood, WA 98499
(253) 581-0660
1
2
mediation by Pierce County Center for Dispute Resolution.
3
4
5
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based on each partys proportional share of income from line 6 of the child
support worksheets.
The counseling, mediation, or arbitration dispute resolution process shall be
commenced by notifying the other party by written request, certified mail/return
receipt.
8
9
10

(a)
(b)
11
12
(c)
13
14
(d)
15
16
(e)

Unless an emergency exists, the parents shall use the designated process
to resolve disputes relating to implementation of the plan, except those
related to financial support.
A written record shall be prepared of any agreement reached in
counseling or mediation and of each arbitration award and shall be
provided to each party.
If the court finds that a parent has used or frustrated the dispute resolution
process without good reason, the court shall award attorneys fees and
financial sanctions to the other parent.
The parties have the right of review from the dispute resolution process to
the superior court.
17
VI. OTHER PROVISIONS
18

19
20
21
VII.
DECLARATION FOR PROPOSED PARENTING PLAN
Does not apply.
22
VIII.
ORDER BY THE COURT
23
24
25
It is ordered, adjudged and decreed that the parenting plan set forth above is
adopted and approved as an order of this court.
WARNING: Violation of residential provisions of this order with actual
knowledge of its terms is punishable by contempt of court and may be a criminal
offense under RCW 9A.40.060(2) or RCW 9A.40.070(2). Violation of this

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

Attorneys at Law
5920 100th Street S.W.. SurTE 25
Lakewood, WA 98499
(253) 581-0660
9524
8 /25/2:918
1
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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.
5
6
7
8
9
10
If a parent fails to comply with a provision of this plan, the other parent=s
obligations under the plan are not affected. Before signing the final parenting
plan, the court consulted the judicial information system and databases, if
available, to determine the existence of any information and proceedings that are
relevant to the placement of the children.
DONE IN OPEN COURT this
2010.
11
12
13
14
COMMISSIONER
PRESENTED BY:
FAUBION, JOHNSON
& FRALEY, P.S.
15
16
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CLim^PfJOHNSQ
Of Attorneys for R
D IA N A LY N N K IE S E L
C O U R T C O M M IS S IO N E R
14794
TRY WAIVED
GREENE & LLOYD, PLLC
20
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Jennifer Shipman, Petitioner
ENE, WSBA 17499

etitioner
22
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25

WPF DR 01.0400 (6/2008)
RCW 26.09.181, 26.09.016; .187; .194

A t to r n e ys a t L aw
5920 100 th S t r e e t S.W.. SurrE 25

La k e w o o d , WA 98499
(253)581-0660
9524
18
1
2
10-3-00961-1
34 896178
TMORSW
08-25-10
3
4
5
6

County of Piercer
1
8
No. 10-3-00961-1
Petitioner,
and
10
Respondent.
Clerks Action Required
12
I. Judgment Summary
1.1
Judgment Summary for Non-Medical Expenses
14
[]
15
A.
B.
C.
16
17
18
19
20
[X] Temporary (TMORS)
11
13
Order of Child Support
D.
E.
F.
G.
H.
I.
J.
K.
L.
Does not apply.

Applies as follows:
Judgment creditor
___________
Judgment debtor
___________
Principal judgment amount (back child support/other obligations) $
from (date)____________ through (date) ______________
Interest to date ofjudgment
$
Attorney fees
$
Costs
$
Other recovery amount
$
Principal judgment shall bear interest at_________%per annum
Attorney fees, costs and other recovery amounts shall bear interest at______ %per annum
Attorney forjudgment c r e d i t o r ____________________________
Attorney forjudgment debtor
____________________________
Other:
21
22
23
(253) 770-0808, Fax (253) 770-0259
5524
1.2
3
4
D.
E.
F.
G.
H.
I.
J.
K.
5
6
7
8
48
Judgment Summary for Medical Support
[]
[]
A.
B,
C.
8^ 25 /2 8 1 8
Does not apply.

Applies as follows:
Judgment creditor
Judgment debtor
Judgment for medical support
$
from (date)
through (date)
$
Attorney fees
$
Costs
$
Principal iudgment shall bear interest at
%per annum
Attorney fees, costs and other recovery amounts shall bear interest at
Attorney for iudgment creditor
Attomev for iudement debtor
Other
%per annum
II. Basis
9
2.1
Type of Proceeding
10
This order is entered under a petition for dissolution of marriage or domestic partnership, legal
separation, or declaration concerning validity:
11
[]
[]
[X ]
[]
t]
[]
12
13
14
15
2.2
Child Support Worksheet

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.
16
17
decree of dissolution, legal separation or a declaration concerning validity.

order for modification of child support.
hearing for temporary child support.
order of adjustment.
order for modification of a custody decree or parenting plan.
other:
2.3
Other
18
19
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21
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23
(253) 770-0808, Fax (253) 770-0259
3S24
8 /2 5 /2 3 1 8
1
III. Findings and Order
2
3
It Is Ordered:
3.1
Child(ren) for Whom Support is Required
Name (first/last)
Age
TS
15
HS
6
7
8
9
10
II
12
13
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3.2
Person Paying Support (Obligor)

Name (first/last): Jason Shipman
Birth date: August 20, 1972
Service Address: P.O. Box 167, McKenna, WA 98558
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.
15
For purposes of this Order of Child Support, the support obligation is based upon the following
income:
16
A.
Actual Monthly Net Income: $

OR
17
18
19
B.
[]
Monthly net income after exclusion requiring findings:

Actual monthly gross income $ _____________ from which the court
excludes $ _____________ because the court finds that the obligor earned that
income from overtime or from second jobs beyond 40 hours per week averaged
over a 12-month period to:
[]
provide for a current familys needs; or
[]
retire past relationship debts; or
[]
retire child support debt; and
that the income will cease when the obligor has paid off his or her debts.
Monthly net income after allowed exclusion: $
(253) 770-0808, Fax (253) 770-0259
9524
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OR
2
C.
[]
The net income of the obligor is imputed at $ _____________ because:

[]
[]
[]
4
5
the obligors income is unknown.

the obligor is voluntarily unemployed.
the obligor is voluntarily underemployed.
The amount of imputed income is based on the following information in order of

priority. The court has used the first option for which there is information:
6
[]
[]
[]
7
8
[]
9
10
11
12
[]
13
[]
current rate of pay.

reliable historical rate of pay information.
Past earnings when there is incomplete or sporadic information of the
parents past earnings.
minimum wage in the jurisdiction where the parent lives at full-time
earnings because the parent:
[]
has a recent history of m inim um wage jobs,
[]
recently came off public assistance, general assistanceunemployable, supplemental security income, or disability
[]
was recently released from incarceration, or
[]
is a high school student.
Median Net Monthly Income Table.
Other:
14
15
3.3
16
17
18
Person Receiving Support (Obligee)

Name (first/last): Jennifer Kay Shipman
Birth date:
February 16,1974
Service Address: (You may list an address that is not your residential address where you agree
to accept legal documents.) 9306 116* St. E. Puyallup, WA 98373
19
20
The Obligee Must Immediately File With the Court and the Washington
State Child Support Registry and Update as Necessary the Confidential
Information Form Required by RCW 26.23.050.
21
22
23
The Obligee Shall Update the Information Required by Paragraph 3.3

information Continues as Long as any Monthly Support Remains Due or
any Unpaid Support Debt Remains Due Under This Order.
(253) 770-0808, Fax (253) 770-0259
SSZ4
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2
income;
^
A.
[x ]
Actual monthly Net Income:

OR
4
5
B.
[]

excludes $ _____________ because the court finds that the obligee earned that
[]
[]
[]
that the income will cease when the obligee has paid off his or her debts.
6
7
8
9
Monthly net income after allowed exclusion: $_______________ .
10
OR
11
C.
[]
The net income of the obligee is imputed at $ _____________ because:
12
[]
[]
[]
13
14
the obligees income is unknown.

the obligee is voluntarily unemployed.
the obligee is voluntarily underemployed.

15
17
[]
[]
[]
18
[]
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[]
t]
current rate of pay;

reliable historical rate of pay information;
parents past earnings;
[]
has a recent history of minimum wage jobs;
[]
recently came off public assistance, general assistanceunemployable, supplemental security income; or disability
[]
[]
is a high school student;
Other:

Mailing: P.O, Box 731063
(253) 770-0808, Fax (253) 770-0259
9524
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The obligor may be able to seek reimbursement for day care or special child rearing expenses not
actually incurred. RCW 26.19.080.
2
3
4
5
6
3.4
Service of Process
Service o f 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, m ay Be Allowed or Accepted as
Adequate in any Proceeding to Establish, Enforce or Modify a Child
Support Order Between the Parties by Delivery o f Written Notice to the
Obligor or Obligee at the Last Address Provided.
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(253) 770-0808, Fax (253) 770-0259
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3.5
8 /2 5 ^ 2 0 1 3
Transfer Paym ent
The obligor parent shall pay the following amounts per month for the following child(ren):
Name
TS
HS
Amount
$_____
$_____
5
6
Total Monthly Transfer Amount
[]
The parents combined monthly net income exceeds $12,000 and the court sets child
support in excess of the presumptive amount for $12,000 because:
[]
The court finds that the obligors child support obligations owed for all his or her
biological or legal children exceeds 45% of his or her net income and it is [ ] just
[ ] unjust to apply the 45% limitation based upon the best interests of the children) and
the circumstances of each parent as follows:
[]
If one of the children changes age brackets, the child support shall be as follows:
[]
This is a downward modification that has caused an overpayment of $

This amount shall be repaid or credited as follows:
[]
This is an upward modification that has caused an underpayment of $_

This amount shall be paid as follows:
[]
Other:
8
9
10
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19
The Obligor Parent's Privileges to Obtain or Maintain a License, Certificate,

Registration, Permit, Approval, or Other Similar Document Issued by a
(253) 770-0808, Fax (253) 770-0259
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49;
Licensing Entity Evidencing Admission to or Granting Authority to Engage

in a Profession, Occupation, Business, Industry, Recreational Pursuit, or
the Operation o f a Motor Vehicle may Be Denied or may Be Suspended if
the Obligor Parent is not in Compliance With This Support Order as
Provided in Chapter 74.20A Revised Code o f Washington.
1
2
3
3.6
1&D.WL
$~7z.&4 per month. (See Worksheet line 17.)
5
6
7
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9
10
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13
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17
18
19
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Standard C a lc u la tio i/
3.7
Reasons fo r Deviation From Standard Calculation
[x ] The child support amount ordered in paragraph 3.5 does not deviate from the standard
calculation.
[ ] The child support amount ordered in paragraph 3.5 deviates from the standard calculation for
the following reasons:
[} Income of a new spouse or new domestic partner of the parent requesting a deviation for
other reasons;
[ ] Income of other adults in the household of the parent requesting a deviation for other
reasons;
[ ] Child support actually paid or received for other child(ren) from other relationships;
[ ] Gifts;
[ ] Prizes;
[ ] Possession of wealth;
[ ] Extraordinary income of children);
[ ] Tax planning which results in greater benefit to the child(ren);
[ ] Income from overtime or second jobs that was excluded from income of the parent
requesting a deviation for other reasons;
[ ] A nonrecurring source of income;
[ ] Extraordinary debt not voluntarily incurred;
[ ] A significant disparity in the living costs of the parents due to conditions beyond their
control;
[ ] Special needs of disabled child(ren);
[ ] Special medical, educational, or psychological needs of the children);
[ ] The child(ren) spend(s) a significant amount of time with the parent who is obligated to
make a support transfer payment. The deviation does not result in insufficient funds in
the receiving parents household to meet the basic needs of the child(ren). The
children) do(es) not receive public assistance;
[ ] Children) from other relationships;
[ ] Costs incurred or anticipated to be incurred by the parents in compliance with courtordered reunification efforts or under a voluntary placement agreement with an agency
supervising the children);
[ ] The obligor has established that it is unjust to apply the presumptive minimum payment
of $50.00 per child;
[ ] The obligee has established that it is unjust to apply the self-support reserve.
22
[ ] Other reason(s) for deviation:
23
Street: 4115 S, Meridian
(253) 770-0808, Fax (253) 770-0259
9524
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496214
The factual basis for these reasons is as follows:
3.8
Reasons w hy R equest fo r Deviation W as Denied
[]
[x ]
[]
3.9
Does not apply. A deviation was ordered.

A deviation was not requested.
The deviation sought by the [ ] obligor [ ] obligee was denied because:
[]
no good reason exists to justify deviation,
f]
other:
Starting Date and Day to Be
Starting Date:
Day(s) of the month support is due:
3.10
Increm ental Paym ents
[]
[]
3.11
Does not apply.

This is a modification of child support. Pursuant to RCW 26.09.170 (9)(a) and (c), the
obligation has been modified by more than 30 percent and the change would cause
significant hardship. The increase in the child support obligation set forth in Paragraph
3.5 shall be implemented in two equal increments, one at the time of this order and the
second on (date)_____________ six months from the entry of this order.
Making Support Paym ents
Select Enforcement and Collection, Payment Services Only, or Direct Payment:

[x ]
Enforcement and collection: The Division of Child Support (DCS) provides support
enforcement services for this case because: [ ] this is a public assistance case, [] this is
a case in which a parent has requested services from DCS, [ ] a parent has signed the
application for services from DCS on the last page of this support order. (Check all
that apply.) Support payments shall be made to:
Washington State Support Registry
P. O. Box 45868
Olympia, WA 98504
Phone: l-800-922-4306 or
I-800-442-5437
[]
Payment services only: The Division of Child Support will process and keep a record of
all payments but will not take any collection action. Support payments shall be made to:
P. O. Box 45868
Olympia, WA 98504
Phone: 1-800-922-4306 or
1-800-442-5437
(253) 770-0808, Fax (253) 770-0259
9524
[]
8^ 2 5 /2 8 1 8
Direct Payment: Support payments shall be made directly to:

Name________________________________
Mailing Address________________________
3
A party required to make payments to the Washington State Support Registry will not receive
credit for a payment made to any other party or entity. The obligor parent shall keep the registry
informed whether he or she has access to health insurance coverage at reasonable cost and, if so,
to provide the health insurance policy information.
4
5
Any time the Division of Child Support is providing support enforcement services under
RCW 26.23.045, or if a party is applying for support enforcement services by signing the
application form on the bottom of the support order, the receiving parent might be required to
submit an accounting of how the support, including any cash medical support, is being spent to
benefit the children).
6
7
8
9
10
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13
3.12
W age W ithholding Action
Withholding action may be taken against wages, earnings, assets, or benefits, and liens enforced
against real and personal property under the child support statutes of this or any other state,
without further notice to the obligor parent at any time after entry of this order unless an
alternative provision is made below:
[If the court orders immediate wage withholding in a case where Division of Child Support does
not provide support enforcement services, a mandatory wage assignment under Chapter 26.18
RCW must be entered and support payments must be made to the Support Registry.]
[]
14
15
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.
[]
the Division of Child Support provides support enforcement services for this
case [see 3.11] and there is good cause [as stated below under "Good Cause"]
not to require immediate income withholding which is in the best interests of the
child(ren) and, in modification cases, previously ordered child support has been
timely paid.
[]
the Division of Child Support does not provide support enforcement services for
this case [see 3.11] and there is good cause [as stated below under "Good
Cause] not to require immediate income withholding.
16
17
18
19
20
21
Good Cause:
22
23
(253) 770-0808, Fax (253) 770-0259
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3.13
Term ination of Support
Support shall be paid:
[x ]
[]
5
[]
6
[]
7
[]
8
9
[]
3.14
10
provided that this is a temporary order, until a subsequent child support order is entered
by this court.
until the children) reach(es) the age of 18 or as long as the child(ren) remain(s) enrolled
in high school, whichever occurs last, except as otherwise provided below in Paragraph
3.14.
until the child(ren) reach(es) the age of 18, except as otherwise provided below in
Paragraph 3.14.
after the age of 18 for (name)___________________________ who is a dependent
adult child, until the child is capable of self-support and the necessity for support ceases.
until the obligation for post secondary support set forth in Paragraph 3.14 begins for the
child(ren).
Other:
Post Secondary Educational Support
12
The right to petition for post secondary support is reserved, provided that the right is
exercised before support terminates as set forth in paragraph 3.13.
The parents shall pay for the post secondary educational support of the child(ren). Post
secondary support provisions will be decided by agreement or by the court.
No post secondary educational support shall be required.
13
[]
11
14
15
16
17
18
3.15
Paym ent fo r Expenses not Included in the Transfer Paym ent
[]
Does not apply because all payments, except medical, are included in the transfer
The petitioner shall pay
% and the respondent M J f
%(each parents
proportional share of income from the Child Support Schedule Worksheet, line 6) of the
Vn
long distance transportation expenses.

X
19
22
23
iff/J
.)
A/i
thCT: U r '
$(LfnCO
Payments shall be made to [ ] the provider of the service [ ] the parent receiving the
transfer payment.
20
21
fa itx v A
[]
The obligor shall pay the following amounts each month the expense is incurred on
behalf of the child(ren) listed in Paragraph 3.1:
[]
day care: $
parent;
payable to the [ ] day care provider [ ] other

(253) 770*0808, Fax (253) 770-0259
^524
[]
[]
[x ]
8 /2 5 /2 0 1 0
educational expenses: $ _____________ payable to the [ ] educational

provider [ ] other parent;
long distance transportation: $ ________ ____ payable to the
[ ] transportation provider [ ] other parent.
other: Th^'obligor shall pay 50% of daycare.e:
err*5 sports activities expenses, as outlined in'
th
supptn^wecksheets, and _45JZ%-otextraordin< realth
5
3.16
Periodic Adjustm ent
6
7
[x ]
[]
Does not apply.

Child support shall be adjusted periodically as follows:
[]
Other:
8
9
10
3.17
Incom e Tax Exem ptions
Does not apply.

Tax exemptiorvs for the children) shall be allocated as follows;
11
12
The parents shall sign the federal income tax dependency exemption waiver.
Other:
13
14
15
3.18
Medical Support - Health Insurance
Each parent shall provide health insurance coverage for the child(ren) listed in paragraph 3.1, as
follows:
16
3.18.1 Health Insurance (either check box A, or complete sections B and C. Section D
applies in all cases.)
17
18
19
A. [ ] There is insufficient evidence for the court to determine which parent must provide
coverage and which parent must contribute a sum certain. Therefore, the court is not
specifying how insurance coverage shall be provided. The petitioners and respondents
medical support obligations may be enforced by the Division of Child Support or the
other parent under RCW 26.18.170 as described in paragraph 3.18.2, below.
OR
B.
Findings about insurance:

25% of the petitioners basic support obligation is $________ , (from line 19 of the
Worksheets). 25% of the respondents basic support obligation is $________ , (from
line 19 of the Worksheets).
(253) 770-0808, Fax (253) 770-0259
9524
[]
Insurance coverage for the child(ren) is available and accessible to:

[ ] the petitioner at $__________cost (child(ren)s portion of the premium, only);
and/or
[ ] the respondent at $_________cost (child(ren)s portion of the premium, only).
[]
Insurance coverage for the child(ren) is available but not accessible to:
[ ] the petitioner at $________ cost (child(ren)s portion of the premium, only) and/or
[ ] the respondent at $___________cost (child(ren)s portion of the premium, only).
[]
Neither parent has available or accessible insurance through an employer or union; but:
[ ] the petitioner is able to provide private coverage at a cost not to exceed 25% of the
petitioners basic support obligation; and/or
[ ] the respondent is able to provide private coverage at a cost not to exceed 25% of the
respondents basic support obligation.
f]
Both parties have available and accessible coverage for the child(ren). The court finds
that:
[ ] the petitioner, or
[ ] the respondent
has better coverage considering the needs of the child(ren), the cost and extent of each
parents coverage, and the accessibility of the coverage.
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3
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5
6
7
8
9
10
AND
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C.
Parties obligations (check the option(s) that apply for each parent):
(i)
Petitioner shall:
a.
[]
Provide health insurance coverage for the child(ren) that is available

through employment or is union-related so long as the cost of such
coverage does not exceed 25% of the petitioners basic support
obligation.
b.
[]
Provide health insurance coverage for the children) that is available

through employment or is union-related even though the cost of such
coverage exceeds 25% of the petitioners basic support obligation. It is
in the best interests of the child(ren) to provide such coverage despite
the cost because:
c.
[ ]
Provide private health insurance coverage for the children) so long as

the cost of such coverage does not exceed 25% of the petitioners basic
support obligation.
d.
[]
Pay $_______ towards the health insurance premium being paid by the
other parent (petitioners proportionate share of the premium, not to
exceed 25% of the petitioners basic support obligation). This payment
is only required if the petitioner is not providing insurance as described
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16
S /2 5 ^ 2 B lg
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18
19
20
21
22
23

(253) 770-0808, Fax (253) 770-0259
9524
8 ^ 2 5 /2 8 1 8
<
above.
1
e.
[x ]
3
4
Be excused from the responsibility to provide health insurance coverage

and from the responsibility to provide monthly payment towards the
premium because (check this box only if check box C(ii)(e) is not
checked below):
Respondent provides excellent health insurance coverage for the
children through his employer for which he does not have to
pay any premiums.
5
6
7
8
(ii)
Respondent shall:
a.
[x ]

through employment or is union-related so long as the cost of such
coverage does not exceed 25% of the respondents basic support
obligation.
b.
[ ]

through employment or is union-related even though the cost of such
coverage exceeds 25% of the respondents basic support obligation. It is
in the best interests of the child(ren) to provide such coverage despite
the cost because:
c.
[ ]
Provide private health insurance coverage for the child(ren) so long as

the cost of such coverage does not exceed 25% of the respondents basic
support obligation.
d.
[ ]
Pay $_____towards the health insurance premium being paid by the

other parent (respondents proportionate share of the premium, not to
exceed 25% of the respondents basic support obligation). This payment
is only required if the respondent is not providing insurance as described
above.
e.
[ ]
Be excused from the responsibility to provide health insurance coverage

and from the responsibility to provide monthly payment towards the
premium because (check this box only if check box C(i)(e) is not
checked above):
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10
11
12
13
14
15
16
17
18
19
20
21
D.
Both parties obligation:
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If the child(ren) are receiving state financed medical coverage, the Division of Child
Support may enforce the responsible parents monthly premium.
(253) 770-0808, Fax (253) 770-0259
'9524
8^25 ^zase
I
The parent(s) shall maintain health insurance coverage, if available for the child(ren)
listed in paragraph 3.1, until further order of the court or until health insurance is no
longer available through the parents employer or union and no conversion privileges
exist to continue coverage following termination of employment.
2
3
A parent who is required under this order to provide health insurance coverage is liable
for any covered health care costs for which that parent receives direct payment from an
insurer.
4
5
A parent who is required under this order to provide health insurance coverage shall
provide proof that such coverage is available or not available within 20 days of the entry
of this order to the other parent or the Washington State Support Registry if the parent
has been notified or ordered to make payments to the Washington State Support
Registry.
6
7
8
If proof that health insurance coverage is available or not available is not provided within
20 days, the parent seeking enforcement or the Department of Social and Health Services
may seek direct enforcement of the coverage through the other parents employer or
union without further notice to the other parent as provided under Chapter 26.18 RCW.
9
10
3.18.2 Change of Circumstances and Enforcement
11
A parent required to provide health insurance coverage must notify both the Division of Child
Support and the other parent when coverage terminates.
12
If the parents circumstances change, or if the court has not specified how medical support shall
be provided, the parents medical support obligations will be enforced as provided in
RCW 26.18.170. If a parent does not provide proof of accessible coverage for the children)
through private insurance, a parent may be required to satisfy his or her medical support
obligation by doing one of the following, listed in order of priority:
13
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1) Providing or maintaining health insurance coverage through the parents employment or

union at a cost not to exceed 25% of that parents basic support obligation;
2) Contributing the parents proportionate share of a monthly premium being paid by the
other parent for health insurance coverage for the children) listed in paragraph 3.1 of
this order, not to exceed 25% of the obligated parents basic support obligation; or
3) Contributing the parents proportionate share of a monthly premium paid by the state if
the child(ren) receives state-financed medical coverage through DSHS under RCW 74.09
for which there is an assignment.
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17
18
19
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.
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3.19
Uninsured Medical Expenses
Both parents have an obligation to pay their share of uninsured medical expenses.
(253) 770-0808, Pax (253) 770-0259
9524
The petitioner shall pay 54.3% of uninsured medical expenses (unless stated otherwise,
the petitioners proportional share of income from the Worksheet, line 6) and the
respondent shall pay 45.7% of uninsured medical expenses (unless stated otherwise, the
respondents proportional share of income from the Worksheet,
line 6).
1
2
3
4
8/2 S /-2 0 f*
3.20
Back Child S upport
[]
n
6
7
n
[]
n
8
9
10
No back child support is owed at this time.

Back child support that may be owed is not affected by this order.
(Name)
is awarded a iudgment against
in the amount of $
(name)
for back
child support for the period from (date)
through (date)
No back interest is owed at this time.
Back interest that may be owed is not affected by this order.
(Name)
is awarded a iudgment against
(name)
in the amount of $
through (date)
interest for the period from (date)
^ C ^ A p th e r: ^
for back
0/Y ^
11
12
3.21
13
Past Due Unpaid Medical Support
[]
[]
[]
No past due unpaid medical support is owed at this time.

Unpaid medical support that may be owed is not affected by this order.
(Name)_________________________ is awarded a judgment against
(name)______________________ in the amount of $ _____________ for past due
unpaid medical support for the period from (date)_______ through (date)_______ .
[]
[]
[]

(Name)________________________ is awarded a judgment against
(name)_____________________ in the amount of $ ______________ for back
interest for the period from (date)____________ through (date)______________ ,
[]
Other:
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15
16
17
18
19
3.22
O ther Unpaid Obligations
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[]
[]
[]
No other obligations are owed at this time.

Other obligations that may be owed are not affected by this order.
(Name)_____________________________ is awarded a judgment against
(name)______________________ in the amount of $ ______________ for [ ] child
care [ ] ordered contributions to extracurricular activities [ ] long distance transportation
costs f ] educational expenses [ J post secondary [ ] other______________________
for the period from (date)____________ through (date)_________________ .
(253) 770-0808, Fax (253) 770-0259
.9524
0225/Z ei*.
1
2
[]
[]
[]

(Name)___________________ __is awarded a judgment against
(name)________________ ____ in the amount of $ _____________ for back
interest for the period from (date)____________ through (date)____________
[]
Other:
3
4
5
6
7
3.23
O ther
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9
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-\o i &
Dated:
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Jttfkje/C m m issioner
Approved for entry:\V/\fy|A LYNN KIESI

N otfdeofw e^t,**^ COMMISSIOI
Presented by:
14
15
Si
of Party ftr Lawyer/WSBA No. |w1 ^ j ^

jj/rv A k
16
Print Name
17
[]
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19
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21
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Signature of Party \jr Upwyer/WSBA No.

Print Name
I apply for full support enforcement services from the DSHS Division of Child Support (DCS).
(Note: If you never received TANF, tribal TANF, or AFDC, an annual $25 fee applies if over
$500 is disbursed on a case, unless the fee is waived by DCS.)
Signature of Party
[]
Approval required in Public Assistance cases. The DSHS Division of Child Support received
notice required by RCW 26,23A30. This order has been reviewed and approved as to:
[]
[]
[]
[]
Current Child Support

Back Child Support
Medical Support
Other:
(253) 770-0808, Fax (253) 770-0259
9S24
6 /2 5 ^ 2 8 X 8
J
2
Deputy Prosecuting Attorney/
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(253) 770-0808, Fax (253) 770-0259
498
9524
8 /2 5 /2 8 .1 8
498224

[X proposed by [ X ] JASON WILLIAM SHIPMAN [ ] State of WA [ ] O ther____________________ (CSWP)
Dr, [ JSigned by the Judicial/Re viewing Officer. (CSW)
MOTHER
COUNTY

PIERCE
FATHER
CASE NO.

10-3-00961-1
CHILD SUPPORT ORDER SUMMARY REPORT

judicial/reviewing officer.
B. The STANDARD CALCULATION listed on line 17 of the Worksheet for the paying parent is: $780.02.
[ X ] Does not apply
[ ] Sources of income and tax planning
[ ] Split custody
( ] Residential schedule (including shared custody)
[ j Other (please describe):
E.
Income for the Father is [ ] imputed [ X ] actual income.

Income was imputed for the following reasons:
P artlllWSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2010 page 1 of
Original

8/18/2010
9:10AM
WORKSHEETS
Children and Ages: Hunter 9, Tyler 16
(child ages calculated using August 18, 2010)
Part I: Incom e (See Instructions, page 6)

Father
Mother
$4,299.00 j
$6,192.00
$0.00
$0.00
c. Business Income
SO. 00 j
$0.00
$0.00
$0.00
e. Other Income
$0.00
$0.00
f. Imputed Income
$0.00
$0.00
$4,299.00
$6,192.00
$670.65
$1,002.09
b. FICA (Social Security plus Medicare)/SeIf-Employment Taxes
$328.87
$473.69
'
g. Total Monthly Gross Income (add lines 1a through 1f)

$5.00
$0.00
$54.00
$80.00
$0.00
$0.00
$0.00
$0.00
g. Maintenance Paid
$0.00
$0.00
$0.00
$0.00
$1,058.52
$1,555.78
$3,240.48
$4,636.22

3. Monthly Net Income (line 1g minus line 2i)
(add parents monthly net incomes from line 3)
$7,876.70
5. Basic Child Support Obligation (enter total amount in box -> )

Hunter
$848
Tyler
$1,048
$1,896.00
(presumptive)
58.86%
41.14%

P a rt II: B a sic C h ild S u p p o rt O bligatio n (See Instructions, page 7)
7. Each Parent's Basic Child Support Obligation without consideration of

low income limitations. (Multiply each number on line 6 by line 5)
$780.02
$1,115.98
8. Calculating low income limitations: Fill in only those that apply.

a. Is Combined Net Income Less than $1,000?
enter the presumptive $50 per child.
If yes, for each parent
b. Is Monthly Net Income Less Than Self-support Reserve? If yes, for that
c. Is Monthly Net Income Greater Than Self-support Reserve? If yes, for each
parent subtract the self-support reserve from line 3. If that amount is less than
line 7, enter that amount or the presumptive $50 per child, whichever is greater
9. Each parent's basic support obligation after calculating applicable limitations.
For each parent enter the lowest amount from line 7, 8a - 8c. but not less than
the presumptive $50 per child.
$1,128.00
$ 0.00
$ 0.00
$0.00 j
$0.00
$0.00
$0.00
$780.02
$1,115.98
D'' 3 / O IO
Part 111: Health Care, Day Care, and Special Child Rearing Expenses

Father
10 Health Care Expenses
Mother
$0.00 ;
$0.00
$0.00
$0.00
$0.00
$0.00

$0.00 S
$0.00
$0.00 !
$0.00
$0.00
$0.00
$0.00
$0.00
e. Total Day Care and Special Expenses (add lines 11a through 11 d)
(add parent's day care and special expenses from line 11e)
13. Total Health Care, Day Care, and Special Expenses
(line 10d plus line 12)
1
1
$0.00
$0.00
'
$0.00
$0.00
$780.02
$1,115.98
$0.00
$0.00
$0.00
$0.00
14. Each Parent's Obligation for Health Care, Day Care, and Special Expenses
Part IV: Gross Child Support O bligation
Part V: Child Support Credits

$0.00
$0,00
$0.00
$0.00
Part VI: Standard C alculation/Presum ptive Transfer Payment (See instructions, page 9)
17. Standard Calculation (line 15 minus 16d or $50 per child whichever is greater)
$780.02
$1,115.98
Part VII: A dditional Inform ational Calculations

18. 45% of each parent's net income from line 3
19. 25% of each parent's basic support obligation from line 9
$1,458.22 j
$2,086.30
i
$195.01 j1
$279.00
,0 1*1 q y s z x ,'
Part VIII: A dditional Factors fo r C onsideration (See Instructions, page 9)

i
a. Real Estate
b. Investments
F ather's
H ousehold
i
i
f. Other (describe)
21. Household Debt (List liens against household assets, extaordfnary debt)

i
a. Income of Current Spouse or Domestic Partner (if not the other parent of this action)
Name
Name
Name
Name
c. Gross income from overtime or second jobs the party is
asking the court to exclude per instructions, page 10
d. Income of Children (If considered extraordinary)
Name
Name
i
j
Name
Name
Program
Program
WSCSS-WorKsheets - Mandatory (CSW/CSWP) 6/2010 page 4 of
Mother's
Household
2001-10 THOMAS E. JAFFE
9524
8 /25/28:18
498223

County of
No. 10-3-00961-1
Tem porary O rder
(TMO/TMRO)

Petitioner.
and
[ ] Clerks Action Required

[ ] Law Enforcement Notification, U 3.1

Respondent.
I. Judgm ent/Order Sum m aries
1.1 Restraining Order Summary
[X ] Does not apply.
1.2 Money Judgm ent Sum mary
[X ]
Does not apply.
II. Basis
A motion for a temporary order was presented to this court and the court finds reasonable cause to issue
the order.
III. Order
It is Ordered:
3.1
Restraining Order
Previous Order
Temp Order (TMO/TMRO) - Page 1 of 5

WPF DR 04.0250 Mandatory (7/2009) - R C W 26.09.060; .110;. 120;. 194, .300(2)
9524
B -S Z S S 2 9 1&
498238
[X ]
Does not apply.

Pursuant to 18 U.S.C. 2265, a court in any of the 50 slates, the District of
Columbia. Puerto Rico, any United States territory, and any tribal land within the United States
shall accord full faith and credit to the order.
3.2
Temporary Relief
Child support shall be paid in accordance with the order of child support, signed by the
court.
The parties shall comply with the Temporary' Parenting Plan signed by the court.
Each party' shall be immediately responsible for their own future debts whether incurred by
credit card or loan, security interest or mortgage.
The family' home shall be occupied by the petitioner

***
Other: Petitioner shallI) make Hpct

best pffnrtc
efforts fn
to nrnl^r't
protect flip
the PAmmnhiftrc
community's omnttr
equity in
in tliA
the
Petitioner or petitioner's attorney:

A signature below is actual notice of this order.
[ ] Presented by:
neror Lawver/WSBA No.,
Print or Type Marne
Date /
Vl
I
Respondent or respondentT^SjptbhRT: COMMISSIONER

[ ] Presented by :
[/[Approved for Entryr
waived:
Signature of Respondent br Lawver/WSBA No.
Print or TypeNdme
Temp Order (TMO/TMRO) - Page 2 of 5

WPF DR 04.0250 Mandatory (7/2009) - R C W 26.09.060;. 110;. 120;. 194, .300(2)
Date
E-FILED
October 15 2010 11:55 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)

Phone: (253) 770-0808

Show Cause
N a tu re o f H earin g:
Contempt
CALENDAR DATE: Monday, December 06, 2010 9:30 AM

W O R K IN G C O P IE S S H A L L BE S U B M IT T E D T O C O M M IS S IO N E R S S E R V IC E S R O O M 140,
B E F O R E 12:00 NO O N T W O C O U R T D A YS P R IO R T O H E A R IN G
DA TED :
October 15, 2010.
S ign ed :
/s/ CLINT P. JOHNSON
NA M E:
CLINT P. JOHNSON
Phone:
(253) 581-0660
W SBA#:
14794
A D D R E S S : 5920 100th St SW Ste 25
For:
1 of
E-FILED
October 15 2010 2:39 PM
KEVIN S TOCK
COUNTY LERK
NO: 10-3-D0961-1
5
6

7
8

Petitioner,
10
11
12
13
NO. 10-3-00961-1
Respondents Attachment to
Motion
vs.
Respondent.
14
15
16
17
18
19
20
21
22
23
24
25

ATTORNEYS AT LAW

Lakew ood , WA 98499
(253) 581-0660
Clint Johnson
From:
Sent:
To:
Subject:
jason shipman [outlaw0015@gmail.com]

Saturday, October 02, 2010 6:43 PM
Clint Johnson
Fwd: FWD: Flave fun @ the
.............Forwarded message---------From: <2536178858@vtext.com>

Date: Sep 29, 2010 3:48 PM
Subject: FWD: Have fun @ the
To: <Outlaw0015@gmail.com>
FWD: Have fun @ the carnival. I AM NOT MAKING THE HOUSE PAYMENT. ITS WAR!!!!!!
3-00961-1
35213191
MTSC
C O U N T ^ c l e r K' S
10-18-10
o p p ,c e
J
A' -
0 C r l 5 2010
p .m.
4
5
6

7
8
9

Petitioner,
10
11
12
NO. 10-3-00961-1
MOTION AND DECLARATION
TO SHOW CAUSE RE
CONTEMPT/JUDGMENT
AND FOR OTHER RELIEF
(MTSC)
vs.
Respondent.
13
14
I. MOTION
15
JASON W. SHIPMAN moves the court for an order directing JENNIFER
16
KAY SHIPMAN to appear personally before the court and show cause why an
17
18
order should not be entered:
19
1.1
20
Finding contempt for failure to comply with:
21
The Temporary Order,
22
Signed by the court on August 24, 2010, in Pierce County, Washington.
23
1.2
FINDING CONTEMPT.
ESTABLISHING A JUDGMENT.
24
Does not apply.
25
MOTION AND DECLARATION TO
SHOW CAUSE RE CONTEMPT/
JUDGMENT (MTSC)- 1
WPF DRPSCU 05.0100 (6/2008)
RCW 26.09.160

5920 100th St r e e t S.W.. S uite 25

L a k e w o o d , WA 98499
(253) 581-0660
ORIGINAL
1
2
3
4
1.3
5
6
GRANTING SANCTIONS.
Does not apply.
1.4
OTHER:
7
That paragraph 3.2 of the Temporary Parenting Plan entered August 24, 2010, be
8
9
10
modified to change the weekend schedule.

That Respondent be granted an award of attorney's fees in an amount of no less
11
than $1,500.00 payable to the law office of FAUBION, JOHNSON, REEDER&
12
FRALEY, P.S,, for the necessity of bringing this motion.
13
14
This motion is based upon the declaration which follows.

DATED this i M
day of October, 2010.
15
FAUBION, JOHN SOI
16
REEDER & FRALEY, P.S.
17
18
CLINT R JQMNSON, WSBA 14794

Of Attorneys for Respondent
19
20
II. DECLARATION
21
22
23
24
25
JENNIFER KAY SHIPMAN should be held in contempt for the following

reasons:
Failure to comply with the Temporary Order which required:
Paragraph 3.2, Other, states Petitioner shall make the monthly mortgage
JUDGMENT (MTSC)- 2
WPF DRPSCU 05.0100 (6/2 008)
RCW 26 09.160

Attorneys at Law
5920 100th Street S.W.. S uite 25
Lakewood, WA 98499
(253)581-0660
1
2
3
payments and make best efforts to protect the community's equity in the family home
and keep Respondent informed on the status of her efforts."
5
6
This order was violated in the following manner:

Petitioner has taken no action to make the monthly mortgage payments on the
7
family home, and despite requests to comply she has chosen to ignore the court order.
8
9
Petitioner is a registered nurse, has ample income to pay the mortgage, and states,
10
within her own financial declaration filed March 15. 2010, she has the ability to pay; she
11
has chosen not to do so. Her financial declaration states she has living expenses of
12
$4,750.96. These living expenses are to include making the mortgage payment.
33
14
According to the temporary support order, her net earnings are $4,636.22. With the
$780.02 child support I pay her, she has a monthly income of $5,416.24. She has the
15
16
17
means to meet the mortgage obligation easily and there is absolutely no reason for her to
miss the $ 1,670 mortgage payments.
18
On the weekend of October 2-3 Petitioner moved out of the house and relocated
19
into an apartment across town, without notice to me. Quite frankly, she never intended
20
to make the mortgage payment. Texts that she has sent in the past confirm her attitude
21
and her intention not to comply with the court order. Attached is a text she sent me on
22
May 20, 2010. She consistently tells me the same thing when she does communicate
23
24
25
with me. She will say that 1 have not cooperated in assisting in some sort of loan
modification. That is not true. She has not communicated with me to even inform me
of what she is doing and what attempts she may have made in dealing with mortgage
JUDGMENT (MTSC)- 3
WPF DRPSCU 05.0100 (6/2008)
RCW 26.09.160

Attorneys at Law
5920 100th Street S.W.. Suite 25
Lakewood, WA 98499
(253) 581-0660
10 294
itt
1
2
3
4
5
6
arrears. She is simply choosing to ignore the court order.

As mentioned above, Petitioner moved out of the family home the first weekend
in October. That was the weekend the children were with me. At the hearing on
August 24, 2010,1 had asked the court to reverse the weekends so the children could
7
spend time with their cousins, who happened to be visiting their parents on a different
8
9
schedule, and the rest of my family. The court was willing to make that change, except
10
that Petitioner asserted she was unable to change her alternating-weekend work
11
schedule. The court order in Parenting Plan paragraph 3.2 required her to provide proof
12
that she could not change her work schedule. A copy of the notice she provided is
13
14
attached. However, as it turns out, she was able to take the weekend of October 2 and 3
off to move, so clearly she can change her schedule, contrary to the letter she obtained
15
16
17
18
from her employer. I would therefore ask the court to invoke the provisions of
paragraph 3.2 and allow the reversal of the weekends, as I previously requested.
I am asking for attorney fees and costs in the amount of $1,500, for the necessity
19
of bringing this motion, and an order to bring the mortgage current. I ask that she be
20
ordered to make the September through November mortgage installments within ten (10)
21
days, and that she make arrangements to bring the mortgage completely current within
22
ninety (90) days of entry of this order.
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I declare under penalty of perjury under the laws of the State of Washington that
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JUDGMENT (MTSC)- 4
WPF DRPSCU 05.0100 (6/2008)
RCW 26.09.160

Attorneys at Law
Lakewood, WA 98499
(253)581-0660
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the foregoing is true and correct to the best of my knowledge.
Signed at Lakewood, Washington,yon October
, 2010.
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JAgON' SHIPMAN
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JUDGMENT (MTSC)- 5
WPF DRPSCU 05.0100 (6/2008)
RCW 26.09.160
FAUBION, JOHNSON, REEDER & FRALEY, P,S.

A t to r n e ys a t La w
S t r e e t S.W., S uite
La k e w o o d , WA 98499
5920 100t h
(253)581-0660
25
18294* iB /iB /S ffc lb .21
ORTSC
10-3-00961-1
10- 18-10
1
2
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FILED
OCT 1 5 2010
a.m.

KEVIN S to c k , Cfiunjv Clerk
BY:^
DEPUTY
p.m,
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COUNTY OF PIERCE
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NO. 10-3-00961-1
and
ORDER TO SHOW CAUSE RE:

CONTEMPT (ORTSC)
Clerks Action Required.
Petitioner,
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Respondent.
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IT IS ORDERED:
That JENNIFER KAY SHIPMAN shall appear in person before this court at
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the place and time below and show cause why the relief requested in the Motion
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and Declaration to Show Cause re Contempt/Judgment should not be granted.
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Date:
December 6, 2010
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Time:
9:30 a.m.
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Place;
100/117/407 as assigned or posted
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ORDER TO SHOW CAUSE RE: CONTEMPT (ORTSC)

Page 1
WPF DRPSCU 005.0150 (6/2008)
RCW 26.09.160
ORIGINAL
FAUBION, JOHNSON,
REEDER & FRALEY, P.S
5920 100th Street SW
Suite 25
Lakewood, WA 98499
(253) 581-0660
10294
If you disagree w ith any part of the motion, you m ust respond to the motion
in w riting before the hearing and by the deadline for your county. A t the
hearing, the court will consider W RITTEN sworn affidavits or declarations.
Oral testim ony may NOT be allowed. To respond you must: (1) file your
docum ents with the court; (2) provide a copy of those docum ents to the
judge or c o m m is s io n e rs staff; (3) serve the other party=s attorney with
copies of your docum ents (or have the other party served if that party does
not have an attorney); and (4) com plete your filing and service of documents
within the tim e period required by the local court rules in effect in your
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county. If you need m ore information, you are advised to consult an
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attorney or a courthouse facilitator.
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IF YOU FAIL TO APPEAR IN PERSON, THE COURT MAY G RANT THE
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RELIEF REQUESTED IN THE MOTION.
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day of
2010
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S50GE / COMMISSIONER
^
iIN COUNTY
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Presented by:
FAUBION, JOHNSON, REEDER
& FRALEY, P.S.
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mi.
CLERK'S OFFICE
OCT 1 5 2010
p.m
P1FRCE COUNTY, WASHINGTON

KEVIN
BY,V-.
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BY___________________________
CLINT P. JOHNSON, WSBA14794
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ORDER TO SHOW CAUSE RE: CONTEMPT (ORTSC)
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Page 2
WPF DRPSCU 005.0150 (6/2008)
RCW 26.09.160
FAUBION, JOHNSON,
REEDER & FRALEY, P.S.
5920 100th Street SW
Suite 25
Lakewood, WA 98499
(253) 581-0660
x !3 i&
&0193

COUNTY OF PIERCE
Id re the Marriage of:

NO: 10-3-00961-1
DECLARATION OF SERVICE
Petitioner,
and
JASON W. SHIPMAN,
Respondent
The undersigned states that I am a citizen of the United States and of the State of Washington, over the
age of eighteen years, not a party to the above entitled action, competent to be a witness therein, and
was at all times herein mention. I effected service as indicated below:
[a] Number of copies served: One(l)
[b] Title of Papers served: Note for Commissioners Calendar, Motion and Declaration to Show
Cause re: Contempt/Judgment and for Other Relief, Respondents Attachment to Motion and Sealed
Financial Documents.
[c] Date and Time of Service: October 27,2010 at 5:00 P.M.
[d] Person (s) to be served:
[e] Place of Service:
4102 S. Meridian
Puyallup, WA 98373
Service was made pursuant to Civil Rule 4(d)
D E C L A R A T IO N O F SE R V IC E
Page 1
11316
[X] By delivery to the person(s) named in paragraph (d)

[ ] By delivery to
defendants usual abode.
a person o f suitable age and discretion residing at the
Signed at LAKEWOOD, WASHINGTON, on October 27, 2010.
LANNIE FLAAEN, #9270
FEES: Service $10.00 Rush: $00.00 Miles: $41.60 Misc: $ 14.00 TOTAL: $65.60
D EC LA RA T tO N O F SE R V IC E
P age 2
68134
1 0 ?9 i
1 1 ^ 2 4 /2 0 1 0
190652
1
10-3-0096 M
35427006
NTWSUB
11-24-10
" cou" cL
&
NOV 1 9 2010 P8
0FF1CE
^ ^ s a s a a -
gPUTY
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S uperior C ourt o f W ashington

County o f Pierce
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In re the marriage of:

JENNIFER KAY SHIPM AN,
No.
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and
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JASON W ILLIAM SHIPM AN,
NOTICE OF W ITHDRAW AL AND

SUBSTITUTION OF ATTORNEY
Respondent.
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TO THE CLERK OF THE COURT, and
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TO:
JENNIFER KAY SHIPMAN, Petitioner.
AND TO:
LANCE HESTER, Petitioners Attorney
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10-3-00961-1
Petitioner,
YOU AND EACH OF YOU PLEASE TAKE NOTICE that CLINT P. JOHNSON, has
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ascended to the Pierce County Superior Court as Court Commissioner effective

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November 8, 2010 and hereby withdraws as Attorney of Record for the Petitioner.
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YOU ARE FURTHER NOTIFIED that Daniel N. Cook of FAUBION, REEDER,

FRALEY & COOK, P.S., located at 5920 100th Street S.W., Suite 25, Lakewood,
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Washington 98499, telephone (253) 581 0660, is hereby substituted as Attorney of
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Record for the withdrawing counsel.

Notice Of Withdrawal And Substitution Of Attorney -1
FAUBION, REEDER, FRALEY

& COOK, P.S.
5920-100 Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
l 7 9 i
ii/2 4 /2 0 1 0
1900S3
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COPIES OF ALL FURTHER PAPERS AND PROCEEDINGS herein, except
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original process, should be served on the substituted Attorney of Record along with all
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others above named.

DATED this
/9
day of
________ , 2010.
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Daniel N. Cook, WSBA #34866
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Notice Of Withdrawal And Substitution Of Attorney - 2

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
November 30 20'
KEVIN ST
COUNTY C
NO: 10-3-0
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County of Pierce
In re th e M arriage of:
No. 10-3-00961-1
JE N N IF E R KAY SH IPM A N
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Declaration of
Counsel fo r Petitioner
In Opposition to
R espondents Motion
and Declaration to
Show Cause Re:
C ontem pt/Judgm ent
And fo r O ther Relief
P etitio n er(s),
an d
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JA S O N W ILLIAM SH IPM A N
R espondent(s).
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I, T im othy M. G reene, declare as follows:

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1. T h a t I am over 18 y ears of age an d com petent, an d th a t I am th e a tto rn e y for

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p e titio n e r J e n n ife r K ay S hip m an .
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2. Ms. S h ip m an h a s b een ill recently, a n d h a s b een u n ab le to a s s is t m e in h e r defense on

th is m a tte r. In p a rtic u la r, she a n d I h a d p la n n e d to have h e r p re p a re a d eclaratio n in
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an sw er to re sp o n d e n ts m otion, an d to m eet on N ovem ber 29, 2010, to finalize th e

docum ent. She cancelled th e ap p o in tm e n t becau se of illn ess an d se n t m e a n e-m ail today,
N ovem ber 30, 2010, a t 9:07 a.m ., w hich
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in d icates an ongoing illn ess w hich is g ettin g
w orse a n d w hich im plies she h a s b een u n d e r a doctors care for th e illness. She in d icates in
th e e-m ail th a t she w ill be g ettin g a doctors note re g a rd in g h e r illness.
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Declaration of Counsel for Petitioner

in Opposition to Respondennts
Motion to Show Cause Re:
Contempt

Puyallup, Washington 98373-0030
PH: (253) 770-0808, Fax (253) 770-0259
1
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3. A ssum in g th e bona fides of Ms. S h ip m an s re p re se n ta tio n s, w hich I am confident th a t I

w ill be able to show, I believe th a t th is is good cause for h av in g th is m a tte r set over.
4. I w ould fu rth e r note th a t a m otion for co n tem p t its e lf is n o t ap p ro p ria te in th is m a tte r
(alth o u g h arg u ab ly o th e r form s of re lie f m ay be av ailable to M r. S hipm an). C o n tem p t is

u n av ailab le to enforce p ro p e rty se ttle m e n ts or p ro p e rty division. In re Marriage of Young,
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26 W n. App. 843, 615 P .2d 508 (1980). F a ilu re to p ay debts or lien s is n o t a n ap p ro p ria te
issu e for co n tem p t proceedings. Corrigeux v. Corrigeux, 37 W n. 2d 403, 224 P .2d 343
(1950); State ex rel. Foster v. Superior Court, 193 W ash. 99, 102, 74 P .2d 479 (1937).
C o n tem p t is only a n ap p ro p ria te rem ed y if re la te d to th e su p p o rt n eed s of th e m oving p a rty

8
a n d th e child ren . Decker v. Decker, 52 W n. 2d 456, 326 P .2 d 332 (1958).
In th e in s ta n t case, resp o n d en t, M r. S hip m an , is m oving for co n tem p t b ecau se Ms.

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S h ip m an is n o t p ay in g th e m ortgage on th e hom e, w h en she h a d b een co u rt o rd ered to

m ake th e m ortgage p ay m en t. H ow ever, th e c h ild ren live w ith Ms. S hip m an , a n d n e ith e r
p a rty lives in th e com m unity hom e anym ore (Ms. S h ip m an h a d b e en th e re s id e n t of th e
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com m unity hom e a t th e tim e th a t th e A u g u st 24 te m p o ra ry o rd er h a d b e en issued, b u t she

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h a s since m oved out, as re sp o n d en t n o tes in h is d eclaration). Accordingly, th is m otion is

u n re la te d to su p p o rt n eed s of e ith e r M r. S h ip m an or th e children. Therefore, Ms. S h ip m an
can n o t be found in contem pt.
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5. Finally, I w ould re q u e st p roof of service on m e of th is m otion. A lthough m y clien t h a d

a p p a re n tly b een p erso n ally serv ed w ith th e m otion in la te O ctober, p e r h e r re c en t
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re p re se n ta tio n to me, I do n o t recall ever receiving a copy of th e m otion, a n d w as n o t m ade

aw are of th is m otion u n til m y clien t ad v ised m e sh o rtly before T hanksgiving.
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Contempt

PH: (253) 770-0808, Fax (253) 770-0259
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I declare u n d e r p e n a lty of p e rju ry u n d e r th e law s of th e s ta te of W ash in g to n th a t th e

foregoing is tru e a n d correct.
S igned a t P uyallu p , W ash in g to n on N ovem ber 30, 2010..
/s/T im othy M. G reene

S ig n a tu re of D e c la ra n t
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Contempt

PH: (253) 770-0808, Fax (253) 770-0259
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ATTACHMENT:
NOVEMBER 30, 2010 E-MAIL FROM
JENNIFER SHIPMAN TO DECLARANT
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Contempt

PH: (253) 770-0808, Fax (253) 770-0259
Windows Live Hotmail Print Message
Page 1 of 1
(No Subject)
From: chevygirl015@hotmail.com
Sent: Tue 11/30/10 9:07 AM
To: Tim greene (tgreene01@hotmail.com)
Hi Tim,
I did get your voicemails last night. I have been sick these last couple of
weeks, but I'm not getting better I'm getting worse. Because of that I
haven't been able to get everything ready for you. You mentioned that you
could ask for another date. That would be great. I will see my doctor, again,
and get a note saying I have been ill.
Thanks,
Jennifer Shipman
Sent from my Verizon Wireless BlackBerry
http://byl47w.bayl47.mail.live.com/mail/PrintMessages.aspx?cpids=44103be5-fca4-l Id...
11/30/2010
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
November 30 20'
KEVIN ST
COUNTY C
NO: 10-3-0
3
4
5
6
7
IN THE SUPER IO R CO U R T OF THE STATE OF W ASHINGTON

8
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10
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12
13

Petitioner,
vs.
)
) Case No.: 10-3-00961-1
)
) DECLARATION OF SERVICE
)
)
)
___________Respondent._____________ )
14
I,
Bettyann Walter
, the undersigned, hereby declare as follows:
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1.
I am over the age of 18 years and not a party to this action. My business/residence address is:
P.O. Box 731063, Puyallup, WA 98373_______________________________________
2.
On November 30, 2010

(Date), I served
with the following documents:
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22
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(Name)
Declaration of Counsel for Petitioner In Opposition to Respondent's Motion and Declaration to Show Cause Re:
Contempt/Judgment And for Other Relief and Email Attachment
3.
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Daniel Clark_______________
Address(es) of service:
5920 100th Street S.W., Suite 25, Lakewood, WA 98499
4.
Service was made as indicated below:
By delivery to the person named by a peace officer.

XX
By mailing to the person named at the address(es) of service.
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and
correct.
Signed at
Puyallup____________ , Washington on November 30, 2010_________________.

(Place)
(Date)
/s/ Bettyann Walter
26
Signature
Bettyann Walter
Type or Print Name
1 of 1

Street Address: 4115 S. Meridian, Suite B
Tel. (253) 770-0808; Fax (253) 770-0259
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
November 30 20'
KEVIN ST
COUNTY C
NO: 10-3-0
3
4
5
6
7
IN THE SUPER IO R C O U R T OF PIERCE COUNTY

IN AND FOR THE STATE OF W ASHINGTON
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9
10
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)
) Case No.: 10-3-00961-1
)
) DECLARATION OF SERVICE
)
)
)
)

Petitioner,
vs.
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Jason William Shipman

Respondent.
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I, Bettyann Walter_____ , the undersigned, hereby declare as follows:
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1.
I am over the age of 18 years and not a party to this action. My business/residence address is:
P.O. Box 731063, Puyallup, Wa 98373___________________________________________
2.
On November 30, 2010

(Date), I served
with the following documents:
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Daniel Cook
(Name)
Declaration of Counsel and Email Attachment
3.
Address(es) of service:
5920 100th Street S.W., Suite 25, Lakewood, WA 98499
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4.
Service was made as indicated below:
By delivery to the person named by a peace officer.

xx
By mailing to the person named at the address(es) of service.
correct.
24
Signed at
Puyallup____________ , Washington on
November 30, 2010_________________.
(Place)
25
(Date)
/s/ Bettyann Walter
26
Signature
Bettyann Walter
Type or Print Name
1 of 1

Street Address: 4115 S. Meridian, Suite B
Tel. (253) 770-0808; Fax (253) 770-0259
E-FILED
December 02 2010 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
IN THE S U PE R IO R COURT OF THE STATE OF W ASHINGTON

IN AN D FOR THE COUNTY OF PIERCE

JENNIFER KAY SHIPM AN
NO. 10-3-00961-1
Petitioner,
v.
REPLY DECLARATION
OF JASON SHIPM AN
JASON W ILLIAM SHIPM AN
____________________ Respondent.
I, JASON SHIPMAN, make this reply declaration on the basis of my personal
knowledge. I am the Respondent in this matter and competent to testify.
Jennifer has used the family home divisively for months. Her actions have risen to
the level of waste of a community asset. She was specifically ordered to make the
payments and attempt to protect the communitys equity in the house. Not only has she
failed to make the payments but she has failed to use any efforts to protect the community.
Jennifer and I have had marital troubles for years. After several discussions about
divorce it was decided she wanted an apartment. In October of 2009 I went to the bank to
finance the home in my name at her request. Attached as Exhibit A is a bank letter
Reply Declaration of Jason Shipman - Page 1 of 4
Shipman, Jennifer v Jason
S:\CASES1\Shipman, Jason disso'iPLEADINGS\Disso\Reply Declaration of Jason
Shipman.doc
FAUBION, REEDER, FRALEY &

COOK, P.S.
Lakewood, WA 98499
253-581-0660
documenting my refinance efforts. After I was approved for refinance Jennifer said no she
wanted the house and that I needed to move out.
After she told me she wanted the house I went to work in Arkansas. When 1returned
for visits I stayed with friends. In February 2010 I came back to Washington for good and
moved into a separate residence because that is what she told me to do.
During that period around the time of separation, we had several arguments where
she threatened not to pay the mortgage. She knew that was a leverage point she could use
because I wanted to keep the house. On May 21st she sent me a text saying I am not
making the house payment. ITS WAR!!!! This text message was filed with our moving
declaration.
She has not paid the mortgage since May 2010 (the month she sent the text
message). In several conversations she has said she is doing all this to hurt me. She has
also bragged to me that by living in the house for several months with no payments she has
been able to save up lots of money. I know that Jennifer lived in the house from May 2010
through August 2010 without making any house payments. I do not know exactly when she
incurred a rent payment for where she is living now but there were at least four months
when she made no house payment at all. She has thus been able to save at least $6,500 in
house payments.
At our hearing in August 2010 the court granted me residential time with the children.
The parenting plan provided that the children could attend school from my residence if I
were living close enough to their school. Within 3 days of the hearing I moved into a
residence across the street from their school and within a few blocks of the family home
where Jennifer was residing. In less than a month Jennifer moved out of the family (that she
S:\CASES1\Shipman, Jason disso\PLEADINGS\Disso\Reply Declaration of Jason
Shipman.doc

COOK, P.S.
Lakewood, WA 98499
253-581-0660
had refused to allow me to refinance, or move into myself) and all the way across town and
changed the childrens school.
1am asking the court to make her pay the mortgage as previously ordered. She
needs to make payments and turn the utilities on so we can sell the home now that she is
not living there and I am locked into a 12 month lease.
Before I left we had two agents come over and say we could sell the home.
Jennifer needs to make sure the landscaping is been done and the home is clean so it can
be shown. Jennifer has had several animals in the home including chickens (inside of the
house). It reeks of ammonia.
As far as not preparing a declaration goes this is the second time she has done this.
Using an illness" as an excuse is not fair. It did not stop her from taking my son on an
extravagant vacation in the San Juan Islands a few weeks ago. Nor did it stop her from
assaulting me on November 10, 2010.
Prior to separation Jennifer first agreed to get her own apartment and changed her
mind and refused to let me refinance the mortgage into my name alone. Jennifer then told
me I had to move out. I asked her again to move out and let me keep the home and she
refused. She asked for use of the family home in her motion and the court authorized her to
have use of the home and ordered her to make the monthly house payments. After the
hearing allowing Jennifer use of the home, I signed a 12 month lease for a rental home near
the family home so that I could have more time with the children (as the court authorized).
Jennifer then, after months of preventing me from refinancing or living in the home and
asking for use of the home herself, moved out of the home. Jennifer has used the family
home as a weapon to inflict conflict and pain in this situation. Jennifer is now allowing the
S:\CASES1\Shipman, Jason disso\PLEADINGS\Disso\Repty Declaration of Jason
Shipman.doc

COOK, P.S.
Lakewood, WA 98499
253-581-0660
only community asset of any value to depreciate and waste because of her desire to be
vindictive and spiteful. The court should find Jennifer in contempt for her willful and
intentional violation of the order. Even if contempt is not found, the court should order
Jennifer to do what is necessary to allow the house to be sold, including moving all of her
stuff out since she is no longer living there and getting the property cleaned up and in
condition for sale. Further, the court can impose financial sanctions for non-compliance with
a valid order even if contempt (and threat of incarceration) is not specifically found. At a
minimum the court should order Jennifer to pay $1,500 in attorneys fees for her actions
which necessitated this matter to be brought before the court.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE

OF WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
Signed at
______________ , Washington, on December

S:\CASES1\Shipman, Jason disso\PLEADINGS\Disso\Reply Declaration of Jason
Shipman.doc
/ , 2010.

COOK, P.S.
5920-1 00th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
Basskof America
Home Loans
October 26, 2010
RE: Jason Shipman Loan Application
To Whom It May Concern:
This letter is to verify that Jason Shipman applied for a refinance loan in October of 2009. Mr. Shipman
explained that he and his wife were in the process of separating and needs to refinance his current mortgage
removing Jennifer from the loan. An application was taken and a conditional approval was issued for Jason to
proceed with the refinance. In order for us to issue a full approval, Jason was to provide us with some income
and asset documentation. He was provided with a conditional approval letter and was to contact the loan officer if
he so wishes to move forward with the loan. He applied for the loan on 10/14/2009.
If you need any further information or clarification regarding the above statement, please feel free to contact me at
253-904-1081.
Sincerely
Chanthy Lodgd
Mortgage Loan Coordinator
Phone: 253-904-1081
Fax: 1.800.461.3995
Email: chanthy.lodge@bankofamerica.com
Bankof America
Home Loans
Chanffiy Lodge
Mortgage Loan Coordinator
Tel: 253.904.1081 * Fax: 800.461.3995
chanthy.lodge@bankofamerica.com
WAS-962-01-01
5605112th Street E - Ste 600, Puyallup, WA 98373
ts> Equal Housing Lender
Recycled '
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, '
December 03 20'
KEVIN ST
COUNTY C
NO: 10-3-0
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3
4
5
6
7
8
9

County of Pierce
No. 10-3-00961-1

Petitioner
and
Supplem ental
Declaration of
In Opposition to
Respondents Motion
and Declaration to
Show Cause Re:
And fo r O ther R elief
10
11

Respondent
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13
14
I, Timothy M. Greene, declare as follows:
15
1. That I am over 18 years of age and competent, and that I am the attorney for
16
petitioner Jennifer Kay Shipman.
17
18
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2. As I indicated in my November 30, 2010 declaration, Ms. Shipman has been ill recently,
and has been unable to assist me in her defense on this matter. I attached an e-mail from
Ms. Shipman to my declaration in which she indicated that she would be obtaining a note
from her doctor.
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Supplemental Declaration of Counsel
23
for Petitioner in Opposition

to Respondennts Motion to
Show Cause Re: Contempt

PH: (253) 770-0808, Fax (253) 770-0259
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3. A ttach ed is to th is d eclaratio n is a note from M s. S h ip m an s doctor w hich she su b m itte d

to th e office. (P lease see a tta c h e d as A tta c h m e n t# !).
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4. Also a tta c h e d to th is d eclaratio n is a note from Ms. S h ip m an s em ployer th a t h e r

em ployer is u n ab le to modify M s. S h ip m an s w ork schedule to accom m odate M r. S h ip m an s
w ishes. (Please see a tta c h e d as A tta c h m e n t #2).
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I declare u n d e r p e n alty of p e rju ry u n d e r th e law s of th e s ta te of W ash in g to n th a t the

foregoing is tru e an d correct.
Signed a t P uyallup, W ash in g to n on D ecem ber 3, 2010..
/s/T im othv M. G reene
S ig n a tu re of D e cla ra n t
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ATTACHMENT #1:
LETTER FROM MS. SHIPMANS DOCTOR
REGARDING HER ILLNESS
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PH: (253) 770-0808, Fax (253) 770-0259
SUMMIT VIEW CLINIC

11019 CANYON ROAD EAST, SUITE A
PUYALLUP, WA 98373-4298
(253) 537-0293 FAX (253) 537-7650
JENNIFER SHIPMAN
2323 7TH ST SE APT B203
PUYALLUP, WA 98374
Date: 11/30/10
To Whom It May Concern;
Jennifer has been ill with a persistent respiratory infection for 2-3 weeks. She has required 2 visits to
her physicians and is still ill, requiring antibiotics and other medications. She has missed several days of
work.
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ATTACHMENT #2:
LETTER FROM MS. SHIPMANS EMPLOYER
REGARDING RESCHEDULING HER WEEKENDS
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to Respondents Motion to

PH: (253) 770-0808, Fax (253) 770-0269
C A T H O L IC HEALTH
INITIATIVES
Franciscan Health System

ST. C L A R E H O S P IT A L
N ovem ber 30, 2010
To W hom It M ay Concern:
Jennifer Shipman is employed at St. Clare H ospital in onr Ortho/Snrgical unit as a Registered
Nurse. She was hired into a specific seat w ithin our scheduling m atrix. It is not our intention
to be noncom pliant in this situation, however, we cannot change her scheduled work weekends,
because this would upset other em ployees set schedules, and create a hardship on the hospital.
Jennifers next scheduled w orking weekend is Decem ber 11 & 12, 2010.
If you have further questions, please contact me at 253-985-6861.
Sincerely,
JtfYTLti _ .
Connie Luu
Clinical M anager, Ortho/Surgical U nit
CC: Jennifer Shipman, RN
CL:bau
A mission to heal, a promise lo care.
1131 5 Bridgeport Way SW Lakewood, WA 98499 P 253.588.1 711 F 253.512.2833
ST. CLARE HOSPITAL ST. FRANCIS HOSPITAL ST. JOSEPH MEDICAL CENTER ENUMCLAW REGIONAL HOSPITAL ST. ANTHONY
HOSPITAL FRANCISCAN FOUNDATION FRANCISCAN HOSPICE AND PALLIATIVE CARE FRANCISCAN MEDICAL GROUP
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E-FILE [
IN COUNTY CLER
PIERCE COUNTY, W
December 08 201
KEVIN S T
COUNTY C
NO: 10-3-CI
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9

County of Pierce
No. 10-3-00961-1

Petitioner
and
Second
Supplem ental
Declaration of
In Opposition to
R espondents Motion
and Declaration to
Show Cause Re:
And fo r O ther Relief
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Respondent
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I, Timothy M. Greene, declare as follows:

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2. It is now 2:45 p.m, on Wednesday, and I am concerned that Ms. Shipmans response
to the Motion for Contempt which we have not submitted yet, will be deemed untimely.
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Accordingly, I am submitting on her behalf an e-mail which I sent to the Mr. Shipmans
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counsel (at the time Clint Johnson) on September 29, 2010 in which I gave notice on Ms.
Shipmans behalf that she was moving out of the home, and indicated in the e-mail that
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Ms. Shipman would like to list the home. Mr. Johnson responded that he fully supports
listing the home.
Second Supplemental Declaration of Counsel

PH: (253) 770-0808, Fax (253) 770-0259
3. It is my understanding that Ms. Shipman has listed the home.
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4. I am not s u b m ittin g th is e-m ail for th e tr u t h of th e co n ten ts (w hich w ould be h earsay )
b u t to d e m o n stra te good fa ith on Ms. S h ip m a n s p a r t in co m m u n icatin g h e r in te n tio n to
move o u t of th e hom e p rio r to m oving out, a n d in com m u n icatin g h e r in te n t to lis t th e

hom e.
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5. Also a tta c h e d is a le tte r from Ms. S h ip m an s em ployer, d a te d S ep tem b er 7, 2010, in

w hich th e em ployer in d icates th a t scheduled w ork w eekends c an n o t be changed, a t le a s t
n o t on a p e rm a n e n t basis.
T his
le tte r w as e-m ailed to M r. S h ip m a n s counsel, C lint
Joh n so n .
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I declare u n d e r p e n alty of p e rju ry u n d e r th e law s of th e s ta te of W ash in g to n th a t th e

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to Rcspondennts Motion to

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ATTACHMENT #1:
E-MAIL EXCHANGE BETWEEN COUNSEL
ON SEPTEMBER 29. 2010
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to R espondent's Motion to

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Page 1 of 2
RE: marriage of shipmanmortgage payments

Fro m : Clint Johnson (CJohnson@fjr-law.com)
Sent: Wed 9/29/10 12:53 PM

To:
Tim Greene (tgreene01@hotmail.com)
Mr. Shipman is not in a position to move in the home [he is under a lease in his current residence].
But he fully supports putting the home on the market ASAP. He has not failed to cooperate with your
client despite her claims.
FA U B IO N , JOHNSON, REEDER & FRALEY P.S.

Clint P. Johnson
Attorney at Law
Faubion, Johnson, Reeder & Fraley, P.S.
5920 100th Street SW, Suite 25
Lakewood, WA 98499
(253) 581-0660; Fax (253) 581-0894
ciohnson@fir-law.com
NOTICE: This email message and all attachments are privileged and confidential attorney-client
communications and/or attorney work product that have been transmitted for the exclusive use of
the addressee(s) named above. If you are not the intended recipient, you are hereby notified that any
dissemination, distribution or copying of this communication is strictly prohibited. If you have received
this communication in error, please immediately notify the sender and delete this message from your
computer's memory and destroy all printed and copied documents that contain this message.
From: Tim Greene [mailto:tgreene01@hotmail.com]

Sent: Wednesday, September 29, 2010 12:14 PM
To: Clint Johnson
Subject: marriage of shipman-mortgage payments
dint
i spoke to Jennifer last night, she advised me that she thought the language of the temporary order was
"Petitioner shall make best efforts to protect the communitys
equity in the famly home" and she was not aware of anything else, i then advised her of the
interlineated language we mutually agreed to, based on our recollection
of commissioner kiesel's oral ruling, that she also "make the monthly mortgage payments", (i thought i
had orally advised jennifer of the change, but i have to concede
i had inadvertantly forgotten to mail her a copy of the ruling).
at any rate, she advised me that she cannot make the entire payment on her own. she indicates that
the courts and jason's understanding of her income is incorrect
in that she is making less this year than last because she is working less, if any, overtime in order to be
home in the evening for the boys, she says her take home
pay is between $ 1400 and $ 1800 every two weeks and the mortage payment is $ 1670
http://byl47w.bayl 47.mail.live.com/mail/PrintMessages.aspx?cpids=:234c2fd9-cc03-l ldf-... 12/8/2010
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monthly, accordingly, her mortgage payment is approximately half of her

income.
Jennifer has, as you are aware, not ignored the situation, she has tried to get jason to cooperate in the
home retention program and she has tried to get jason to
sign documents putting the house on the market, now i am aware that the home retention program is a
black mark on a participant's credit status, and the home
would probably sell at a loss now. but my client is unable to make the house payments.
she now is considering moving out of the house into an apartment, i advised her to wait on that until i
advised you of the situation . i know you have the court order
on your side, on the other hand, that order was entered with the understanding that my client, making
the most income, had chosen to remain in the home and is
"enjoying" that community asset, she now is considering moving out. perhaps your client would consider
moving in, given that he has refused to cooperate in putting the house on the market.
--tim
http://byl47w.bayl 47.mail.live.com/mail/PrintMessages.aspx?cpids=234c2fd9-cc03-l ldf-... 12/8/2010
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LETTER FROM MS. SHIPMANS EMPLOYER

RE: WEEKEND SCHEDULE
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to R espondent's Motion to

PH: (253) 770-0808, Fax (253) 770-0259
i C A T H O L IC HEALTH
T IN ITIATIVES
F ranciscan H ea lth System

ST. CLARE HOSPITAL
September 7,2010

Jennifer Shipman is employed at St. Clare Hospital in our Ortho/Surgical unit as a Registered
Nurse. She was hired into a specific seat within our scheduling matrix. It is not our intention
to be noncompliant in this situation, however, we cannot change her scheduled work weekends,
because this would upset other employees set schedules, and create a hardship on the hospital.
Jennifers next scheduled working weekend is September 18 and 19.
If you have further questions, please contact me at 253-985-8307.
Sincerely,
Clinical Manager, Medical/Surgical Division

CC: Jennifer Shipman, RN
CG:bau
A mission to liraI, a pm mist In care.
11315 Bridgeport Way SW Lakewood, WA 98499 P 253.5BB.1711 F 253.512.2833
ST. CLARE HOSPITAL ST. FRANCIS HOSPITAL ST. JOSEPH MEDICAL CENTER ENUMCLAW REGIONAL HOSPITAL ST. ANTHONY
HOSPITAL FRANCISCAN FOUNDATION FRANCISCAN HOSPICE AND PALLIATIVE CARE FRANCISCAN MEDICAL GROUP
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---------------------------------DEPUTY
PIERCE COUNTY SUPERIOR COURT, STATE OF WASHINQTON
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CALENDAR DATE
Nature of Caae:
r/f(M O ) ShowCaiwafFamBy Law; Confemattan R a quM ......... ..........................(930 Mon.- T tu a .)

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PARTY SETTING HEARING MUST CONFIRM BY CAUJNG (253)798-6697 BY NOON, TWO (2)
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THE ABOVE INFORMATION MUST BE COMPLETED AND SIGNED

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THIS MATTER having come before the Court upon the moving partys Motion, and the
Court having heard the argument of the parties and having considered the records and files
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ORDERED, ADJUDGED AND DECREED_____________ :________________ _______
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KEVIN STOCK, County Clerk
BY_____________________ DEPUTY

WPF DRPSCU 01.0150 (6/2006)
F:\Word\Commissioners Business\Ex Parte DepttCourtroom Forms\Blank order #2.DOC
e - f il e :
IN COUNTY CLERK
PIERCE COUNTY, W
December 09 2010
KEVIN STOC
COUNTY CLE
NO: 10-3-0(9
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County of Pierce
No. 10-3-00961-1

Petitioner
and
Third
Supplem ental
D eclaration o f
C ounsel fo r P etition er
In O pposition to
R espondents M otion
and D eclaration to
Show C ause Re:
And fo r O th er R elief
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Respondent
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L Timothy M. Greene, declare as follows:

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2. This m atter was set over from Monday, December 6, 2010, to Thursday,
December 9, 2010, in order that Ms. Shipman, who had been ill for between
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two to three weeks prior to the hearing, would have an opportunity to respond
to the allegations of contempt.
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Third Supplemental Declaration of Counsel
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fur Petitioner in Opposition


PH: (253) 770-0808, Fax (253) 770-0259
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3. In o rd er for Ms. S h ip m an to be p re s e n t on T h u rsd ay , she h a d to w ork a double sh ift

on T uesday. Accordingly, she w as u n ab le to come in to my law office to p re p a re a
declaration . She is sen d in g me an e-m ail from work, w hich I have a tta c h e d to th is
declaration . If Ms. S h ip m an s e-m ail is defective in m eetin g th e s ta tu to ry re q u ire m e n ts
for a declaration, I w ould resp ectfu lly move th e co u rt to allow h e r to p erfect h er

subm issio n on th e record.
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ATTACHMENT #1:
E-MAIL FROM MS. SHIPMAN
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response tojason
From: Jen S (chevygirl015@hotmail.com)
Sent: Wed 12/08/10 4:03 PM
To: tgreene01@hotmail.com
Tim,
In jason's motion, it states my that my net earnings are $4,636.22. This is not true. I have printed up my
paystubs from March 2010 thru November 2010. My net monthly income for those months varied from
$3,474.00-$4,128.72. In August 2010 jason was ordered to pay monthly child support in the amount of
$780.02, but he has not. I went to my bank's website and printed up the verification of his child support
checks. In November he paid a total of $750.50; October 2010 $180.00; September 2010 $780.02; August
2010 $525.00; July $2010 $525.00; June 2010 $525.00; May 2010 $875.00; April 2010 $1,000.00 and
March 2010 $0 (nothing). My net monthly income with my earnings and child support is not $5,416.24 as
jason states it is. I have told jason this on several occasions. If you add my earnings from my job and the
child support jason has paid, my monthly net incomes are as follows: March 2010 $4,024.85; April 2010
$5,077.76; May 2010 $4,679.69; June 2010 $3,999.00; July 2010 $4,201.75; August 2010 $4,653.72;
September 2010 $4,754.67; October 2010 $3,436.28 and November 2010 $3,376.86.
In March of 2010 when I filled out the papers regarding my budget I wasnt completely sure what my
budget would be (because jason had left). Even though he had told me he would help with the bills, I
didn't know if he was going to actually follow through with that statement. I realized that going from
two incomes to one income would be difficult. To the best of my ability, I have worked out my current
budget. Some of my bills vary every month (cell phone, power, water, etc) as well as the amount I need
to spend on things like clothes, school supplies, food and gas, but for the most part my monthly budget
is $4,200-$4,300. Since March 2010, there have been some months that my income did not cover all of
my bills. I have also had to pay some medical and dental bills for the children.
In regards to the mortgage payment, I did speak to representatives from both our old mortgage
company (Bank of America) and our current mortgage company (LBPS). I was informed by both
company's that a person's mortgage/rent should not exceed 1/3 of their net income. With our monthly
mortgage payment being $1,670.69, my monthly net income should be a minimum of $5,012.07. As I
have shown my net monthly income is less than that. With my income, both mortgage company's highly
recommended that my monthly mortgage/rent to exceed $1,400. My monthly rent is $1,345.00- $325.69
less than our mortgage payment.
On the weekend of October 2-3, 20101 did move out of the house and into an apartment home two
miles away, not 'across town' as jason stated. The move was necessary for several reasons. I couldnt
afford the mortgage payment. The house needs work and repairs that exceed what I can do. The kitchen
has a mold problem. I am allergic to mold. Since the day we moved into the house it has had problems
with rats, jason did re-do the wiring in the house as well as install the security system. On a couple of
occasions he had to fix the wiring because the rats had chewed through the wires. Since jason installed
the security system he was the only one that had the code to program the system. I asked jason several
times what the code was so that I could have it reprogrammed, but he refused to give it to me. We did
remodel the bathroom but the bathtub drain never worked properly. When jason moved out he took the
weed eater and left behind a non working lawn mower, therefore I had difficulty keeping up on the yard
maintenance as I had to borrow equipment. We had several neighborhood kids that cause problems.
Belongings on our property as well as the neighbors property were being stolen. The neighbors property
as well as the easement between my house and the neighbors were set on fire. I did not feel safe in my
neiahborhood. iason also had the neiahbors watchina me (he told me this in a voicemail). I felt unsafe in
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my home. I also felt like I had no privacy.

I choose my apartment home because its one of the few places in town that accept medium size dogs.
My youngest son has a black lab puppy. It's only two miles from my old home, so my boys are still close
to their friends and family. I am on the second story and the community is gated so I feel much safer. My
boys each have their own bedroom. My community is newer so there is no mold or rat problem. My
sinuses are doing better since moving out of my old house (due to mold in old home - I'm allergic to
mold). There were only two (three bedroom) units available at the time that were with in my budget so I
jumped on the opportunity, especially since I was aware that forclosure proceedings would be starting
soon. Also, the rent was with in my budget, unlike my mortgage. Also, 20% of my rent goes into an
"account" to go towards purchasing a condo or a home. My long tern goal is to be able to purchase
another home/condo with in 10 years or less.
On May 15, 2010 jason sent me a text saying "refi the house and I'll be nice again. In regards to the text
sent on May 20, 2010 that was sent out of emotional upset. (In May 2010 jason was down in Arkansas for
work) On May 17,2010 jason sent me a text saying "I love you Jenny. I haven't seen Misty because of you.
I'm here being a good boy." On May 20, 2010 jason and I had been texting each other discussing
reconsiliiation. He wanted to be a family again. He loved me. He missed me. He was no longer cheating
on me. That afternoon I caught jason in a lie. He had been seeing Misty. I spoke with Misty on the phone
(may 20, 2010 at 3:51pm, I have the phone records) as well as received texts from her. She told me that
at that very moment jason was with her and her two kids at a carinval. When she told me that my heart
sank. I was devastated. I was hurt. I was mad. My healing heart was being broken, agian. Out of
emotional turmoil and in the heat of the moment I sent that text to jason. I had believed jason that he
did want to be a family again., on numerous occasions jason told me that if the mortgage payments
were made he would be nice and we could be a family again.
I never wanted the mortgage payments not to be made. I just wanted help in doing so. Jason left on
February 27, 2010 with out any notice to me. He bought tickets for our youngest son and I to go see
Avatar at the IMAX theater in Seattle. Then he told me to take our son to Pacific Science Center and the
Pike Place Market. He said to have fun and to spend the day in Seattle. When my son and I returned
home jason had packed up his things and moved out. He moved into a mobile home in McKenna. Per
jason, his rent was only $600 a month. Also, per a voicemail jason left on my cell phone (I still have that
voicemail), between March 2010 and August 2010 he had three different women living with him. That's
two incomes. There should have been no reason jason could not have assisted in paying the mortgage,
jason currently has a woman living with him so he continues to have two incomes in his house hold while
I only have one.
I have asked jason on several occasions to please help in resolving this issue. I had spoken to both
mortgage company's and explained to them my situation. I had both mortgage company's mail out
home retention program forms, jason refused to sign those forms. In March 20101 had a realator come
out to the home with the intention of listing the house, jason refused to sign those papers. (I still have
those forms), jason had said he wanted to take some time but he did want to move back into the home
and thats why he didn't want to list the house at that time. On September 6, 20101 had a different
realator come out to the home with the intent to list the house, jason once again refused to sign the
papers to list the home. (I still have those forms too). I received an email from you saying that you had
received an email from his attorney and that jason had agreed to sign papers to list the house, jason has
yet to sign the papers, jason has made the accusation that I meliciously did this just to hurt him and his
credit. This is falso as this also affects my credit. I have made attempts to either take part in a home
retention program and/or sell the home.
In regards to my weekend work schedule, I am unable to change my schedule. I was hired on to what my
http://byl47w.bayl47.mail.live.com/mail/PrintMessages.aspx?cpids=adb09823-0327-l leO... 12/8/2010
Page 3 of 3
work calls a "seat." I work alternating weekends. I CAN NOT CHANGE MY WEEKEND WORK SCHEDULE.
My employer has provided a few letters to that effect. When I moved out off the house on October 2-3,
2010 that was my regular weekend to work but I got two 'per diem' nurses to cover for me. One of them
worked for me on Saturday and the other worked for me on Sunday. Our work schedules are out in
advance by at least six weeks. Once our schedules are out we are commited to that schedule. If for some
reason you need a day off that you are scheduled to work that staff member either needs to trade
days/shifts with another staff member (the change can not put either staff member into OT) or find a 'per
diem' staff member to work for them. I was lucky to find two nurses whom were gracious enough to
work for me that weekend, especially since it was short notice.
I declare under the penalty of perjury in the state of Washington that my statements are true to the best
of my knowledge.
Jennifer Shipman
http://byl47w.bayl47.maiUive.com/mail/PrintMessages.aspx?cpids=adb09823-0327-lle0... 12/8/2010
ec. 8. 2 0 1 0
4:15PM
-SCH O r t h o p e d i c s 12535816889
No. 1 004
P. 2 3 / 4 2
Page 1 of 1
Statement of Earnings Details
Print
Close
P ayro ll D etails
E m ployee d e ta ils
Em ployee ID
55218
Pay End Date
Nov 13, 2010
Em ployee Name
SHIPMAN, JENNIFER K.
A dvice #
23124838
Em ployee SSN
XXX-XX-2306
Date
Nov 19, 2010
Home A dd ress
PO BOX 905
PUYALLUP, WA_98371
Com pany
CATHOLIC HEALTH
INITIATIVES
Tax S ta tu s
5ingle
D e p a rtm e n t
3136
Tax A llo w a n ce s
MBO
ST CLARE HOSPITAL
__
Tax D e ta ils
1
Earnings
c u r r e n t E arn in gs .
YTD Earnings
C u rre n t H ours
C u rre n t Rate
REGULAR
48.00
35.4300
1,700.64
50,218.35
SICK
16.00
35.4300
566.88
3,488.11
REST BETWEEN SHIFTS FL$A
08.25
53.1454
43B.45
847.33
DAILY OT
04.75
53.1936
252.67
4,759.04
D e scrip tio n
DOUBLE TIME
00.75
70.8533
53.14
390.4B
WEEKEND DIFF
08.25
3.0000
24.75
951.75
GROUP TERM LIFE
00.00
1.00
21.35
ANNUAL LEAVE CUT
00.00
0-00
1,383.28
HOLIDAY OVERTIME FLSA
00.00
0.00
1,029.42
EDUCATION
00.00
0.00
809.09
PRECEPTOR PAY
00.00
0.00
262.82
ON CALL
00.00
0.00
96.00
SHIFT 2 DIFF
00.00
0.00
30.00
EDUCTION OVERTIME
00,00
0.00
S H IF T 2 D IF F ...........................
00.00
A ccount
Type
C u rre n t Period
Y ea r To Date
MEDICAL PRE-TAX
5-08
116.84
CHECKING
XXXXXX7901
VISION PRE-TAX
2.91
66.93
CHECKING
XXXXXX4757
583.93
11,974.42
43.93
930.18
187.83
3,977.30
50.00
700.00
................ .....33.81
______743.82
FEDERAL INCOME
TAX
Am ount
212.91
_ 1 ,9 1 6 .13_
FTO S u m m a ry
MEDICARE TAX
SOCIAL SECURITY
TAX
CAFETERIA
UNION DUES__ _
20.00
D ire c t D e p o sit D is trib u tio n
T a x e s /D e d u e tlo n s
D e scrip tio n
26.82
____0.0 0.....
E arned th is
P eriod
A va ila b le
Hours
5.68
120.77
............................3,59
59.40
H ours Type
ANNUAL LEAVE
BALANCE
SICK_BALANCE_
Pay s u m m a ry
C u rre n t
YTD
T o ta l G ross
F ede ral T a xa b le Gross
T o ta l T axes
T o ta l D e du ctions
N et Pay
3,037.53
3,029.54
64,150.07
815.69
907.49
2,129.04
64,333.84
Close
16,881.90 -----
IB ,509,49
... ---------
45,803.00
ec. 8. 20 1 0
4 : 1 5PM
*SCH O r t h o p e d i c s 1 2 5 3 5 8 1 6 8 8 9 :
'
Wo. 1004
P. 2 4 / 4 2
Page 1 of 1
Close
-St at e m e n t of Com in g s D etails

P a yro ll D etails
E m ploye s D etails
55218
E m ployee ID
Pay End Date
Oct 30, 2010
Em ployee Name
A dvice #
23082398
Em ployee SSN
XXX-XX-2306
Date
Nov 05, 2010
PlliVtllU /tu lil
PO BOX 905
PUYALLUP, WA 98371
Tax D etails
C om pany
CATHOLIC HEALTH
INITIATIVES
T ax s ta tu s
Single
D e p a rtm e n t
3136
Tax A llow a nce s
MBO
ST CLARE HOSPITAL
E arnings
C u rre n t H ours
C u rre n t Rate
C u rre n t E arn in gs
YTD E arnings
REGULAR
72.00
35.4300
2,550.96
48,517.71
DAILY OT
04.00
53.3700
213.48
4,506,37
WEEKEND DIFF
08.25
3.0000
24.75
927.00
PRECEPTOR PAY
07.25
1.2496
9.06
262.82
GROUP TERM LIFE
00.00
1.00
20.35
SICK
00.00
0.00
2,921.23
ANNUAL LEAVE CUT
00.00
00.00
o.oo
T383.2B
0.00
1,029.42
EDUCATION
00.00
0.00
809.09
REST BETWEEN SHIFTS FLSA
00.00
408.88
DOUBLE TIME
ON CALL
00.00
00.00
0.00
0.00
Q.QO
96.00
SHIFT 2 DIFF
00.00
0.00
30.00
EDUCTION OVERTIME
00.00
0.00
26.82
SHIFT 2.DIFF
00.00
........o.oo
D e s c rip tio n
T a x e s /D e d u c tlo n s
337.34
----- - _
20.00
__ lxj
D ire c t D e p o sit Dls trib u tlo n

Y e a r To D ate
5.08
111.76
CHECKING
XXXXXX7901
199.B4
VISION PRE-TAX
2.91
CHECKING
XXXXXX4757
1,798.48
519.59
64.02
11,390.49
40.48
886.25
173.06
3,789.47
CAFETERIA
25.00
650-00
UNION DUES
33.81
710.01
...............
D e s c rip tio n
FEDERAL INCOME
TAX
A ccount
Am ount
C u rre n t P eriod
MEDICAL PRE-TAX
Type
PYO S um m a ry
MEDICARE TAX
SOCIAL SECURITY
TAX
Earned th is
P eriod
A va ila b le
Hours
ANNUAL LEAVE
BALANCE____
5.55
115.10
SICK BALANCE
3.51
71,81
H ours T ype
Pay s u m m a ry
C u rre n t
YTD
T otal Gross
Federal T axab le G ross
T o ta l Taxes
T o ta l D e d u ctio n s
N et Pay
2,799.25
2,791.26
733.13
799.93
1,998.32
61,296.31
61,120.53
16,066.21
.....17,602,00
43,673.96
Close
ec. 8. 2 0 1 0 ' : 4 : 1 5 P M
.. SCH O r t h o o e d i cs 1 2 5 3 5 8 1 6 8 8 9
No. 1004 P. 2 5 / 4 2
Page 1 of 1
Print
Close
-Sta te m e n t of Earnings D e ta ils

P a yro ll D e ta ils
E m ployee D e ta ils
E m ployee ID
55210
Pay End Date
Oct 16, 2010
Em ployee Nam e
A dvice #
23040369
Em ployee SSN
XXX-XX-2306
D ate
Oct 22, 2010
Hom e A dd ress
PO BOX 905
PUYALLUP, WA 98371
T ax D e ta ils
C om pany
CATHOLIC HEALTH
INITIATIVES
T ax S tatus
Single
D e p a rtm e n t
3136
Tax A llo w a n ce s
MBO
ST CURE HOSPITAL
E arn in gs
C u rre n t H ours
D e s c rip tio n
C u rre n t Rate
C u rre n t E arn in gs
YTD E arn in gs
45,966.75
REGULAR
48.00
35.4300
1,700.64
ANNUAL LEAVE CUT
08.00
35.4300
283.44
1,383.28
DAILY
ot
01.25
53.4560
66.82
4,292.89
WEEKEND DIFF
08.50
3.0000
25.50
902.25
GROUP TERM LIFE
EDUCTION OVERTIME
00.00
00.00
00.00
00.00
00.00
00.00
00.00
00.00
00.00
00.00
SHIFT 2 DIFF ......................_____
00,00
SICK
EDUCATION
REST BETWEEN SHIFTS FLSA
DOUBLE TIME
PRECEPTOR PAY
ON CALL
SHIFT 2 DIFF
1.00
19.35
0.00
0.00
0.00
0.00
0.00
0.00
0,00
0.00
0,00
0.00
2,921.23
1,029.42
609.09
408.8B
337.34
253.76
96.00
30.00
26.82
20.00
D ire c t D e p o sit D is trib u tio n
T a x e s /D e d u c tio n s
C u rre n t Period
Y ea r To D ate
MEDICAL PRE-TAX
5.08
106.68
CHECKING
XXXXXX79Q1
VISION PRE-TAX
2.91
61.11
CHECKING
XXXXXX4~7~57~
335.38
10,870.90
30.00
845.77
128.30
3,616.41
25.00
625.00
D e s c rip tio n
FEDERAL INCOME
TAX
A ccount
Am ount
151.60
1,364.32
PTO S um m a ry
MEDICARE TAX
SOCIAL SECURITY
TAX
CAFETERIA
UNION DUE5
T ype
.........______ 33.81
676.20_
Earned th is
P eriod
A v a ila b le
H ours
ANNUAL LEAVE
BALANCE
4.18
109.55
SICK BALANCE
2.64___
H ours Type
_____ 68.30.
Pay S u m m a ry
C u rre n t
T o ta l Gross
F ederal T a xa b le Gross
T o ta l Taxes
T o ta l D e du ctions
N et Pay
2,077.40
2,069.41
493.68
560.48
1,515.92
YTD ............. .......... 58,497.06
58,329.27___
Close
15,333.08
..................16,802.07....
41,675354
Dec. 8. 20 1 0
4 : 1 3PM' SCH O r t h o p e d i c s 1 2 5 3 5 8 1 6 8 8 9
DIVISION OF CHILD SUPPORT

PO BOX 11520
TACOMA WA 98411-5520
No. 1004 > -P. 6/42'
STATE OF WASHINGTON
DEPARTMENT OF SOCIAL AND HEALTH SERVICES
DIVISION OF CHILD SUPPORT (DCS)
'M'iiSfiji-aa SMI}
=j9| l\ Utpajonent,bfSocial
/ll l l V-ftKtSjftServices :
li0&rbRi^h:%Vi*W'9^Ps8rt'
233 47 1
16864
PO BOX 905
PUYALLUP WA 98371-0078
DATE; 11/05/2010
___________ Child Support Distribution and Disbursement Statement__________

This statement tells you how the Division of Child Support (DCS) applied collections on your case(s) (distribution) and
how DCS determined the amount of child support collections that were sent to you (disbursement) during the period set
out below. DCS distributes collections according to state and federal law. You only receive a statement for a period
DCS receives a collection.____________________________________________ ____________________
The amounts below are the combined totals for all of your child support cases.
A. DCS received a total of $ _____ 180.00
support for your case(s) from OCT 01. 2Q1Q to OCT 31.2010 DCS distributed the money as follows;
1.
$ 180,00_______ to paycurrent cash support for the month.
2. $ ______ ôq_______ to paycurrent cash medical support owed for the month.
3. $ ______ jjg______ to paypast-due cash support owed to you,
4. $ ______ op
to paypast-due cash medical support owed to you.
5. $ ______ jpg______ to the State to repay past public assistance (AFDC/TANF) paid to you. As of the date of
this notice, the State claims an additional $ ________ .00
to repay public assistance paid to you in the past.
6.
$ _____ op
to the State to repay past Medicaid expenses on behalf of you and your children.
B. From the total amounts listed in sections A1 through A4 above, DCS kept the following amounts:
1.
.op_______to repay cash support paid to you in error.
2. $
,oq _______to pay the $25,00.annual fee. The paying parent receivescredit against the support debt
for the full amount of the collection even though DCS kept part of the collection to pay the fee. You are required
to pay the fee if you never received Temporary Assistance for Needy Families (TANF), Tribal TANF, or Aid to
Families With Dependent Children (AFDC) for minor children and DCS has sent at least $500.00 in support
collections to you in the current federal fiscal year.
C. From the total amounts listed in section A above, DCS sent you the following amounts:
1.
180-00 _____ to Pgy 035,1 support owed to you.
2. $ ______j 30_______as a cash support pass-through (if you are currently receiving public assistance).
If you disagree with the way DCS distributed your support, you may:
1. Write or call DCS to discuss your concerns.
2. Ask for a hearing unless your disagreement is about the $25.00 annual fee. You must ask for a hearing before
02/03/2011
T request a hearing, complete page 3 and return it to DCS.
If you disagree with the $25,00 annual fee because it creates a hardship for your family, you may request a Conference
Board. A Conference Board will determine if DCS will waive the fee.
c h il d s u p p o r t d is t r ib u t io n
DSHS 16-511 (REV. 03/2009)
AND DISBURSEMENT s t a t e m e n t
Page1
* - D e c . 8. 20 1 0 4 : 1 3 P M . . . ^ SCH O r t h o p e d i c s 1 2 5 3 5 8 1 6 8 8 9
No. 1004-
P. 7 / 4 2
STATE OF WASHINGTON
DEPARTMENT OF SOCIAL AND HEALTH SERVICES
DIVISION OF CHILD SUPPORT (DCS)
DIVISION OF CHILD SUPPORT

PO BOX 11520
TACOMA WA 98411-5520
l pi<;s DNLlah bf ChlldSupporf
242 40 1
16970
PO BOX 905
PUYALLUP WA 98371-0078
DATE: 10/07/2010
|l.l.]|.||l|i|li|il||| | llii| ll.liil| | lll| lllll| ...| i |||M|l|ii||l
Child Support Distribution and Disbursement Statement

This statement tells you how the Division of Child Support (DCS) applied collections on your case(s) (distribution) and
how DCS determined the amount of child support collections that were sent to you (disbursement) during the period set
out below. DCS distributes collections according to state and federal law. You only receive a statement for a period
DCS receives a collection._______________________________ __________________ ____________
.
The amounts below are the combined totals for all of your child support cases.
A. DCS received a total of $ _____ 780.02
support for your case(s) from SEPT 01,2010 to SEPT 30. 2010 .
DCS distributed the money as follows:
1. $
78Q.Q2_______
pay current cash support for the month.
2. $
op_______ topay current cash medical support owed for the month.
3. $ ______ jô_______ to pay past-due cash support owed to you.

4. $ _____J20________ to pay past-due cash medical support owed to you.
5. $ ______ .gg_______ tothe State to repay past public assistance (AFDC/TANF) paid to you. As of the date of
this notice, the State claims an additional $ ________ .00
to repay public assistance paid to you in the past.
6. $ _____ .gg_______ to the State to repay past Medicaid expenses on behalf of you and your children.
B. From the total amounts listed in sections A1 through A4 above, DCS kept the following amounts:
1.
.op_______ to repay cash support paid to you in error.
2. $ ______ .go_______ to pay the $25.00 annual fee. The paying parent receivescredit against the support debt
for the full amount of the collection even though DCS kept part of the collection to pay the fee. You are required
to pay the fee if you never received Temporary Assistance for Needy Families (TANF), Tribal TANF, or Aid to
Families With Dependent Children (AFDC) for minor children and DCS has sent at least $500.00 in support
collections to you in the current federal fiscal year.
C. From the total amounts listed in section A above, DCS sent you the following amounts:
1.
2. $
78Q.Q2________ to pay cash support owed to you.

,oo________as a cash support pass-through (if you are currently receiving public assistance).
If you disagree with the way DCS distributed your support, you may:
1. Write or call DCS to discuss your concerns.

2. Ask for a hearing unless your disagreement is about the $25.00 annual fee. You must ask for a hearing before
01/05/2011
To request a hearing, complete page 3 and return it to DCS.
If you disagree with the $25.00 annual fee because it creates a hardship for your family, you may request a Conference
Board. A Conference Board will determine if DCS will waive the fee.
CHILD SUPPORT DISTRIBUTION AND DISBURSEMENT STATEMENT
DSHS 13-511 (REV. 08/2009)
Page 1
1 2 /S ^ e x a
[')a hi
L I* < )
iv o ii& fh
For Petitioner
RE
For Respondent
( 2 o ivV - *\K k
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___________t _________._________"'_______________________________.______________________
(-C
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December 9, 2010 9:30 AM
6^ >
ontempt Hearing
Mark L Gelnnan
Salman
KJ4 W p u J
S > c2 j
i 'c t I
Courtroom number 117

Calendar C2 - SHOWCAUSE/FAMILY LAW
Run date/time 12/09/10 8 02
Ixcrtrpt pbl djoumaêntry^showcause^port
Jjgr NMtP&C
S m /P m A a J
No. / o - 1 - 0 0 9 6 / - !
Petitioner(s),
and
ORDER
P /rt/lrJ
[ ] Clerks action required
Respondent(s).
THIS MATTER having come before the Court upon the moving partys Motion, and the
ORDERED, ADJUDGED AND DECREED_____________________________________
___________ lJH 6n
rOATTFJt
Dfi>r
, 7 0 - V S ' n a te
T )m e
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_______
C /jr ^ C s
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WPF DRPSCU 01.0150 (6/2006)
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WPF DRPSCU 01.0150 (6/2006)
F\Word\Commissioners Business\Ex Parte Dept\Courtroom Forms\Blank order #2. DOC
E-FILED
December 30 2010 10:03 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)

Phone: (253) 770-0808

Show Cause
N a tu re o f H earin g:
Contempt
CALENDAR DATE: Monday, February
1 4 , 2011
9 :3 0
AM
W O R K IN G C O P IE S S H A L L BE S U B M IT T E D T O C O M M IS S IO N E R S S E R V IC E S R O O M 140,
B E F O R E 12:00 NO O N T W O C O U R T D A YS P R IO R T O H E A R IN G
DA TED :
December 30, 2010.
S ign ed :
/s/ Daniel N Cook
NA M E:
Daniel N Cook
Phone:
(253) 581-0660
W SBA#:
34866
A D D R E S S : 5920 100th St SW Ste 25
For:
1 of
10-3-00961-1
35725210
MTSC
01-18-11
AM.
JA N ig 2flii PM
.DEPUTY

No. 10-3-00961-1
Petitioner,
and
_______________________ Respondent.

SHOW CAUSE RE
CONTEMPT/JUDGMENT
AND FOR OTHER RELIEF (MTSC)
I. MOTION
JASON W. SHIPMAN moves the court for an order directing JENNIFER KAY SHIPMAN
to appear personally before the court and show cause why an order should not be
entered:
1.1
FINDING CONTEMPT.
PARENTING PLAN
Signed by the court on August 24, 2010, in Pierce County, Washington.
Show Cause Re Contempt/ Judgment (Mtsc)- Page 1 Of 3

WPF DRPSCU 05.0100 (6/2008)
RCW26.09.l60Shipman, Jennifer v Jason
S:\CASES1\SfrJpman, Jason dteso\Wortf\PLADlNGS\Disso\Motk>n to Show Cause re

Contemptdoc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
11484
IS 1 9 /2 0 1 1
18884
1
12
ESTABLISHING A JUDGMENT.
2
Does not apply.
3
4
1.3
INCLUDE LANGUAGE
GRANTING SANCTIONS.
1.4
OTHER:
That Respondent be granted an award of attorney's fees in an amount of no less
than $1,500.00 payable to the law office of FAUBION, JOHNSON, REEDER&
FRALEY, P.S., for the necessity of bringing this motion.
10
11
DATED this /f f l^ dav of January 2011
12
13

& COOK, P.S.
Daniel N. Cook, WSBA 34866

14
15
II. DECLARATION
16
17
18
JENNIFER KAY SHIPMAN should be held in contempt for the following reasons:
Failure to comply with the Parenting Plan as follows:
19
The parenting plan dated August 24, 2010, said that if I resided in the childrens school
20
district, .the children would be permitted to enjoy more residential time with me. When
21
that parenting plan was entered, the children were enrolled in Woodland Elementary
22
and Rogers High School.
23
24
25
I moved into a home less than 5 minutes walking time from
Rogers High School.

Less than one month after I moved into that residence which would allow the
children more time with me, Petitioner moved the children out of their prior school.
Show Cause Re Contempt! Judgment (Mtsc)- Page 2 Of 3
W PF D R P S C U 05.0100 (6/2008)
R CW 26.09. ISOShipm an, Je n n ife r v Ja so n
S:\CASES1\Shipman, Jason di$so\WonfPLEADING$^Disso\Motion to Show Cause re

Contempt.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
11484
19^2811
10B 0S
Petitioner did not notify me or get approval for the move. The parenting plan dated
August 24, 2010, requires joint decision making for educational decisions. The move
out of the school they were in violated the parenting plan because she did not notify,
consult or otherwise obtain consent for the change in schools. The change in schools
was completely unilateral and was an intentional violation of the joint decision making
requirements. The change was in bad faith because it was done entirely to eliminate
the additional residential time the child would be spending with me when l moved closer
to their old school. Petitioner should be held in contempt for violating the parenting
plan.
the foregoing is true and correct to the best of my knowledge.
Signed at Lakewood, Washington, on January___, 2011.
Show Cause Re Contempt) Judgment {Mtsc}- Page 3 Of 3

W PF D R PSCU 05.0100 (6/2008)
RCW26.09.1SOShipman, Jennifer v Jason

S:\CASES1\Shiprmn, Jason
Contemptdoc
di3soWonfPLEAD1NGS\Disso\Motion to Show Causa re
FAUBJON, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
11484
1 ^ 1 9 /2 8 1 1
la e & fc
s ^ v /w -W
Petitioner,
vs.
no.
T)/=)a/7 < :
DECLAFtATION RE: FAr SIGNATURE

(NPF)
S h -i P / ^ ^
Respondent.
It
(0 -3 -0 O 9 C /-
<^X7h _______________ ___________, declare under penalty of
perjury under the laws of the State of Washington, that the faooimilo documents
attached to this declaration, consisting of
pages including this declaration page,
is a complete and legible fseeamtie that I have examined personally and that was
received by me via
Dated
/ /
' &
at the following r
/ /
D /9 /^ t4 c
Printed Name
DccUmwn Re: FAX Sitnaturc.doc (6-2001) P*e I of l
11484
I
I I Nil
1 /1 9 /2 8 1 i
10807
II II!
ill I
10-3-00961-1
35725221
1
2
IN COUNTYCLERKS OFFICE
AM
...
J a n 18 2011
pu
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NO. 10-3-00961-1
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Petitioner,
v.
______________________ Respondent.
Order to Show Cause re

Contempt
(ORTSC)
Clerk's Action Required
14
It is Ordered:
15
16
17
18
JENNIFER KAY SHIPMAN shall appear in person before this court at the place and
time below and show cause why the relief requested in the motion should not be
granted.
Date: February 14, 2011
Time: 9:30 ^p)/p.m .
Place: Pierce County Superior Court
Room/Department: TBA
19
20
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If you fail to appear in person and defend at these proceedings the court may grant all
of the relief requested and/or issue a bench warrant for your arrest without further notice
to you.
If imprisonment is requested in the motion and you cannot afford an attorney, you may
request the court to appoint an attorney to represent you.
23
Other:
24
Dated:
25
Ord to Show Cause re Contempt (ORTSC) - Page
WPF DRPSCU 05.0150 Mandatory (6/2008) - RCW 26.09.160

S :\C A S E S l\S hipm an, Jason disso\W ord\P LE A D lN G S \D isso\O rderto S how Cause
C ontem pt.doc
re

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
11484
1 /1 9 ^ ^ 8 1 1
18088
1
2
Presented By:
FAUBION, REEDER, FRALEY & COOK, P.S.
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Ord to Show Cause re Contempt (ORTSC) - Page 2 of 2
WPF DRPSCU 05.0150 Mandatory (6/2008) - RCW 26.09.160

S:\CASBS1\Shipm an, Jason disso\W orcAPLEAD!NGS\Disso\Order to S how Cause re
C ontem pt.doc

& COOK, P.S.
5920-100th Street SW, Ste 25
Lakewood, WA 98499
253-581-0660
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
February 08 20'
KEVIN ST
COUNTY C
NO: 10-3-0
2
3
4
5
6

County of Pierce
In re th e M arriag e of :
8
No. 10-3-00961-1
P etitio n er(s),
an d
10
11
R espondent(s).
D eclaration of
C O UNSEL IN O PPO SITIO N TO
RESPO N D EN TS MOTION TO
SHOW CAUSE RE CO N TEM PT
(D C LR Modified)
12
13
The m otion a n d d eclaratio n do n o t specify how th e p a re n tin g p la n is v io lated by

14
15
p e titio n e rs move. P e titio n e r h a s n o t relo cated to a n o th e r school d istrict, b u t m erely

allow ed th e ch ild ren to be tra n s fe rre d to a n o th e r school w ith in th e sam e school d istric t.
16
R esp o n d en t accordingly still resid es in p e titio n e rs school d istric t an d he is b ein g provided
17
w ith th e in c reased re s id e n tia l tim e p e r th e p a re n tin g plan.
18
19
The move is n o t an ed u catio n al decision re q u irin g jo in t decision m a k in g . P e titio n e r h a s th e
20
rig h t to move for economic reaso n s. T his issu e only a rises b ecau se R esp o n d en t h a s b een
21
provided, u n d e r th e p a re n tin g p la n , w ith s u b s ta n tia l v isita tio n rig h ts allow ing him to have
22
23
th e c h ild ren u n til M onday m o rn in g so th a t he can ta k e th e m to school.
Declaration of Counsel
In Opposition to Respndents
Motion to Show Cause Re Contempt


PH:(253) 770-0808, Fax (253) 770-0259
No additional visitation time has been lost. Respondent is perhaps inconvenienced by
h av in g to drive th e ch ild ren to th e new school.
3
4
5
I declare u n d e r p e n a lty of p e rju ry u n d e r th e law s of th e s ta te of W ash in g to n th a t th e

S igned a t P u y a llu p , W ash in g to n on F e b ru a ry 7 , 2011..
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/s/T im othy M. G reene____________________

S ig n a tu re of D e c la ra n t
T im othy M. G reene
P r in t or Type N am e

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Declaration of Counsel
In Opposition to Respondents
Motion to Show Cause Re Contempt


PH:(253) 770-0808, Fax (253) 770-0259
E-FILED
IN COUNTY' CLERK'S OFFICE
February 09 2011 2:0 PM
KEVIN STOCK
COUNTY CLERI
NO: 10-3-0096 -1
Superior Court o f Washington

County o f Pierce
No. 10-3-00961-1

Petitioner,
RETURN OF SERVICE
and
JASON VWLLIAM SHIPMAN,
Respondent.
1Declare.
1.
i, \ v~î I c - ^
party to this action.
2.
Is e r v e d .
1.
2.
3.
3.
M r Cl p \ r , am over the age of 18 years, and I am not a
OLpHAh)i/ith the following documents:
Motion for Order to Show Cause re Contempt;

Order re Contempt; and
Note for Commissioners Calendar on February 14, 2011.
The date, time and place of service were:

Date:. ^ J ^ j i )
Address:
Return of Service -1
// ?x \
Time:
a
s ts
0 Q
j.m./^Tm?^
4.
Service was made pursuant to Civil Rule 4(d):

Does not apply.
5.
Service of Notice on Dependent of a Person in Military Service.

Does not apply.
I declare under penalty of perjury under the laws of the state of Washington that
the foregoing is true and correct
Return of Service - 2
E-FILED
February 10 2011 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
IN THE S U PER IO R COURT OF THE STATE OF W ASHINGTON

NO. 10-3-00961-1
Petitioner,
v.
REPLY DECLARATION
OF JASON SHIPMAN

_______________________ Respondent.
I,
JASON SHIPMAN, make this reply declaration on the basis of my personal
knowledge. I am the Respondent in this matter and competent to testify.

I first note that Petitioner has filed NO DECLARATION W HATSOEVER.
only response Petitioner has made is a statement of counsel.
testimony.
This is not evidence.
The
This is not sworn
The statement of Petitioners attorney is argument
only but cannot be used to rebut the factual contentions in my moving declaration.
Furthermore, the statement of Petitioner's counsel is wrong.
On the one hand,
Petitioners attorney argues (without an evidentiary basis) that Petitioner moved

because of economic reasons.
Then Petitioners attorney tries to imply the children

C:\Documents and Settings\dcook\Local Setting$\Temporary Internet
Files\Content. Outlook\ 13RLZYMV\Reply Declaration of Jason Shipman - PP.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
wanted to move by saying Petitioner "allowed the children to transfer to another school.
Not only is the implication the children wanted to move contradicted by the statement
that it was Petitioners voluntary choice, there is absolutely no truth whatsoever to the
implication that the children want to change schools. The fact is, Petitioner forced the
children to change schools.
I do not think even think that Petitioners move to the new apartment "required a
change in schools.
I fully believe that the childrens prior school would have allowed
them to remain in their current classes and buildings and with their current teachers and
peers even though Petitioners residence had changed.
But instead of trying this
approach, Petitioner willfully, intentionally and unilaterally decided to change the

childrens school.
I was not consulted in any manner whatsoever until after the move
had occurred. Petitioner just told me to drop the children off at a new school on Monday
when I picked them up on Friday for visitation.
Petitioners relocation to effectuate a change in schools was a malicious act.
This act is absolutely a bad faith violation of the joint decision making requirements.
The home I moved into was within walking distance (literally next door to the school with
only a field in between) of Tylers school. Tyler has helped me move in and was excited
about the opportunity to spend more time with me.
Petitioner intentionally moved and
changed the childrens school because Tyler (our son together) was stopping by and
spending time at my house after school. When the Petitioner found out, she called me
and threw a temper tantrum. Petitioner stating she was going to "put an end to Tytler
spending extra time at my house.
Petitioner repeatedly stated, "I did not authorize it
over and over again, as she was yelling at me about Tyler dropping by after school.

C:\Documents and Settings\dcook\LocaI Settings\Temporary Internet
Files\ContentOutlook\13RLZYMV\Reply Declaration of Jason Shipman - PP.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood WA 98499
253-581-0660
Petitioners attorney also somehow tries to assert that changing a childs school
is not an educational decision. This is absurd. Changing a childs school is perhaps,
the most basic and essential educational decision which can be made.
This decision was made right in the middle of a semester.
The decision resulted
in the children being taken out of the schools they had attended for many years. For
Hunter he has been in the same school building for four years.
For Tyler, he had been
in his school building for three years and it was less only because he recently moved up
to high school.
Prior to Petitioners unilateral act Tyler had been with the same group
of classmates more than 10 years, since first grade.

The decision has had adverse affects on Tyler.
Tyler has been having trouble in
school since his freshman year of high school and I absolutely think that moving him in
the middle of his Junior year has compounded those problems.
For several months
after the move he refused to go to school - at least when he was attending with the
class he had been with for years he was going to school.
Significantly, Petitioner moved into an apartment complex. In other words, it was
not as if she even found a perfect rental home for her situation that she absolutely could
not pass up.
It was an apartment context and there are literally hundreds of vacant
apartments which would have been on the same side of Meridian as the childrens
schools.
Petitioners argument that her decision was necessitated by finances is also
completely ridiculous.
Petitioner had stopped making the house payment months in
advance of her move.
It was not as if she had to move because she could no longer
pay - she had not even been paying. She had saved and had money in the bank from

C:\Documents and Settings\dcook\LocaI Settings\Temporary Internet
FiIes\Content. OutIook\13RLZYMV\Repiy Declaration of Jason Shipman - PP.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood WA 98499
253-581-0660
months of unpaid mortgage payments and in fact, her non-payment of the mortgage is
another reason I am asking the court to find her in contempt.
In summary, Petitioner made a unilateral decision that substantially affected the
childrens education and her failure to make this a joint decision was clearly in bad faith.
Petitioner did not talk to me in advance. Petitioner did not attempt dispute resolution. I
was not allowed to get input from the children or the childrens teachers or offer
alternatives (e.g., leaving the children where they were in school but still allowing
Petitioner to move). Petitioner just decided she did not like how close the children were
to me, and the fact that they were spending extra time at my house, so she Petitioner
chose to move and change their school.
Petitioner even chose an apartment which
was on the other side of Meridian and therefore Petitioner was allowed to change the
childrens schools. There are lots of apartments she could have moved into that would
have left the kids in their schools. All of those apartment complexes do price matching.
The petitioner has been using the children as a weapon for a long time.
The semester just ended, so I am asking the court to find the petitioner in
contempt and order the children back to their original schools.
It is my understanding
that both children would prefer to be in the prior school than remain at the new school. I
would not ask for this relief if I did not believe that was what the children wanted.
believe the children miss their friends and the teachers they had in the old school.
also believe that since the semester just ended the timing for a move back is also more
advantageous.
Finally the Petitioner asked for half the daycare fees and gave a made up
number. I told the court there was no daycare and was no plans for daycare. Back in

C:\Documents and Settings\dcook\Local Settings\Temporary Internet
Files\Content.Outlook\13RLZYMV\Reply Declaration of Jason Shipman - PP.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood WA 98499
253-581-0660
August, the court ordered me to pay half upon being given a receipt.
are not in daycare.
But the children
If the children require daycare at this point, it is because of her
voluntary choice to move.
I believe the court should change the order to state the
petitioner is responsible for daycare.
Alternatively, the Petitioner can drop the children
off at my home or my mothers home before school because both my mom and I live
very close to the childrens school and can ensure the children are cared for between
the time Petitioner has to go to work and when school begins.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE
OF W ASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
Signed at
L t ^
k ,_________________ , Washington, on February
, 2011.
JASON SHIPMAN

Files\Content.Outlook\13RLZYMV\Reply Declaration o f Jason Shipman- PP.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
\a ^ g .r ~ f
Q u o t 'd . I
L lrti/J
For Respondent
For Petitioner
RE: _
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February 14, 2011 9:30 AM
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C O L K < f i l ; * ci ,
Show Cause
MARY E. DICKE
Clerk:*fr)*<JLu^
R -A > .' 7

Run date/time 02/14/11 10:13

(xcrtrpt.pbl dJo umat_entry_showcau$e_report
1867 2 -'15x2*5! j
10-3-00961-1
35885434
ORCN
3-*9_i0tf jlij
02-14-11
2
3
4
IN C0UNTYFCLERK'S OFFICE
FEB 1 4 2011 ejl
S S S K ^ - t. .
------- " y DEPm
8
9
IN THE SUPERIO R COURT OF THE STATE OF W A SHING TO N

IN AND FOR THE CO UNTY OF PIERCE
10
NO. 10-3-00961-1
Order on Show Cause re

Contem pt/Judgm ent
(ORCN)
Next Hearing Date:
11
12
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14
Petitioner,
v.
_______________________ Respondent.
[ ] Clerk's Action Required, U 3.8
15
I. Judgm ent Summary
16
Applies as follows:
17
18
19
20
A.
B.
C.
D.
E.
21
F.
22
G.
H.
23
24
25
J.
K.
L.
Judgment creditor
~
Jason William Shipman________
Judgment debtor
Jennifer Kav Shipman_________
Principal judgment amount (back child suuuui l/i8eJ]caTsupporf7othQjLohligatinng/
naaintonanooH iuin (UateT
through (date)
_______
$
/,*
Interest to date of judgment
$ ________________
Attorney fees
$ ________________
Costs
$ ________________
$
Principal judgment shall bear interest at \ D
% per annum
Attorney fees, costs and other recovery amounts shall bear interest at
|
% per annum
Attorney for judgment creditor
Daniel N. Cook_____
Attorney for judgment debtor
Timothy Greene
Other:
Ord on Show Cause re Cntmpt/Jdgmnt (ORCN) - Page 1 of 6

WPF DRPSCU 05.0200 Mandatory (10/2009) - R C W 26.09.160, 7.21.010

S:\CASES1\Shipman, Jason disso\iVord\PLEADINGS\Disso\Order re Contempt.doc

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
Ii8t'7
15/2611
398183
1
II. Findings and Conclusions
2
This Court Finds :
3
4
2.1
JENNIFER K. SHIPMAN intentionally failed to comply with a lawful order of the

court dated on August 24, 2010.
Com pliance W ith C ourt Order
2.2
Nature of Order
The order is related to parenting plan (custody/visitation).
8
2.3
How the Order w as Violated
This order was violated in the following manner (include dates and times, and
amounts, if any):
10
11
See Motion and Declaration to Show Cause re Contempt entered on

January 18, 2011.
12
13
2.4
Past Ability to Comply With Order
pc
JENNIFER K. SHIPMAN did at-have the ability to comply with the order as
follows:
14
15

January 18, 2011.
16
17
18
19
20
2.5
Present Ability and Willingness to Comply With Order
pc
JENNIFER K. SHIPMAN does-flt have the present ability to comply with the order
as follows:
January 18, 2011.
21
22
23
24
JENNIFER K. SHIPMAN does Bftt have the present willingness to comply with the
order as follows:
January 18, 2011.
25
S:\CASES1\Shipman, Jason disso\WorrfPLEAD!NGS\Disso\Order re Contemptdoc

& COOK, P.S.

Lakewood, WA 98499
253-581-0660
:9ii
39e
1
2
2.6
Back Child Support/M edical Support/Other Unpaid Obligations/Maintenance
Does not apply.
4
5
2.7
Com pliance W ith Parenting Plan

JENNIFER K. SHIPMAN has not complied with
the fSiSontial (m itS fgn) provisions of the parenting pian and had the ability
to comply with the parenting plan, and is currently janwilling to comply. The
noncompliance with the residential provisions was in bad faith.
8
9
2.8
10
Attorney Fees and Costs

The attorney fees and costs awarded in paragraph 3.7 below have been incurred
and are reasonable.
11
III. O rder and Judgm ent
12
13
It is Ordered:
14
3.1
15
16
3.2
3.3
, ^
Additional Residential Time
A t^ [
nMII hnvn irlrlfhnnl r~irHnn4ifil f r r r nn fn lh ir r
^ IAf i7 N
ch/ld&n
c Moot
22
24
Im prisonm ent
21
23
in contempt of court.
Does not apply.
19
20
Contem pt Ruling
JENNIFER K. SHIPMAN [Îs [$
17
18
f>^
Th
S//&X
m yoweo
//v oJtf/C/-/ 7?fy
Z U tN M rf
Of
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id
pe/o/Z
fp r
so m e
* *
/Y )6 Thkff?
SO /dO *
S a m p fi& p e s S M c c e m m s M e ^
3.4
Judgm ent for Past Child Support
25
Does not apply.


S :\C A S E S 1 \S h ip m a n , J a s o n d is s o \W o rd \P L E A D IN G S \D is s o \O rd e rre C o n te m p t.d o c

& COOK, P.S.
Lakewood, WA 98499
253-561-0660
7 r/ 1-q~f -/ 7l.pu 4i ^
390165
UD i
1
2
3.5
Judgm ent for Past Medical Support

Does not apply.
3.6
Judgm ent for Other Unpaid Obligations

Does not apply.
6
3.7
Judgm ent for Past Maintenance
7
Does not apply.
8
3.8
Conditions fo r Purging the Contem pt
9
[ ]y
M
10
11
Does not apply.

The contemnor may purge the contempt as follows:
(njm p u A ^ c _
u j/fH
3 .3
/) r * jD
j> J / ,
0 ^
12
13
14
15
3.9
16
Does not apply.

(Name) A f i t o N
S h U D /n A jJ
shall have judgment
against
(name) J g /V A V p 4
t
in the amount of $
J? ) , 7 Y ), SP
for attorney fees ancH S, =-
" t o costs.
vT
17
18
19
3.10
fo e fH 0
Review
fiew Date
P>mHHY
## .
& / >
F r -
DO
s r ttu lir 1.
20
21
[]
Does not apply.

The court shall review this matter on (date)
at (time)
22
23
24
25
3.11
Other
in n
f m w p-vw orJ6 e
'
^
Aencj a t
f^ fc /^ T }
H ST
Ck f S P ^ L e ^ ^ A c t C C 0P & 4X
r /9 /c e o &
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/><L #6r /H
* f* s* c e .
I
te r n * * * * * * * < - & * * * ^ 5 ^

WPF DRPSCU 05.0200 Mandatory (10/2009) - RCW 26.09.160, 7.21.010

S:\CASES1\Shipman.Jason disso\WonJ\PLEADINGS\Disso\OrderreContempt.doc

& COOK, P.S.
Lakewood WA 98499
253-581-0660
11867
2 /1 5 '2 8 1 1
398166
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3.12
Sum m ary of RCW 26.09.430 - .480, Regarding Relocation o f a Child

This is a summary only. For the full text, please see RCW 26.09.430 through
26.09.480.
If the person with whom the child resides a majority of the time plans to move,
that person 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 R CW 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.
15
If information is protected under a court order or the address confidentiality

program, it may be withheld from the notice.
16
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.
17
18
Failure to give the required notice may be grounds for sanctions, including
contempt.
If no objection is filed within 30 days after service of the notice of intended
19
relocation, the relocation will be permitted and the proposed revised residential
20
schedule may be confirmed.
21
22
23
24
25
A person entitled to time with a child under a court order can file an objection to
the childs relocation whether or not he or she received proper notice.
An objection may be filed by using the mandatory pattern form W PF DRPSCU
07.0700, (Objection to Relocation/Petition for Modification of Custody
Decree/Parenting Plan/Residential Schedule). The objection must be served on
all persons entitled to time with the child.

S:\CASES1\Shipman, Jason disso\Word\PLEADINGS\Disso\Order re Contempt.doc

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
186?
2 / i 5 ^ 2 l l
39616?
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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.
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If the objecting person schedules a hearing for a date within 15 days of timely
service of the objection, the relocating person shall not move the child before the
hearing unless there is a clear, immediate and unreasonable risk to the health or
safety of a person or a child.
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W arning: Violation of residential provisions of this order with actual knowledge of its
terms is punishable by contempt of court and may be a criminal offense under RCW
9A.40.060(2) or 9A.40.070(2). Violation of this orderjpoayLûbject a violator to arrest.
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Dated:
'r ^
I t (_________
\
/ ' s C ~ ^ M a r y E . D icke
Jtfdg& Com m issioner
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C0UNTyFcurb 's 0FFlcj
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Presented by:
FAUBION, REEDER, FRALEY & COOK,
P.S.
Approved by;
Noticaof presentation
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ne, W S B A # 17499
etitioner

Approved and agreed by:
A signature below is actual notice of this
order.
,
Approved and agreed by:

A signature below is actual notice of this
order.
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son Shipman, Respondent
Date
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WPF DRPSCU 05.0200 Mandatory (10/2009) - RCW 26.09.160, 7.21.010
S:\CASES1\Shipman, Jason disso\Word\PLEADINGS\Disso\Orderre Contempt.doc

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
February 25 20'
KEVIN ST
COUNTY C
NO: 10-3-0
2
3
4
5
6

County of Pierce
In re th e M arriage of :
8
No. 10-3-00961-1
P etitio n er(s),
an d
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R espondent(s).
PETITIO NERS MOTION FOR

REVISION OF FEBRUARY 14,
2011 ORDER OF CO NTEM PT
(Non-m andatory Form)
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P e titio n e r J e n n ife r K ay S h ip m an , th ro u g h u n d e rsig n ed counsel, h ereb y m oves th e co u rt for
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a n o rd er rev isin g th e O rd er on Show C ause Re: C o n te m p t/Ju d g m en t e n te re d on F e b ru a ry
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14, 2011. Ms. S h ip m an re q u e sts a revision of th e following p a ra g ra p h s:
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P a r a g r a p h 2.1 a n d 2.2: J e n n if e r S h ip m a n in t e n t io n a lly fa ile d to c o m p ly w ith a
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la w fu l o r d e r o f th e c o u r t d a te d o n A u g u s t 24, 2 0 1 0 ....T h e o r d e r is r e la te d to
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p a r e n tin g p la n (c u s to d y /v is ita tio n ). Ms. S h ip m an con ten d s th a t th e re w as n e ith e r an

in te n t to fail to com ply n o r a failu re to com ply w ith th e p a re n tin g p lan . H ence th e
p a ra g ra p h s should be strick en . In addition, she con ten d s th a t th e d eclaratio n in su p p o rt of
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th e m otion does n o t com ply w ith th e re q u ire m e n ts of RCW 9A.72.085 in th a t it w as not

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dated.
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23
m t t i rn ei-!! Mo on for ReYisin

of February 14, 2011 Order of
Contempt

Ph.:(253) 770-0808, Fax (253) 770-0259
1
2
P a r a g r a p h 2.3 T h is o r d e r w a s v io la t e d in th e fo llo w in g m a n n e r (in c lu d e d a te s
a n d tim e s , a n d a m o u n ts , i f an y): S e e M o tio n a n d D e c la r a tio n to S h o w C a u s e re
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C o n te m p t e n te r e d o n J a n u a r y 18, 2011:. B ecause Ms. S h ip m an con ten d s th a t th e re

w as n e ith e r a n in te n t to fail to com ply n o r noncom pliance w ith th e p a re n tin g p lan , th a t
th is p a ra g ra p h sh o u ld be strick en .
P a r a g r a p h 2.7:
J e n n if e r K. S h ip m a n h a s n o t c o m p lie d w ith th e jo in t d e c is io n
p r o v is io n s o f th e p a r e n tin g p la n a n d h a d th e a b ility to c o m p ly , a n d is c u r r e n tly

9
w illin g [s ic ] to c o m p ly . T h e n o n c o m p lia n c e w ith th e r e s id e n t ia l p r o v is io n s w a s in

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b a d fa ith :
B ecause Ms. S h ip m an con ten d s th a t th e re w as n e ith e r an in te n t to fail to
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com ply nor noncom pliance w ith th e p a re n tin g p lan , th a t th is p a ra g ra p h sh o u ld be strick en .

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P a r a g r a p h 2.8: T h e a tt o r n e y fe e s a n d c o s t s a w a r d e d in p a r a g r a p h 3.7 b e lo w h a v e
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b e e n in c u r r e d a n d a r e r e a s o n a b le . B ecause th e re w as n e ith e r a n in te n t to fail to
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com ply n o r noncom pliance w ith th e p a re n tin g plan, as a ss e rte d in th is m otion, th e
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a tto rn e y s fees an d costs to b rin g th is m otion are n o t reaso n ab le an d th is p a ra g ra p h should
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be strick en .
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Petitioners Motion for Revision

Contempt

Ph.:(253) 770-0808, Fax (253) 770-0259
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P o r tio n s o f th e r ec o r d r e le v a n t to t h is m o tio n :
1) N ote for C om m issioners C a le n d a r:
10/15/10
2) M otion for O rd er to Show C au se re C o n te m p t/Ju d g m en t
10/15/10
3) O rd er to Show C ause re C o n te m p t/Ju d g m en t
10/15/10
4) D eclaratio n of C ounsel for P e titio n e r
11/30/10
5) R eply D eclaratio n of R esp o n d en t
12/02/10
6) S u p p le m e n ta l D eclaratio n of C ounsel for P e titio n e r
12/03/10
7) C lerks M in u te E n try
12/06/10
8) O rd er for C o n tin u an ce
12/07/10
9) Second S u p p le m e n ta l D eclaratio n of C ounsel for P e titio n e r
12/09/10
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10) T h ird S u p p le m e n ta l D eclaratio n of C ounsel for P e titio n e r
12/09/10
12/06/10
12) O rd er for C ontinuance
12/09/10
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13) N ote for C om m issioners C alen d ar
12/30/10
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14) M otion for O rd er to Show C ause re: C o n te m p t/Ju d g m en t
01/18/11
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15) O rd er to Show C ause re: C o n te m p t/Ju d g m en t
01/18/11
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16) D eclaratio n of C ounsel for P e titio n e r
02/08/11
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17) D eclaratio n of R esp o n d en t
02/10/11
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02/14/11
19) O rd er re: C o n tem p t
02/14/11
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C ounsel sh all fo rth w ith tra n sc rib e a reco rd in g of th e F e b ru a ry 14, 2011

h e a rin g on th is m a tte r.
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Petitioners Motion for Revlsion

Contempt

Ph.:(253) 770-0808, Fax (253) 770-0259
1
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Date: February 24, 2011

R espectfully su b m itted ,
G R EEN E & LLOYD, PLLC
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/s/ T im othy M. G reene

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T im othy M. G reene, W SBA #17499

A tto rn ey for P e titio n e r
J e n n ife r K ay S h ip m an
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Petitioners Motion for Revision

Contempt

Ph.:(253) 770-0808, Fax (253) 770-0259
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
February 25 20'
KEVIN ST
COUNTY C
NO: 10-3-0
2
3
4
5
6

County of Pierce
In re th e M arriage of :
8
No. 10-3-00961-1
P etitio n er(s),
PETITIO NERS MOTION AND

DECLARATION FOR
RECONSIDERATION
OF FEBRUARY 14,
2011 ORDER OF CO NTEM PT
an d
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11
R espondent(s).
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(Non-m andatory Form)
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P e titio n e r J e n n ife r K ay S h ip m an , th ro u g h u n d e rsig n ed counsel, p u rs u a n t to CR 59,
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resp ectfu lly m oves th e co u rt for reco n sid eratio n of its F e b ru a ry 14, 2011 O rd er of
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C ontem pt. T h is m otion is for good cause, as s ta te d in th e following d eclaratio n .
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D E C L A R A T IO N
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I, J e n n ife r S h ip m an , declare as follows:
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1. O n th e evening of F e b ru a ry 7, 2011, w h en M r. G reene a n d I w ere to m e et an d I w as

going to p re p a re a d eclaratio n in resp o n se to th e co n tem p t m otion in th is case, I w as
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stric k en w ith a te rrib le m ig rain e h ead ach e a n d w as u n ab le to m ak e m y ap p o in tm en t.

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Petitirnei-!! Motin fi - Recnsideratin

Contempt

Ph.:(253) 770-0808, Fax (253) 770-0259
2. I h a d called J a s o n on S ep tem b er 22, 2010, in o rd er to advise h im of m y in te n tio n s to
move. He n ev er re tu rn e d m y call. I d idnt fill o u t an ap p licatio n an d o b tain a hold on m y
a p a rtm e n t u n til S ep tem b er 25, 2010, a n d I d idnt sign a lease u n til S ep tem b er 29, 2010.
4
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J a s o n drove by th e house a n d p re su m ab ly observed u s m oving on O ctober 2, 2010. J a so n

n ev er resp o n d ed to m y phone call, so I se n t a n e-m ail on O ctober 14.
(please see a tta c h e d te x t m essage an d phone record).I w as n o t aw are th a t J a s o n w as u p se t
w ith m y move for ed u catio n al reaso n s u n til he filed th e co n tem p t m otion on J a n u a ry 18,
2011.
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3. I m oved for economic reaso n s in th a t I could n o t continue to m ak e th e m ortgage

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p a y m en ts on th e house, n o t for e d u catio n al re a so n s.

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4. I am n o t ask in g for reco n sid eratio n to be v ex atio u s. I know th a t I can p u rg e th e

co n tem p t by com plying w ith th e c o u rts order, an d I am doing so. The problem is th a t th e
14
c h ild ren now have to tra v e l long d istan ces to a tte n d school a n d daycare before a n d a fter
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school (daycare for H u n te r). They boys have to get up a t 5:30 a.m . to a tte n d school in s te a d
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of th e form er 8:00 a.m . for H u n te r a n d 6:30 a.m . for T yler . I w ill now have to stop w orking
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overtim e so th a t I can tra n s p o rt th e c h ild ren long d istan ces to a co u rt o rd ered school.
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Petitioners Motion for Reconsideration

Contempt

Ph.:(253) 770-0808, Fax (253) 770-0259
1
2
I declare u n d e r p e n a lty of p e rju ry u n d e r th e law s of th e S ta te of W ash in g to n th a t th e
foregoing is tru e to th e b e s t of m y know ledge, in form ation, a n d belief.
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S igned an d d a te d th is 24th day of F eb ru ary , 2011, in P uyallu p , W ashington.
/s/Je n n ifer S h ip m an
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J e n n ife r S h ip m an
DECLARANT
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Petitioners Motion for Reconsideration

Contempt

Ph.:(253) 770-0808, Fax (253) 770-0259
FILED
DEPT 12
n o pen c o uri
FEB 2 *! 2011
Pierce County fC lo rk
02-2B-11
10-3-00961-1
.By
IN THE SU PE R IO R COURT OF THE STATE OF W ASHING TO N

IN AND FOR PIERCE CO U N TY
Petitioner(s)
No. 10-3-00961-1
vs
NOTICE OF NONCOMPLIANCE
A N D ORDER SETTING
NO NCO M PLIANCE HEARING
Respondent(s)
Court records indicate that the attorneys and/or parties listed below have failed to comply with the Case Schedule in
regard to the following item
Settlement Conference not confirmed by deadline - (See PCLR 16 & PCLSPR 94 04)
Deadline 02/21/11
You are hereby ORDERED to appear for a hearing at 1 30 pm on Friday, 05/06/11 to comply with the Case
Schedule, or deliver a report of the same no later than the time set for the hearing
The court may impose sanctions or terms for failure to comply with the Case Schedule If the court finds that an
attorney or party has failed to comply with the Case Schedule and has no reasonable excuse, the court may order
the attorney or party to pay monetary sanctions to the court, or terms to any other party who has incurred expense
as a result of the failure to comply, or both, in addition, the court may impose such other sanctions as lustice
requires See PCLR 1( j )
*
^
DATED 02/24/11
Judge Stephanie A Arend

Department 12
Phone # 253-798-7562
Copies mailed to:

Robert D Lloyd
Daniel N Cook
TO:
Superior Court Clerk for Filing
(Court File Copy)
PAGE 1 OF 1
E-FILED
March 01 2011 4:01 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1

JEN N IFER KAY SHIPM AN
Petitioner,
v.
NO. 10-3-00961-1
OBJECTION AND MOTION TO
STRIKE

_______________________ Respondent.
OBJECTIO N/M OTIO N
COMES NO W the Respondent, JASON SHIPMAN, by and through his attorney
of record, Daniel Cook, of FAUBION, REEDER, FRALEY, & COOK, P.S., and objects to
the Motion for Revision and Motion for Reconsideration. Respondent further requests
an award of fees in the amount of $1,500 for the cost responding to Respondents
improper submission. This objection is based upon the following authorities, including
CR 59, and PCLR 7.
DATED this
day of

JLCOOK, PJ
Daniel N. CooiCW S B A -94866-Of Attorneys for Respondent

Objection and Motion to Strike - Page 1 of 4
Files\Content.Outlook\13RLZYM\AMotion to Strike.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
FACTS OF THE CASE:

A parenting plan was entered by the court on August 24, 2010. A motion for
contempt was brought by Respondent against Petitioner. An order for contempt was
entered on February 14, 2011 against Ms. Shipman for not complying with the joint
decision provisions of the parenting plan and not paying the house mortgage. The
motion for reconsideration and motion for revision were served on Mr. Shipman
February 24, 2011. Both motions were not filed with the court until February 25, 2011.
AUTHORITY:
RCW 26.12.215 provides:
Revision by the Superior Court. All acts and proceedings of the court
commissioners shall be subject to revision by the superior court as provided in
RCW 2.24.050.
RCW 2.24.050 provides:
Revision by Court. All of the acts and proceedings of court commissioners
hereunder shall be subject to revision by the superior court. Any party in interest
may have such revision upon demand made by written notice, filed with the Clerk
of the superior court, within ten days after the entry of any order or judgment of
the court commissioner. Such revision shall be upon the records of the case, and
the findings of fact and conclusions of law entered by the court commissioner,
and unless a demand for revision is made within ten days after the entry of the
order or judgment of the court commissioner, the orders and judgments shall be
and become the orders and judgments of the superior court, and appellate
review thereof may be sought in the same fashion as review of like orders and
judgments entered by the judge.
CR 59(b) provides:
Time for Motion: Contents of Motion. A motion for a new trial or for
reconsideration shall be filed not later than 10 days after the entry of the
judgment, order, or other decision. The motion shall be noted a t the time it is
filed, to be heard or otherwise considered within 30 days after the entry of the
judgment, order, or other decision, unless the court directs otherwise. A motion
for a new trial or for reconsideration shall identify the specific reasons in fact and
law as to each ground on which the motion is based. Emphasis added.

Files\ContentOutlook\13RLZYMV\Motion to Strike.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
1
PCLR 7 reads:
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Section (a) Judge's Motions and Trial assignments- (11) Motions for Revision.
Within 10 days of the entry of a written order or judgment by a court
commissioner, either party may file a motion for revision. Such motion shall be
schedule for argument on the assigned judicial departments next available
motion date...
Section (c) Motions held before Judges or Commissioners- (1) Motions for
Reconsideration . A Motion for Reconsideration shall be heard by the Judge or
Commissioner who initially ruled on the motion or to the Presiding Judge or
his/her designee upon a showing of good cause.
8
ARGUMENT:
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10
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A commissioner's decision becomes a final decision of the superior court unless

a motion for revision is filed within 10 days. RCW 2.24.050. The case Robertson v.
Robertson involves the authority of the superior court to extend the time for reviewing a
12
superior court commissioner's order beyond the 10 days set forth in RCW 2.24.050. The
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court held that the plain language of the statute requires the party seeking review to file
14
a motion for revision within 10 days and that after that time, the party must obtain review
15
from the appellate court. Neither the statute nor court rules allow the superior court to
16
treat a late motion for revision as a timely motion for reconsideration. Roberts v.
Roberts, 113 Wn.App. 711, 54 P.3d 708 (Wash.App. Div. 2 2002). In this matter, the
17
motion for reconsideration and motion for revision were served on Mr. Shipman
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February 24, 2011. Both motions were not filed with the court until February 25, 2011.
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February 25, 2011 was the eleventh (11th) day and therefore is outside the timeline put
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forth by statute and case law. Therefore, the motion for revision should be dismissed.
In a motion for reconsideration, the matter must be filed within ten days of the
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order, it must be noted at the time of filing, and the motion must identify the reasons in
law and fact the motion is based. CR 59. A motion for reconsideration is to be before
the judge or commissioner who ruled on the original motion.
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A motion for revision must be heard by a judge in superior court. PCLR 7. After a
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formal order has been entered, it is improper to offer new evidence. New evidence may
Files\Content.Outlook\13RLZYMV\Motion to Strike.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
not be submitted to a court for purposed of reconsideration after a formal order has
been entered. AIMCOR v. Melton , 74 Wn. App. 73, 872 P.2d 87 (1994). The motion for
reconsideration by Ms. Shipman was also filed on the eleventh (11th) day on February
25, 2011 with the court. It is outside the timeline required by the statute. The motion was
not noted at the time of filing. The motion lists facts of why the contempt motion should
be reconsidered, but it does not identify the reasons in law why the motion should be
allowed. The motion for revision and reconsideration cannot be heard before the same
judge. It is unclear who will hear the motions since they are not noted, but they must be
heard separately.
For all of these the reasons, the court should grant this motion and strike the
pleadings untimely filed by Petitioner as a Motion for Revision or Reconsideration.
RELIEF REQUESTED:
Wherefore, the Respondent requests that the court strike and/or dismiss both the
motion for revision and the motion for reconsideration. The Respondent further requests
an award of attorneys fees and costs in the amount of $1,500 for the cost of responding
to petitioners improper motions.
Respectfully Submitted by:
B y Daniel N. Cook, WSBA 34866


Files\Content.Outlook\13RLZYMV\Motion to Strike.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
10-3-00961-1
35990595
LTRSTC
Court
OF THE
S tate of Washington
for Pierce County
uperior
334 COUNTY-CITY BUILDING

930 TACOMA AVENUE SOUTH
TACOMA, WA 98402-2108
SUPERIOR COURT
(253) 798-6630
March 3, 2011
ROBERTO LLOYD
ATTORNEY AT LAW
4115 S MERIDIAN, SUITE B
PUYALLUP, WA 98373
DANIEL N COOK
ATTORNEY AT LAW
5920 100TH ST SW STE 25
Dear Counsel
This is to confirm the following settlement conference
Case:
Cause No.:
Before:
Date & Time:
JENNIFER KAY SHIPMAN VS. JASON WILLIAM SHIPMAN

10-3-00961-1
Judge ELIZABETH MARTIN, County-City Bldg, RM 833
July 11,2011 at 4:00PM
The court requires all parties to'

1.
Be personally present unless excused by the Judge,
Deliver the pretrial information and any supplemental information to the

department conducting the settlement conference at least two business days
before the settlement conference, and
Be fully prepared, with all discovery matters completed
Please remember that failure to supply the settlement judge with appropriate forms in a timely
manner may result in the imposition of sanctions For complete information regarding settlement
conferences, please refer to the Pierce County Local Rules
Sincerely,
DEA FINIGAN
Dea Fintgan
Judicial Assistant
CC Pierce County Clerk for Filing
/
1
10-3-00961-1
36109256
NOTE
03-25-11
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W ^ 2 4 2o
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Superior Court of W ashington
County of Pierce
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No.
10-3-00961-1
Petitioner,
and
R ESPO N D EN TS
CALCULATIONS
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Respondent.
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FRANCISCAN HEALTH SYSTEM

G arnishee Defendant
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COMES NOW the Respondent, JASON WILLIAM SHIPMAN, and hereby

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submits the following calculations regarding the judgment herein
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Judgment entered February 14, 2011
Interest from 2/15/11 to 3/23/11 (37 days @ $0 49 per
diem)
$1,500 00
$
18 13
TOTAL
$1,518 13
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RESPONDENTS CALCULATIONS-1
S \CASES1\Shipman, Jason disso\Garnishmeni\CALC doc

& COOK, P S
5920 - 100lh St SW #25
Lakewood, WA 98499
253-581-0660
:S
-j
jl 413-e %
1
Dated this ? 5 *
day of March, 2011.
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& COOK, P.S.
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DANIEL N. C O O k, W SBA #34866

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RESPONDENTS CALCULATIONS- 2
S \CASES1 \Shipman, Jason disso\Garmshment\CALC doc

& COOK, P S
5920-1 0 0 th St SW #25
Lakewood, WA 98499
253-581-0660
/L
3^ *
10-3-00961-1
3610S264
AFGAR
Ct/*ryp'i
03-25-11
Oi
* *-s
& E?C-
**>
& ff
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S uperior Court of W ashington

County o f Pierce
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In re the marriage of
No.
10-3-00961-1
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Petitioner,
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and
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APPLICATION FOR W RIT OF

G ARNISHM ENT (APL)
Respondent.
FRANCISCAN HEALTH S YSTEM
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I. APPLICATION
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1 1
Respondent has a judgment wholly or partially unsatisfied, against the Petitioner,
in the court from which the writ is being sought

1.2
The amount alleged to be due is the balance of the judgment or amount of claim,
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$1,500 00, plus interest and estimated garnishment costs as indicated in the writ
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1.3
Respondent has reason to believe, and does believe, that FRANCISCAN
APPLICATION FOR WRIT OF GARNISHMENT (APL) Page -1

WPF GARN 01 0100 (8/2000), RCW 6 27 060
FAUBION, REEDER, FRALEY,

& COOK, P S
5920 - 100th St SW #25
Lakewood, WA 98499
253-581-0660
1
HEALTH SYSTEM, Garnishee, whose residence and/or business location is 11315
2
Bridgeport Way SW, Lakewood, Washington, is:
3
4
5
[]
indebted to the Petitioner in amounts exceeding those exempted from
garnishment by any state or federal law
[]
the garnishee has possession or control of personal property or effects belonging
to the Petitioner which are not exempted from garnishment by any state or federal law
14
The garnishee is the employer of the Petitioner
9
10
11
12
II. CERTIFICATION
I CERTIFY under penalty of perjury under the laws of the State of Washington
that the foregoing is true and correct.
Dated th is P ^ ? _ day of March, 2011, at Lakewood, Washington
13
14
& COOK, P S.
15
16
17
18
19
20
21
22
23
24
25
APPLICATION FOR WRIT OF GARNISHMENT (APL) Page - 2
WPF GARN 01 0100 (8/2000), R C W 6 27 060
FAUBION, REEDER, FRALEY,

& COOK, P S
5920 - 100th St SW #25
Lakewood, WA 98499
253-581-0660
1
10*3-00961-1
36109265
SWRG
4^12
03-25-11
3
4
5
6
7
S uperior C ourt of W ashington

County o f Pierce
10
11

No.
12
Petitioner,
13
and
14
15
16
10-3-00961-1
W RIT OF G ARNISHM ENT

(CONTINUING LIEN ON
EARNINGSBAFTER
JUDGMENT) (W RG or $WRG)
Respondent.
17
Garnishee D efendant
18
STATE OF W ASHINGTON TO
FRANCISCAN HEALTH SYSTEM, Garnishee
AND TO.
JENNIFER KAY SHIPMAN, Petitioner
19
20
21
22
The Respondent in this action has applied for a Writ of Garnishment against you,
claiming that the above-named Petitioner is indebted to Respondent and that the
amount to be held to satisfy that indebtedness is $1,808 13 (total amount), consisting of
23
Balance of Judgment:
$1,500.00
24
Interest under judgment from 2/15/11 to 3/23/11:
$18 13
25
WRIT OF GARNISHMENT (CONTINUING LIEN ON

EARNINGSBAFTER JUDGMENT) (WRG or $WRG) -1
WPF GARN 01 0250 {7/2003) - RCW 6 27 100, 340
S \CASES1\Shipman, Jason disso\Garnishment\writ doc

& COOK, P S
5920 - 100th St SW #25
Lakewood, WA 98499
253-581-0660
Taxable Costs and Attorneys fees as set forth below.
$300.00
Estimated Garnishment Costs and Fees:

Writ Fee
$ 20.00
Answer Fee
$ 10.00
Postage & Costs of Certified Mail
$ 20 00
Garnishment Attorney Fee
$250.00
Total
$300.00
YOU ARE HEREBY COM M ANDED, unless otherwise directed by the court, by
the attorney of record for the Respondent, or by this writ, not to pay any debts, whether
wages subject to this garnishment or any other debt, owed to the Petitioner at the time
this writ was served and not to deliver, sell, or transfer, or recognize any sale or transfer
of, any personal property or effects of the Petitioner in your possession or control at the
time this writ was served. Any such payment, delivery, sale, or transfer is void to the
extent necessary to satisfy the Respondents claim and costs for this writ with interest
YOU ARE FURTHER COM M ANDED to answer this writ by filling in the attached
form according to the instructions in this writ and in the answer forms; and within twenty
(20) days after the service of the writ upon you, to mail or deliver the original of such
answer to the court, one copy to the Respondent or the Respondents attorney, and one
copy to the Petitioner in the envelopes provided.
If, at the time this writ was served, you owed the Petitioner any earnings (that is,
wages, salary, commission, bonus, or other compensation for personal services or any
periodic payments pursuant to a pension or retirement program), the Petitioner is
entitled to receive amounts that are exempt from garnishment under federal and state
law You must pay the exempt amounts to the Petitioner on the day you would
customarily pay the compensation or other periodic payment. As more fully explained in
the answer, the basic exempt amount is the greater of 75 percent of disposable
earnings or a minimum amount determined by reference to the employees pay period,
to be calculated as provided in the answer
IF THIS IS A W RIT FOR A CONTINUING LIEN ON EARNINGS, YOU MAY
DEDUCT A PROCESSING FEE FROM THE REMAINDER OF THE EMPLOYEE'S
EARNINGS AFTER W ITHH O LDING UNDER THIS W RIT. TH E PROCESSING FEE
MAY NOT EXCEED TW E NTY DOLLARS ($20) FOR THE FIRST ANSW ER AND TEN
DOLLARS ($10) AT THE TIM E YOU SUBMIT THE SECOND ANSW ER
EARNINGSBAFTER JUDGMENT) (WRG or $WRG) - 2
WPF GARN 01 0250 (7/2003) - RCW 6 27 100, 340
S \CASES11Shipman, Jason disso\Gamishment\wnt doc

& COOK, P S
5920 - 100th St SW #25
Lakewood WA 98499
253- 581-0660
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
If you owe the Petitioner a debt payable in money in excess of the amount set
forth in the first paragraph of this writ, hold only the amount set forth in the first
paragraph and any processing fee, if one is charged, and release all additional funds or
property to the Petitioner.
THIS IS A W R IT FOR A CONTINUING LIEN THE G ARNISHEE DEFENDANT
SHALL HOLD the nonexempt portion of the Petitioners earnings due at the time of
service of this writ and shall also hold the Petitioners nonexempt earnings that accrue
through the last payroll period ending on or before SIXTY (60) days after the date of
service of this writ HOW EVER, IF THE GARNISHEE DEFENDANT IS PRESENTLY
HOLDING THE N O N EXEM PT PORTION OF THE P ETITIO N ER S EARNINGS UNDER
A PREVIOUSLY SERVED W R IT FOR A CONTINUING LIEN, THE GARNISHEE
DEFENDANT SHALL HOLD UNDER THIS W RIT only the Petitioners nonexempt
earnings that accrue from the date the previously served writ or writs terminate and
through the last payroll period ending on or before sixty (60) days after the date of
termination of the previous writ or writs IN EITHER CASE, TH E GARNISHEE
DEFENDANT SHALL STOP W ITHHOLDING W HEN THE SUM W ITHHELD EQUALS
THE AMOUNT STATED IN TH IS W R IT OF GARNISHMENT.
IF YOU FAIL TO A NSW ER THIS W R IT AS COMMANDED, A JUDGMENT MAY
BE ENTERED AGAINST Y O U FOR THE FULL AM OUNT OF THE RESPONDENTS
CLAIM AGAINST TH E PETITIO NER W ITH ACCRUING INTEREST, ATTORNEY
FEES, AND COSTS W H E TH E R OR NOT YOU OW E ANYTHING TO THE
PETITIONER. IF YOU PROPERLY ANSW ER THIS W RIT, ANY JUDGM ENT
AGAINST YOU WILL NOT EXCEED THE AM OUNT OF ANY N O N EXEM PT DEBT OR
THE VALUE OF ANY N O N EXEM PT PROPERTY OR EFFECTS IN YOUR
POSSESSION OR CONTROL
JUDGMENT MAY ALSO BE ENTERED AGAINST TH E PETITIO NER FOR
COSTS AND FEES INCURRED BY THE RESPONDENT.
WITNESS, the Honorable BRYAN CHUSHCOFF, Judge of the Superior Court,
and the seal thereof, th i& g ^ ^ d a y of March, 2011.
20
21
22
23
24
25
KEVIN STOCK f
CLERK OF THE'SUF'ERIOR CO U RT
C
B y :^ _
Deputy
930 Tacoma Avenue South #110
Tacoma, WA 98402
W PF GARN 01 0250 (7/2003) - RCW 6 27 100, 340
S \CASES1\Shipm an, Ja so n disso\G arnishm ent\w rit d o c

& COOK, P S
5920 - 100th St SW #25
Lakewood WA 98499
253-581-0660
"T
1
2

& COOK, P.S.
3
4
5
6
7
B y .____________________________
DANIEL N COOK, W SBA #34866
5920 100th Street S.W , Suite 25
Lakewood, WA 98499
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

W PF GARN 01 0250 (7/2003) - RCW 6 27 100, 340
S \CASES1\Sliipman, Ja so n disso\G arm shm ent\w nt doc

& COOK, P S
5920- 100th St SW #25
Lakewood, WA 98499
253-581-0660
12567
3 /3 8 /2 8 1 1
118870
2
3
4
'" county^
,
s FF/ce
iiitiiniiti, ...
,
10-3-00961-1
36133474
AFML
03-30-11
tePUYy
6
7
8
Superior Court o f W ashington
County of Pierce
9
10
11
12
and
13
Petitioner,
No.
10-3-00961-1
AFFIDAVIT OF MAILING
14
Respondent.
15

16
17
State of Washington
County of Pierce
) ss
)
18
19
Sally DuCharme, being first duly sworn upon oath, deposes and says:
20
That on the 28th day of March, 2011, she placed true copies of the following
21
22
23
documents:
1.
Application for Writ of Garnishment
24
2.
Respondents Calculations
25
3.
Writ of Garnishment
AFFIDAVIT OF M A IL IN G -1
S:\CASES1\Shipman, Jason disso\Gamishment\MAILdef.doc

& COOK, P.S.
5920- 100th St. SW#25
Lakewood, WA 98499
253-581-0660
ORIGINAL
-IfESer?*. 3 ^ 34*X 2 9 1 1
118871
4.
Copy of Judgment
5.
Notice of Garnishment
6.
Exemption Claim
2
3
4
5
6
7
On file in the above entitled matter in envelopes addressed as follows:

Jennifer Shipman
c/o Timothy M. Greene
P.O. BOX 731063
Puyallup, W A 98373
8
That she placed and affixed proper postage stamps to each said envelope,
9
10
11
12
certified mail, return ijeceipt, and first class mail, sealed the same, and placed them in a
receptacle maintained by the United States Post Office for the deposit of letters for
mailing in the City of Lakewood, County of Pierce, State of Washington.
13
14
15
Subscribed and sworn to before me this 28th day of March, 2011.
16
17
NOTARY PUBLIC in and for the State of
Washington residing at Pierce County.
Name: Paula J. Ledbetter
My commission expires: 3/27/13
18
19
20
21
22
23
24
25
AFFIDAVIT OF MAILING- 2
S:\CASES1\Shipman, Jason cJisso\Gamishment\MAILdef.doc

& COOK, P.S.
5920-1 0 0 th St. SW#25
Lakewood, WA 98499
253-581-0660
1258?
3 /3 0 ^ 2 8 1 1
110872
1
2
3
4
5
6
7
8
S uperior Court of W ashington
County of Pierce
9
10
11
12
Petitioner,
13
and
14
15
16
No.
10-3-00961-1
A FFID A VIT OF MAILING
Respondent.
17
Garnishee Defendant
18
19
State of Washington
)
)s s
20
County of Pierce
21
Sally DuCharme, being first duly sworn upon oath, deposes and says:
22
That on the 28th day of March, 2011, she placed true copies of the following
23
documents:
24
1-
Application for Writ of Garnishment
25
AFFIDAVIT OF M A IL IN G -1
S:\CASES1VShipman, Jason disso\Gamishment\MAILempl.doc
qR1

- ,F/
& COOK, P.S.
5920-1 0 0 th St. SW #25
Lakewood, WA 98499
\NM-
253-581-0660
12567
3 / 3 8 / 2 8 1 1 U *87.3
?
1
2.
Respondent's Calculations
3.
Writ of Garnishment
4.
Copy of Judgment
5.
Four Answer forms
2
3
4
5
6.
Stamped envelopes directed to: Pierce County Clerk, Jennifer Shipman

and Daniel Cook.
7
On file in the above entitled matter in envelopes addressed as follows:
8
9
10
Franciscan Health System

St. Clare Hospital
11315 Bridgeport Way SW
Lakewood, W A 98499
11
12
That she placed and affixed proper postage stamps to each said envelope,
13
certified mail, return receipt, sealed the same, and placed them in a receptacle
14
maintained by the United States Post Office for the deposit of letters for mailing in the
15
City of Lakewood, County of Pierce, State of Washington.
16
17
Bally
DuC&sfirme
-^ S a
lly DuCfctSrrme
18
19
Subscribed and sworn to before me this 28th day of March, 2011.
20
21
NOTARY PUBLIC in and for the State of

Washington residing at Pierce County
Name: Paula J. Ledbetter
22
23
24
25
AFFIDAVIT OF MAILING- 2
S:\CASES1\Shipman, Jason disso\Gamishment\MAILempl.doc

& COOK, P.S.
5920 - 100th St. SW #25
Lakewood, WA 98499
253-581-0660
4 S X 2 K 2 &11
10-3-00961-1
36205050
ANWRGR
,N c unty CLERK'*
OFF/C
04-12-11
10
APS J J 2fl)(

County of Pierce
8
9
132 27 413517 3
In re the marriage of
No.
10-3-00961-1
11
Petitioner,
12
and
13
14
15
FIRST ANSWER TO WRIT OF

GARNISHMENT FOR
CONTINUING LIEN ON
EARNINGS (ANWRGR)
Respondent.
16
Garnishee Defendant
17
18
19
20
21
22
23
24
25
SECTION I
On the date the Writ of Garnishment was issued as indicated by the date
appearing on the last page of tJie writ,
(A)
The Petitioner [*] was [ ] was not employed by Garnishee If not
employed, and you have no possession or control of any funds of Petitioner, indicate
the last day of employment _________________; and complete Section III of this
Answer and mail or deiivepdhe forms as directed in the Writ.
(B)
Petitioner [vf did [*Ldid not maintain a financial account with Garnishee.
(C)
The Garnishee did [ ] did not have possession of or control over any
funds, personal property, or effects of Petitioner {List all of the Petitioner's personal
property or effects in your possession or control on the bottom of the last page of this
answer form or attach a schedule if necessary )
If you are withholding the Petitioners nonexempt earnings under a previously
ANSW ER WPF GARN 01 0750 (7/2003) - RCW 6 27 190, 340
S \CASES1\Shipman Jason disso\Garnishment\answer doc
FAUBION REEDER, FRALEY

& COOK, P S
5920- 100th St SW #25
Lakewood, WA 98499
253-581-0660
<*
1
2
3
4
5
6
7
4 ^ l2 /2 g J L l
13227
4 b 8 1 7 4
served writ for a continuing lien answer only Sections I and III of this form and mail or
deliver the forms as directed in the writ Withhold from the Petitioners future
nonexempt earnings as directed in the writ and a second set of answer forms will be
forwarded to you later
ANSWER I am presently holding the Petitioner s nonexempt earnings under a
previous writ served o n __________________ (date) that will terminate not later than
____________
(date)
If you are NOT withholding the Petitioners earnings under a previously served
writ for a continuing lien, answer this entire form and mail or deliver the forms as
directed in the writ A second set of answer forms will be forwarded to you later for
subsequently withheld earnings.
SECTION II
8
9
10
11
12
13
14
At the time of service of the Writ of Garnishment on the Garnishee, there was
due and owing from the Garnishee to the above-named Petitioner $______________.
This writ attaches a maximum of 25 percent of the Petitioners disposable
earnings (that is, compensation payable for personal services, whether called wages,
salary, commission, bonus, or otherwise, and including periodic payments pursuant to a
nongovernmental pension or retirement program). Calculate the attachable amount as
follows.
Gross Earnings
$__________________ (D
Less deductions required by law (Social Security, federal
withholding tax, etc. Do not include deductions for child
support orders or government liens here. Deduct child
support orders and liens on line 7):
15
16
17
18
19
20
21
22
23
24
25
Disposable Earnings (subtract line 2 from line 1)'

Enter 75 % (percent) of line 3
Enter one of the following exempt amounts*
If paid Weekly $_____
Semi-monthly
Bi-weekly
$______
Monthly
$_
$______
*These are minimum exempt amounts that the Petitioner must be paid If
your answer covers more than one pay period, multiply the preceding amount
by the number of pay periods and/or fraction thereof your answer covers If
you use a pay period not shown, prorate the monthly exempt amount.
Subtract the larger of lines 4 and 5 from line 3:
Enter amount (if any) withheld from this paycheck for
ongoing government liens such as child support:
Subtract line 7 from line 6. This amount must be held
out for the Respondent
ANSW ER WPF GARN 01 0750 (7/2003) - RCW 6 27 190, 340
S \CASES1 \Shipman Jason disso\Garnishment\answer doc
$________________ (6)
$________________ (7)
$________________ (8)
& COOK, P S
5920 - 100mSt SW #25
Lakewood, WA 98499
253-581-0660
13ZZ7
4& S175
This is the formula that you will use for withholding each pay period over the
2
required 60-day garnishment period Deduct any allowable processing fee you may
3
charge from the amount that is to be paid to the Petitioner

If there is any uncertainty about your answer, give an explanation on the last
5
6
page of this answer form, or on an attached page
SECTION III
An attorney may answer for the Garnishee.
Under penalty of perjury, I affirm that I have examined this answer, including
10
11
12
accompanying schedules, and to the best of my knowledge and belief, it is true, correct
and complete.
Dated:
V - ? ' / / ___________
13
14
Signature of Garnishee Defendant
15
16
;onpection with Garmstlê
f J
y n u u /2 o ( j - L //j? /yu q fiA
17
18
Signature of Person Answering for

Garnishee
19
20
J e t iM F e e .
Print name of person signing
21
24
Phnnp Nrimhpr
Catholic Health Initiatives
Garnishment Department
3900 Olympic Blvd , Suite 400
Erlanger, KY 41018-1099
25
pages
22
23
w to supplement your answer from the first and second
ANSW ER WPF GARN 01 0750 (7/2003) - RCW 6 27 190

S \CASES 1\Shipman, Jason disso\Garnishment\answer doc
340
FAUBION REEDER, FRALEY

& COOK, P S
5920- 1 0 0 th St SW #25
Lakewood, WA 98499
253-581-0660
PR277 Date 04/06/11

Time 06 29
Process Level 51103

Employee
Payment Nbr
Case
File Number /
ST CLARE HOSPITAL
55218
23546907
FIPS
SHIPMAN, JENNIFER K
Payment Type Direct Deposit
Gross Pay
10-3-00961-1
Department
3071 34
Disposable
Income
Exempt Wages
2333 88
1750 41
3136
Page
company 8900
CATHOLIC HEALTH INITIATIVES
Garnishment Audit Report
Report Sequence Proc Level/Dept/Emp Name
ORTHOPEDIC SURGICAL
SSN 536-88-2306
Payment Date 04/08/2011
Garn
Ded
G20P
Amount
583 47
ClrHse
Fee
0 00
Arr
Court Fee Ded
0 00
Amount
0 00
Fee
Com t
Arreas Fee Ded
0 00
Amount
0 00
583 47
0 00
0 00
0 00
583 47
0 00
0 00
0 00
Process Level 51103 Tota 1
583 47
0 00
0 00
0 00
Company 8900 Total
583 47
0 00
0 00
0 00
Employee Total
Department 3136
Total
E-FILED
April 12 2011 4:10 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
5
6
7
County of Pierce
8
9
10
No.
10-3-00961-1
11
12
13
14
15
Petitioner,
and
FIRST ANSW ER TO W R IT OF
G ARNISHM ENT FOR
CONTINUING LIEN ON
EARNINGS (ANWRGR)
-JASON WILLfAM SHIPMAN

Respondent.
16
17
18
19
20
21
22
23
24
25
SECTION I
On the date the Writ of Garnishment was issued as indicated by the date
appearing on the last page of the writ,
(A)
The Petitioner [*] was [] was not employed by Garnishee. If not
employed, and you have no possession or control of any funds of Petitioner, indicate
the last day of employment: ___________________ ; and complete Section III of this
Answer and mail or delivep-the forms as directed in the Writ.
(B)
Petitioner M did |U/did not maintain a financial account with Garnishee.
(C)
The Garnishee [fdid [ ] did not have possession of or control over any
funds, personal property, or effects of Petitioner. (List all of the Petitioner's personal
property or effects in your possession or control on the bottom of the last page of this
answer form or attach a schedule if necessary.)
If you are withholding the Petitioners nonexempt earnings under a previously
ANSWER: W PF GARN 01.0750 (7/2003) - RCW 6.27.190, .340
S:\CASESHShipman, Jason disso\Garnishment\answer.doc

& COOK, P.S.
5920- 1 0 0 th St. SW #25
Lakewood, WA 98499
253-581-0660
served writ for a continuing lien, answer only Sections 1and III of this form and mail or
deliver the forms as directed in the writ. Withhold from the Petitioners future
nonexempt earnings as directed in the writ, and a second set of answer forms will be
forwarded to you later.
ANSWER: I am presently holding the Petitioners nonexempt earnings under a
_
(date).
directed in the writ. A second set of answer forms will be forwarded to you later for
SECTION ii
At the time of service of the Writ of Garnishment on the Garnishee, there was
due and owing from the Garnishee to the above-named Petitioner $
This writ attaches a maximum of 25 percent of the Petitioners disposable
earnings (that is, compensation payable for personal services, whether called wages,
salary, commission, bonus, or otherwise, and including periodic payments pursuant to a
nongovernmental pension or retirement program). Calculate the attachable amount as
follows:
Gross Earnings:
$__________________ (1)
Disposable Earnings (subtract line 2 from line 1):
Enter 75 % (percent) of line 3:
Enter one of the following exempt amounts*:
If paid Weekly $______ Semi-monthly
-
Bi-weekly
$_______
Monthly
$_
$.
*These are minimum exempt amounts that the Petitioner must be paid. If
your answer covers more than one pay period, multiply the preceding amount
by the number of pay periods and/or fraction thereof your answer covers. If
you use a pay period not shown, prorate the monthly exempt amount.
$______________

out for the Respondent:
$_________________(8)
ANSW ER: WPF GARN 01.0750 (7/2003) - RCW 6.27.190, .340

S:\CASES1\Shipman, Jason disso\Garnishment\answer.doc
$_________________(6)
(7)

& COOK, P.S.
5920-1 0 0 th St. SW #25
Lakewood, WA 98499
253-581-0660
This is the formula that you will use for withholding each pay period over the
required 60-day garnishment period. Deduct any allowable processing fee you may
charge from the amount that is to be paid to the Petitioner.
If there is any uncertainty about your answer give an explanation on the last
page of this answer form, or on an attached page.
SECTION III

Under penalty of perjury, I affirm that I have examined this answer, including
accompanying schedules, and to the best of my Knowledge and belief, it is true, correct
and complete.
Dated:
7- / /
Connection with Garnisfljfee

P 'ar qu <j ^2 o / I JM W Q cIA
Signature of Person Answering for
Garnishee
J e m iF tz iz S 'p L u u k
8 6 Q -& 4 3 S3 3
P h o n e N um ber

3900 Olympic Blvd., Suite 400
Erlanger, KY 41018-1099
___________ ___________-
Af
to supplement your answer from the first and second
pages
ANSW ER: W PF GARN 01.0750 (7/2003) - RCW 6.27.190, .340
S:\CASES1VShipman, Jason disso\GarnishmentVanswer.doc

& COOK, P.S.
5920- 100th S t SW #25
Lakewood, WA 98499.
253-581-0660
PR277 Date 04/06/11

Time 06:29
Process Level 51103

Employee
Payment Nbr
Case
File Number /
Company 8900
ST CLARE HOSPITAL
55218
23546907
FIPS
Gross Pay
10-3-00961-1
3071 .34
Employee Total
Department
Disposable
Income
Exempt Wages
2333.88
1750,41
3136
Page
ORTHOPEDIC SURGICAL
SSN 536-88-2306
Garn
Ded
G20P
Amount
583 .47
ClrHse
Fee
0.00
Arr
Court Fee Ded
0.00
Amount
0.00
Court
Fee
Arreas Fee Ded
0.00
Amount
0.00
583 .47
0 .00
0.00
0.00
583.47
0 .00
0.00
0.00
Process Level 51103 Total
583.47
0 .00
0.00
0.00
Company 8900 Total
583.47
0 .00
0.00
0.00
Department 3136
Total
E-FILED
May 17 2011 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO:

Phone: (253) 770-0808

Pierce County Superior Court, County-City Building - 930 Tacoma Ave S - Tacoma, WA 98402
CALENDAR DATE: Tuesday, June 21,2011
9:30 AM
WORKING COPIES SHALL BE SUBMITTED TO COMMISSIONERS SERVICES ROOM 140,

BEFORE 12:00 NOON TWO COURT DAYS PRIOR TO HEARING
DATED:
May 16, 2011.
Signed:
/s/ Daniel N Cook
NAME:
Daniel N Cook
Phone:
(253) 581-0660
ADDRESS: 5920 100th St SW Ste 25
WSBA#:
For:
34866
1 of
E-FILED
May 18 2011 11:24 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
IN THE SUPERIOR CO U R T OF THE STATE OF W ASHINGTON

IN AND FOR THE CO U N TY OF PIERCE
Petitioner,
v.
JASON W ILLIAM SHIPMAN
_________ _____________ Respondent.
NO. 10-3-00961-1
PETITION FOR M ODIFICATION /
MOTION FOR A D JU STM EN T OF
TEM PORARY CHILD SU PPO R T AND
PARENTING PLAN
COMES NOW the Respondent, JASON SHIPMAN, by and through his attorney
of record, Daniel Cook, of FAUBION, REEDER, FRALEY, & COOK, P.S., and moves
the court for:
An order adjusting the support provisions of the most recent Order of Child
Support.
This motion is based upon the following declaration, the Sealed Financial
Source Documents and the Child Support Worksheet and Financial Declaration which
have been, are or will be filed with herewith.
Modifies the parenting plan to give the father first right of refusal for daycare and
orders the mother to allow the children to bring clothes, toys and games to the fathers
during residential time the children spend with the father.
Petition / Motion to Modify / Adjust Child Support
and Parenting Plan - Page 1 of 5
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
Orders that the Mother be 100% responsible for daycare expenses she incurs
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when the father is available as an alternate care provider for before and after school care
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4
5
for the children.

That this adjustment of child support be effective as of May 1,2011.
DATED this____ day of May 2011.
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DECLARATION
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My wife and I were married on April 24, 1994. Two children were born during our
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marriage: TYLER, age 16 and HUNTER, age 9.
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temporary child support order was entered on August 24, 2010. I am filing this motion
15
to modify or adjust that child support order because I am now on unemployment.
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We separated in March 2010.
The child support order was based upon both parents working full-time as they
had during their marriage.
My wife had worked at her job as an RN for 5-6 years. I had
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worked as an installation and maintenance technician for two security companies for 7
19
years at time of separation.
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On or around May 1 ,2 0 1 1 , I was laid off from my job when, at the time of layoff, I
had worked for 8 years in the industry with no periods of unemployment.
My wife
contributed to the lay off. She called my employer and falsely stated that I had stolen
24
from the company and that the stolen materials and equipment were located in her
25
garage. I deny stealing any property from my employer.
Petition / Motion to Modify /Adjust Child Support

FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
Based upon my wifes allegations, my employer and the corporate attorney set
up a time to meet with my wife to retrieve the allegedly stolen property; however, only a
day or two before the scheduled meeting my wife called and canceled the meeting.
Since that time I have been viewed suspiciously by my employer and when decisions
were made to lay individuals off I was at the top of the list.
Prior to my wifes
allegations 1 was a good employee with a long term future at the company. There is no
question in my mind that her allegations substantially contributed to the loss of my job.
I am now on unemployment and need to modify the support order which was
based upon my income before I was laid off. I will receive $479 a week and 10% will be
taken out for Federal income Tax. I will not have to pay FICA while on unemployment.
My child support worksheets use this calculation for my income and adopt the same
figures the court reached at the Temporary Order hearing for my wife.
I am a Union Member.
I have inquired at the Union hall and been assigned a
number in priority for being re-assigned to a new job. I understand the estimated time
for a position to open for me is approximately 12 months from now. During this period
of unemployment I am absolutely available to care for the children and would welcome
the opportunity to spend extra time with them while I am off.
It would be a wonderful
opportunity for me to use this unfortunate event (layoff) to some good as the children
can utilize this opportunity to make up time they have sorely needed and missed since
our separation.
My wife is very angry at me.
My wife has taken every opportunity to financially
and emotionally make this process difficult on me. I incorporate herein by reference my
motions and declarations regarding use of the home and payment the house when she
Petition / Motion to Modify / Adjust Child Support
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
flip-flopped back and forth simply to oppose me.
Whatever proposal I advanced
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regarding the house she took the opposite position in order to make things more
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4
5
difficult.
My wife was also found in contempt for changing the childrens school
unilaterally in violation of the parenting plan.
I incorporate herein by reference my
motion/declaration and order re contempt of the parenting plan.

I believe my wife will oppose the children spending any more time with me simply
because of her bitterness toward me even though it would be financially beneficial to the
community to avoid daycare expenses and it would be emotionally and psychologically
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better for the children to spend more time with me. My home is less than five minutes
walking distance from either childs school but my wife refuses to authorize the children
to even come over after school before she gets done with work.
I ask the court to
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modify the parenting plan to allow me first right of refusal for before and after school
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care and to order my wife to be 100% responsible for any daycare expenses she incurs
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when I could have provided care.

My wife also refuses to allow the children to bring clothing or toys to my home for
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their residential time with me. I have asked her to send clothes with them for weekend
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visits.
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and after they wear them back to her house I never see the clothes I bought again. My
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son has often told me he would like his bike at my house, and I have asked my wife to
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allow him to bring it and she refuses.
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She refuses and tells me to buy clothes myself.
I have bought clothes myself
I would buy him a bike at my house but I am
extremely limited on disposal cash at this point.
I would not make this motion
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independently, but since I am going to court anyway because of the change regarding
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my job, I ask the court

Petition / Motion to Modify/ Adjust Child Support
FAUBION, REEDER,
FRALEY & COOK, P.S,
Lakewood, WA 98499
253-581-0660
I ask the court to make this modification/adjustment effective May 1, 2011.
would hope that my wife wiil agree to a temporary reduction in support because of my
unemployment, but I do not think she will. Even though our trial date is coming soon, I
need the relief from the current Order of Support so that my unemployment checks are
not garnished at a higher level and so that there is not uncertainty as to the daycare
situation.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
STATE OF W ASHINGTON THAT THE FOREGOING IS TR U E AND CORRECT.
Petition / Motion to Modify/ Adjust Child Support

and Parenting Plan - Page 5 o f 5
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
May 18 2011 11:24 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1

[ X Proposed by
MOTHER
COUNTY
[ ] Mother [ X J Father [ ] State of WA [ ] O ther____________________ .(CSWP)

Or, [ JSigned by the Judicial/Reviewing Officer. (CSW)

PIERCE
FATHER
SUPERIOR COURT/OAH CASE NO. 10-3-00961-1
_________________ CHILD SUPPORT ORDER SUMMARY REPORT__________________

B. The STANDARD CALCULATION listed on line 15e of the Worksheet for the paying parent is: $460.96.
[ ] Does not apply
[ ] Sources of income and tax planning
[ ] Split custody
[ j Residential schedule (including shared custody)
[ j Children from other relationships for whom the parent owes support
E. Income for the Father is [ J imputed [ X ] actual income.

F, If applicable: [ ] All health care, day care and special child rearing expenses are included in the worksheets in
Part II.
WORKSHEETS
Children and Ages Tyler 16, Hunter 9
Part I: Basic S upport O bligation (See instructions, page 1)
Father
M other
$2,075.67
$6,192.00
$0.00
$0.00
c. Business Income
$0.00
$0.00
$0.00
$0.00
e. Other Income
$0.00
$0.00
$2,075.67
$6,192.00
f. Total Monthly Gross Income (add lines 1a through 1e)

WSCSS-Worksheets - Mandatory (CSW/CSWP) 6/2008 page 1 of 5
Original
FAUBION, REEDER, FFtALEY & COOK, P.S.

5/16/2011 4:04PM
Father
M other
$207.57 j
$1,475.78
b. FICA (Social Security plus Medicare)/Self-Employment Taxes
$0.00
$0.00
$0.00
$0.00
$0.00
$80.00
$0.00
$0.00
f. Maintenance Paid
$0.00
$0.00
$0.00
$0.00
$207.57
$1,555.78
$1,868.10
$4,636.22
h. Total Deductions from Gross Income (add lines 2a through 2g)

3. Monthly Net Income (line 1f minus line 2h)
4. Combined Monthly Net Income (add parent's monthly net incomes from line 3)
(If combined monthly net income is less than $600, skip to line 7.)
5. Basic Child Support Obligation (enter total amount in box -->)
Tyler
$887
Hunter
$718

7. Each Parent's Basic Child Support Obligation
(If combined net monthly income on line 4 is less than $600, enter each parent's support
(advisory)
28.72%
71.28%
$460.96
$1,144.04
obligation of $25 per child. Number of children: 2. Skip to line 15a and enter this amount)
Part II: Health Care, Day Care, and Special Child Rearing Expenses (See instructions, page 3)
8. Health Care Expenses
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$ 0.00
(add p a ren ts's totals from line 8c)
$80.25
e. Maximum Ordinary Monthly Health Care (multiply line 5 times 0.05)

f. Extraordinary Monthly Health Care Expenses
$0.00
(line 8d m inus 8e, if "0" or negative en ter "0")

$ 0.00
$0.00
$ 0.00
$0.00
$0.00
$ 0.00
$0.00
$ 0.00
e. Total Day Care and Special Expenses (add lines 9a through 9d)
$ 0.00
11. Total Extraordinary Health Care, Day Care, and Special Expenses
(line 8f plus line 10)

Father
12. Each Parents Obligation for Extraordinary Health Care, Day Care, and Special Expenses
Mother
$0.00
$0.00
$460.96
$1,144.04
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$460.96
$1,144.04
c. Amount on line 15b adjusted to meet 45% net income limitation
$840.65
$2,086.30
d. Amount on line 15b adjusted to meet need standard limitation
$737.10
$3,505.22
e. Enter the lowest amount of lines 15b, 15c or 15d.
$460.96
$1,144.04
Part III: Gross Child Support Obligation

Part IV: Child Support Credits
c. Other Ordinary Expense Credit (describe)

Part V: Standard Caiculation/Presumptive Transfer Payment {See instructions, page 4)
15. Standard Calculation
a. Amount from line 7 if line 4 is below $600. Skip to part VI.
b. Line 13 minus line 14d, if line 4 is over $600 (see below if applicable).
Limitation standards adjustments
Part VI: Additional Factors for Consideration (See Instructions, page 4)

a. Real Estate
b. Stocks and Bonds

c. Vehicles
d. Boats
e. Pension/lRAs/Bank Accounts
f. Cash
g. Insurance Plans
h. Other (describe)
17. Household Debt (List liens against household assets, extaordinary debt)
Father's
Household
Mother's
Household
(Household Debt continued)
Father's
Household
M other's
H ousehold
j
Name
Name
Name
Name
c. Income of Children (If considered extraordinary)
Name
Name
d. Income From Child Support
Name
Name
e. Income From Assistance Programs
Program
Program
f. Other Income (describe)
20. Child Support Paid For Other Children

Name/Age
Name/Age
21. Other Chifdren Living In Each Household (First names and ages)
22. Other Factors For Consideration

Mother's income based on 2009 W-2.
Father's income based on YTD as of 8/8/10, divided by 31 weeks, X 52 weeks, divided by 12 months.
Signature and Dates

I declare, under penalty of perjury under the laws of the State of Washington, the information
Judge/Reviewing Officer
Date
2001-08 THOMAS E. JAFFE
E-FILED
May 18 2011 11:24 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
IN THE SUPER IO R CO U R T OF THE STATE OF W ASHINGTON

IN AND FOR THE C O U N TY OF PIERCE
!n re the Marriage of:
Petitioner,
v.
NO. 10-3-00961-1
RESPO N D EN TS W ITNESS LIST
JA SO N W ILLIAM SHIPM AN
_______________________ Respondent.
COMES NOW the Respondent, JASON SHIPMAN, by and through his attorney
of record, Daniel Cook, of FAUBION, REEDER, FRALEY, & COOK, P.S., and hereby
discloses the following possible primary witnesses:
W ITN ESSES EXPECTED TO BE CALLED A T TIM E OF TRIAL:
Jason Shipm an
C/O Faubion, Reeder, Fraley & Cook P.S.
Lakewood, W A 98499
253-581-0660
Witness is Respondent in this matter. He will testify to all relevant matters.
Respondent's Witness List - Page 1 of 3
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
Jennifer Shipman
c/o Timothy Greene, attorney for Petitioner.
Witness is Petitioner in this matter.
She will testify to all relevant matters.
Charles Papas
262 s. 3rd Street
Buckley, W A 98321
253-569-0228
Witness is a real estate agent and he can testify as to circumstances surrounding sale
of the home and cooperation of both parties regarding the same.
C hanthy Lodge
5605 112th Street E, Suite 600
Puyallup, W A 98373
253-904-1081
Witness is a Mortgage Loan Coordinator and she can testify as to the Respondents
attempts to refinance and keep house prior to separation.
B ecky Ram bo
11721 80th Avenue East
Puyallup, W A 98373
253-840-2301
Witness is Respondents mother who can testify about the both parents performance of
parenting functions, the childrens bonding and attachment with both parents and the
practicality of the Respondent/father or herself providing before and after school care.
Tyler and Hunter Shipm an

c/o Jason Shipman
8811-133rd St Court E
Puyallup, W A 98373
253-686-3971
Witnesses are the minor children of the parties. Tyler will be less than a month from his
17th birthday at the time of trial and Hunter will be 10 and Vi. Both children are mature
enough to intelligently articulate a reasoned and independent preference regarding the
residential schedule after dissolution of the marriage.
Respondents Witness List - Page 2 o f 3
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
Executive or Hum an Resources Representative of

Evergreen Fire & Security
2720 South "J" Street
Tacoma, W A 98409
(253)627-3794
Witness is former employer of Respondent and can testify as to communications made
by Petitioner to Respondent's employer.
EXPERT W ITN ESS EXPECTED TO BE CALLED AT TIME OF TRIAL

CPA from Tax C enter o f Am erica Inc.
10316 Bridgeport W ay SW
Lakewood W A 98499
Witness will testify as to the tax consequences of filing single versus joint and the tax
liability associated with each option.
The Respondent reserves the right to amend the Respondent Disclosure of
Primary Witnesses, and reserves the right to call at trial any and all of those witnesses
that may become known through further discovery.
The Respondent reserves the right to call at trial any witnesses identified by any
party in answers to interrogatories or other sources of discovery.
The Respondent further reserves the right to strike any of the depositions and/or
withdraw any designated witnesses before the time of trial.
DATED this
of May 2011.
Respondents Witness List - Page 3 of 3
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
June 02 2011 2:38 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
IN THE SUPERIO R COURT OF THE STATE OF W ASHINGTON

!n re the Marriage of:
NO. 10-3-00961-1
Petitioner,
v.
NOTICE OF INTENT TO W ITH D R A W

AS ATTORNEY

_______________________ Respondent.
TO:
AND TO:
CLERK OF THE COURT

Robert Lloyd and Timothy Greene, Attorneys for Petitioner
NOTICE IS HEREBY GIVEN that pursuant to CR 71(c) Daniel N. Cook of

Faubion, Reeder, Fraley & Cook, P.S. intends to withdraw as counsel of record for the
above Respondent, Jason William Shipman, on the 10th day of June 2011. The
withdrawal as counsel of record shall be effective immediately, without order of the
Court unless an objection to said withdrawal is served upon Daniel N. Cook within 10
days.
For purposes of further process of service, the last known address for Respondent,
which is known to be the true and correct address, is 8811 - 133rd St Ct. E., Puyallup,
WA 98373. Trial is currently scheduled in this case for July 25, 2011.
DATED May 18, 2011.
By Daniel N. Cook, W SBA 34866

O f Attorneys for Respondent
Notice of Intent to Withdraw as Attorney - Page 1 of 2
Files\Content. Outlook\13RLZYMV\Notice o f Intent to Withdraw (7). doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
DECLARATION OF MAILING
I, Sally DuCharme, am over the age of 18, and competent to testify in the abovecaptioned case.
On May 18, 2011, I mailed true and correct copies of the above Notice of Intent
to Withdraw. The documents were mailed via first class mail, via regular mail,
postage pre-paid, to:
Jason Shipman
8811 - 133rd St Ct. E.
Puyallup, W A 98373
l DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE
STATE OF W ASHINGTON, THAT THE FOREGOING IS TR U E AND CORRECT.
Signed on Wednesday, May 18, 2011, at Lakewood, Washington.
Sally DuGfiarme

C:\Documents and Seffings\dcook\Local Settings\Temporary Internet
Files\Content.Outlook\13RLZYMV\Notice o f Intent to Withdraw (7).doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100TH Street SW, Ste 25
Lakewood WA 98499
253-581-0660
1 3 8 2 b 6 / 1 6 / 2 0 1 1
3201S9
4
5
6
7

County of Pierce
No. 10-3-00961-1
Petitioner(s),
and
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Respondent(s).
12
DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
FOR MODIFICATION
OF TEMPORARY ORDERS
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This declaration is made by:

Name:
Jennifer Shipman
Age:
I am over 18 years of age and I am competent.
Relationship to the parties in this action: I am the petitioner

/ Declare:
First of all. I worked as an RN for ten years, not the 5-6 years that Jason states in his
Declaration. This is not a material mistake for the purposes of this Declaration, but f
wanted to set the record straight.
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I did not contribute to Jasons layoff. I did call Jason's employer and said that Jason had
21
left company materials and equipment in his garage. I did that over one year ago.
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c":
DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
TO MODIFY TEMPORARY ORDERS

S treet: 4115 S. M eridian, Ste. B
Mailing; P.O. Box 731063
Puyallup, W ashington 98373-0030
PH: (253) 770-0808, Fax (253) 770-0259
laS-25.
3 2 d i6 g
1
2
T nailed
Jasons employer because Jason had moved out of the house and, in fact, had left
materials and equipment belonging to his employer in the garage. I acted in good faith
because the equipment and materials belonged to Jason's employer and I wanted to give
the rightful owner the opportunity to get the equipment back: and, also. I did not want to
be held responsible for the equipment, and accused of being in possession of stolen
property, since 1 had not taken the equipment and materials in the first place, and Jason
had not consulted me when he started storing the equipment and materials in our garage.
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A meeting was never set up between me and the attorney for Jasons employer. I was
advised by Jasons employer to have mv attorney call the attorney for Jasons employer,
and I told mv attorney. Mr. Greene. Mr. Greene advised me that if Jasons
employer
wanted the equipment and materials, the employer would just come out and retrieve it.
and that I had done mv duty bv giving his employer notice that the equipment and
10
materials were there. If Jason had not wanted me to be concerned about the material and
11
equipment from his employer in our garage, he should have removed it when he moved out
or shortly thereafter. Jason provides no proof that he was laid off because of this incident.
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If Jasons employer was concerned, certainly there would have been an investigation that
Jason could have documented, and certainly the employer would not have waited over a
year to terminate Jason.
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Jason has the right to have his support payments modified if he has been laid off. But he
16
should first provide proof of how much his unemployment checks are through payment
stubs from Employment Security. He should also be required to provide an updated
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Financial Declaration. Finally, he should provide evidence of his job searching efforts, as he
is required bv Employment Security to contact three prospective employers weekly. Also
the figures that Jason has provided regarding mv income are incorrect. I am filing a
Financial Declaration and Sealed Financial Source Documents which document mv correct
income. I am accordingly also filing mv own proposed Child Support Worksheets.
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DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
Law Offices o f G reene & Lloyd, PLLC

Puyallup, W ashington 98373-0030
PH: (253) 770-0808, Fax (253) 770-0259
i38Z b
6^ 1 6 ^ 2 8 1 1
328161
I am opposed to Jason exercising a right of first refusal at this time. Actually. 1 am

concerned at this time about Jasons unsupervised visitation with the bovs. period. The
basis of mv concern is that Jason is dating a woman who is now living with him, and he
refused to disclose anv information about her for the last 10 months that I have inquired.
Jason refused to give me her name, and called m v crazv (and worse), when I asked to have
a background check done on her. Certainly. I have the right to know about anv adult living
in Jason's household if the bovs are going to be staving with him. And, if I ever chose to
have anv other adult living with me. Jason would have the same rights of disclosure. The
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womans name is Melissa Jill Hart. When I asked Jason about her. I received phone and
text messages filled with verbal abuse. I finally obtained her name and some information
about her. So. I did some checking on mv own and discovered that a Melissa Jill Hart was
either arraigned or convicted in Kittitas County Superior Court ( Case #10-1-00121-1) of
second degree burglary and malicious mischief). I also had obtained Ms, Harts maiden
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name and determined that she has had some issues in state district courts, though at this
11
time 1 do not know if they are criminal matters or traffic infractions.. When I confronted
Jason with this information, he admitted that Ms. Hart had been in trouble with the law.
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and that she had caught a previous boyfriend cheating on her, and she damaged his car
with thrown rocks, and entered his home and continued to commit property damage inside.
I have ordered a
copy
of the record from Case #10-1-00121-1 from the Kittitas Countv
Superior Court to find out mvself what has happened, and, among other things, determine
15
if this was a prior act of domestic violence. Besides the potential nature of the crimes
16
themselves. I am concerned because Jason owns several guns, and keens them in his
apartment: I am fearful that Ms. Hart may have a violent disposition with guns on the
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property.
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This being said, a full disclosure of Ms. Harts criminal record and rehabilitation (if any)
mav change mv position on this issue. 1 do want to be reasonable, and do want mv bovs to
have a normal relationship with their father. But this information on Jasons girlfriend is
disturbing. I note that she often drives the bovs around, and her involvement with the hoys
would only increase under the right of first refusal proposal of Jasons.____________
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DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
L aw O ffices o f G reene & L loyd, PLLC

S treet: 4115 S. M eridian, S te. B
M ailing: P.O. B ox 731063
P u y a llu p , W ash in gton 98373-0030
PH: (253) 770-0808, Pax (263) 770-0259
i3fcJ2b
6 / i fe / ^ 2 8 1 i
326162
1
2
Jason is a hypocrite on this issue, and on the issue of saving daycare costs me changing
schools._______________________________________________________________________
3
4
I was found in contempt because I moved and 1 enrolled the children in different schools
close bv to where I live without Jasons input. The court found I had abused the joint
decision-making clause of the parenting plan bv acting
unilaterally in the move in a
manner which affected the childrens education. I will live with the courts decision,
although I will note that at least I e-mailed Jason and advised him I was moving. I advised
mv attorney and he thought the move was OK. and the new schools were within the same
8
9
school district and were the schools the children would normally go to given the move.
Jason, on the other hand, has for ten months verbally abused me for asking about the
woman he is living with. He savs it is none of mv business. Jason only believes in joint
decision making when it is in his interests.
10
n
Also, the only reason Hunter was put in davcare was because J had to change schools back
again after I was found in contempt. There is nothing wrong with that in and of itself.
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1 respect the courts decision. But then Jason has refused to pay a dime for the davcare
anvwav. Accordingly. I have been subsidizing his choice of schools for the bovs (this would
not bother me if Jason would obey the child support order and nav his share of the
support!. The right of first refusal argument is a pretext, because Jason is not paving for
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davcare anvwav. so the fact that he is unemployed doesnt change anything! I have mailed
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Jason the carbon copy portions of the checks I used to pav for the davcare bv certified mail
and he has refused to pick them
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up.
I have texted Jason advising him that 1 h a v e
m a ile d
the invoices to him bv certified mail. Unless Jason becomes current on his hill immediately.
1 reserve the right to file contempt charges against him for not paving his child care bill.
Jason talks about wonderful opportunities to spend time with the bovs. hut, his
performance as a father has troubled me lately in this dissolution process. He has refused
to help pav anv share of the bovs" expenses in extracurricular activities, and he has not
attended meetings with juvenile probation over Tvlers diversion program, a program Tvler
22
23
DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
L aw O ffices o f G ree n e & L loyd, PLLC

S treet; 4115 S. M eridian , S te. B
M ailing: P.O. B o x 731063
P u y a llu p , W a sh in g to n 98373-0030
P H : (253) 770-0808, F ax (253) 770-0259
1382b
621622811
J28163
I
2
3
needs and which has heen very helpful for Tvler.Jason is not doing this to hurt the bovs. T
know he loves the bovs. He is angrv at me. But his anger is hurting the bovs.____________
Regarding the issue of me being ordered to let the bovs bring clothes and toys from mv
household into Jason's . l a m opposed. The reason is that I allowed the bovs to bring their
own clothes from mv household, and then the clothes would not be returned. So. I wisely
stopped letting the bovs bring clothes from mv household. Unless Jason has lost the clothes
I have already sent over, they should have clothes at Jasons household, anvwav.
Regarding tovs. I also am opposed to letting the bovs bring them, as again they will likely
not be returned.. Jason has tovs for the bovs at his house, including video games and
skateboards.
The court should not agree to "right of first refusal until more is known about_________
10
the woman living with Jason. Melissa Jill Hart. The court should adopt mv proposed
11
Child Support Worksheets and Order of Temporary Child Support. The court orderd Jason
and I to enter into co-parenting counseling when the contempt motion is heard, and T
12
13
would ask that the parties enter into that counseling forthwith, and that we split the costs
of the counseling 50/50.
14
15
16
Signed at Puyallup, Washington on June 15, 2011.
17
Jennifer Kav Shipman

Print or Type Name
18
19
20
21
Do not attach financial records, personal health care records o r confidential

22
23
DECLARATION OF
JENNIFER SHIPMAN
IN RESPONSE TO
RESPONDENTS MOTION
Law O ffices o f G reen e & L loyd, PLLC

S treet: 4116 S. M erid ian , S te. B
M ailing: P.O. B ox 731063
P u y a llu p , W ash in g to n 98373-0030
PH: (253) 770-0808, Fax (253) 770-0259
13825
6/18X 2811
328164
fc-g O FFIC E
1HCQU'
15201'
p.m
6
7
8
)
)
) Case No.: 10-3-00961-1
)
) COVER SHEET:
) PETITIONERS FINANCIAL
) DECLARATION
)
)
9
10
JENNIFER SHIPMAN,
Petitioner,
11
And,
12
JASON SHIPMAN,
____________Respondent.
13
To the above named Court
14
Attached please find Petitioners Financial Declaration.
15
16
Respectfully submitted this 15th day of June, 2011
17
18
19
20
21
22
COVER SHEET:
1 of 1

Mailing Address: P.O: Box 731063
(253) 770-0808, Fax (253) 770-0259
0 6 /1 5 /2 0 1 1
0 9 :3 8
FEDEX
253 841-3484
&W
2 S il
3 2 8 i4 ^G E

County of
&.re; Th e
mounriaQo s
Tim vfer
6fiipm&n
No,
Petitioner.
and
neon UOtlliurr> 6fupnwu

Respondent
Name: J e n n i l t y
to y
S h ip m
D4 Petitioner
[ ] Respondent
(FNDCLR)
a n
Date o f Birth: e h J M
/H

Declarant's Total Monthly Net Income (from
3.3 below)
Declarant's Total Monthly Household Expenses (from 5.9 below)
Declarants Total Monthly Debt Expenses (from 5J 1 below)
Declarants Total Monthly Expenses (from 5,12 below)
$ V / 9 /9 0 *
Estimate of the other partys gross monthly income (from 3. l f below)
&
[ ] $ _____ _
1X3 unknown

2.1
Occupation:
2.2
The highest year of education completed: ] t |
2.3
Are you presently employed?

a. If yes:
H U T Se.
(1)
Yes [ ] No
Where do you work. Employers name and address must be listed on the
Confidential Information Form.
Financial Declaration (FNDCLR) - Page 1 of 6

WPF DRPSCU 01.1550 (6/2006) - RCW 26.16.220(1)
06
0 6 /1 5 /2 0 1 1
09:38
2 5 3 -8 4 1 -3 4 8 4
b. If no:
"
FEDEX
&w
2 s ii
32
(2)
When did you start work there (mooth/year)?
e b o 2 .e >
(0
(2)
(3)
When did you last work (month/year)?
lU a
$
What were your gross monthly earnings'?

Why are you presently unemployed?
b i
* ^
ge
_____
O ld .
111. Income Information

Jf child support is at issue, complete the Washington State Child Support Worksheets), skip Paragraphs 3-1 and 3.2.
If maintenance, fees, costs or debts are at issue and child support is N a t an issue this entire section should be
completed. (Estimate o f other party* income information is optional.)
3.1
Gross Monthly Income

Jf you arc paid on a weekly basis, multiply your weekly gross pay by 4.3 to determine your monthly wages
and salaries. If you arc paid every two weeks, multiply your gross pay by 2.15. If you are paid twice
monthly, multiply your gross pay by 2. If you are paid once a month, list that amount below.
Name . .
a.
Wages and Salaries
b.
Interest and Dividend Income
c.
Business Income
d.
Spousal Maintenance Received
Name
s k n r w sh tp n w i ___________
s 5, &/5~. '33
s
j 0
$
$p
$
From
c.
Other Income
f.
Total Gross Monthly Income fadd lines 3.1a throuth 3.lei
g.
Actual Gross Income (Ycar-to-datc)
p
_
s p
S 5] &*(&>>
s
S

$
! DU Ofd p
a.
Income Taxes
b.
nCA/Self-emnioymcm Taxes
c.
State Industrial Insurance Deductions
d.
Mandatory Union/Professional Dues
e.
Pension Plan Payments
f-
s tp
g-
Normal Business Expenses
h.

(add tines 3.2a through 32g)
S jp ___
%ft Lfi3Qt ~}p
Monthly Net Income (Line 3. If minus line 3.2h or

line 3 from the Child Support Worksheets).)

WPF DRPSCU 01.1550 (6/2006) - RCW 26.18.220(1)
$
$ 4 ______
q .a W .O g ,
$
$
0 6 /1 5 /2 0 1 1
3.4
2 S ii
FEDEX
2 5 3 8 4 1 -3 4 8 4
0 9 :3 8
3 2 8 1 6 PAGE
Miscellaneous Income
a.
Child support received from other relationships
b.
Other miscellaneous income (list source and amounts)
$ j f ) _______
% J>
1
$
$
% (p
c.
$ 6V*
Total Miscellaneous Income (add lints 3.4a throuiih 3.4b> $ (t)
Income of Other Adults in Household

3.6
__
$
S
S (f>
If the income of either party is disputed, state monthly income you believe is correct and explain below:

4.1
Cash on hand
4.2
On deposit in banks
s M
4.3
Stocks and bonds, cash value o f life insurance
sjzS_______
4.4
Other liquid assets:
_______

Monthly expenses for myself and
dependents are: (fixpenses Hhould be calculated for the future,
after separation, based on the anticipated residential schedule for the children.)
5.1
Housing
sh & iS J X )
Installment payments for other mortgages or encumbrances

Taxes & insurance (if not in monthly payment) ^Q c tb iC tS /iflS)
%a b . b b
Total Housing
5.2
Utilities
Heat (gas & oil)
* -$ ____
Electricity
j iS tD .o o

WPF DRPSCU 01.1550 (6/200$) - RCW 26.18.220(1)
0B /15/2011
09 :3 8
fedexM
253--B 41-3484
b/M 4 Z B ly
P age
09
s (p O.OD

(S
Telephone
Bui)4 k i - J s aaO'Qd
C,blc .
Other f/H ernet
L *
s Q fto .co
Total Utilities
5.3
320
Food and Supplies

Food for
s^
itZU2Q.
$ ST).DO.
persons

Meals eaten out
5.4
Other
s 4
Total Food Supplies
$?OCUXi
Children
DO
S i00-00
S0
Clothing
Tuition (if any)
(SpOtis)
s 3UD
Total Expenses Children
5.5
Transportation
s S M .lfo
s G jfn .n o

Parking
_______
IdfUUUth
$ $//96>.=?s) I M
<tf I'C filp.lb

5.6
5.7
Health Care (Omit if fully covered)

Insurance *
IS J .W
Uninsured dental, orthodontic, medical, eye care expenses
S^
Total Health Care
sS h l f
Personal Expenses (Not including children)

Clothing
Hair care/personal cure expenses

WPFDRPSCU01.1550 (&2008) - RCW26.18.220(1)
b f s z u io
$z> ,co
o fm sM
0 6 /1 5 /2 0 1 1
FEDEX W P S !
2 5 3 --8 4 1 -3 4 8 4
09 :3 8
b / M
t Z 011
3 2 0 1 fc PAGE
Clubs and recreation V
5.8
Education
________
Books, nen'spapers, magazines, photos
5 SD'OO
Gifts
$ 52.00
Other
$/
(trf. SD
Miscellaneous Expenses
oaxrMnu p CteU)___________ ___
otherlm
H < fs c h /in ) Jim A
).
%AQP-..QD
________
M l.2 k
5.9
Total Household Expenses (The total ofPwngraph! 5.1 through 5.8)
s M & 3Q . to
5.10
Installment Debts Included in Paragraphs 5.1 Through 5.8

Creditor
Re/i Canoe.
JSsUJli. M/te.
5.11
Balance
L o e J ffJ re jk h
JJiD ,LW
shiAs/rf- loan
4 3 , pop
Tast Payment
Other Debts and Monthly Expenses not Included in Paragraphs 5.1

Through 5.8
Creditor
ib
Month of
Description
of Debt
Description
of Debt
Balance
G uar d
Month of
Last Payment
Amount of
Monthly
Payment
7 i ?
S a lk t Hop
$______
%______
5 ________
$______
Total Monthly Payments for Other Debts and Monthly Expenses
W PF DRPSCU 01.1550 (6&006) - RCW 26.16.220(1)
s lleQ jfl
0 6 /15 /2 0 1 1
5.12
FEDEX
253 84 i - 34 84
0 9 :3 8
2811
3 Z t1 1 y PaGE *

VI. Attorney Fees
6. t
Amount paid for attorney fees and costs to date:
6.2
The source of this money was:
6.3
Fees and costs incurred to date:
6.4
Arrangements for attorney fees and costs are:
6.5
Other:
x4,131. CD
$________
* 0 ^ io tW u 4 h l'S / T U k fk d l W JCS16YI % G tfy jT C O s fs
w&kr L&U) grwp
1 declare under penalty o f perjury under the laws of the state of Washington that the foregoing is true and correct.
[City]
LQ^___[Stale] on _ M
______ '
i/
___[Date].
KJ e ,n n & r k ip m a s )___________
Print or Type Name
The follow ing financial records are being provided to the other party and filed separately with the court.
Financial records pertaining to myself:
f t Individual [ ] Partnership or Corporate Income Tax returns fin the years
________
_________________________ . .
. j______________including all W -2s and schedules;
^ Pav stubs for the dates o f 4 / &J/J-'i d w
l l ________________________________ _
[ j Other..
Do not attach these financial records to the financial declaration. These financial
records should be served on the other party and filed with the court separately
using the sealed financial source documents cover sheet (WPF DRPSCU
09.0220). If filed separately using the cover sheet, the records w ill be sealed to
protect your privacy (although they w ill be available to a ll parties in the case,
their attorneys, court personnel and certain state agencies and boards.) See GR
22(C )(2),

WPF DRPSCU 01.1560 (6/2006) - R C W 26.18.220(1)
13^47
6 /1 W 2 B 1 1 88836
1 111 1
FILED

10-3-00961-1
36617522
AFRSP
06-17-11
a .m .
JUN 16 2011
p.m .
ja y is g g
Superior court of Washington

County of Pierce
In the Marriage of:
No. 10-3-00961-1
Petitioners),
DECLARATION OF
JASON SHIPMAN
And
Respondent(s)

Name:
Jason Shipman
Age:
I am over 18 years of age and I am competent
Relationship to the parties in this action:
I am the respondent
I Declare:
The petitioner did not tell the truth in her response. First, she made many phone calls to
me threatening to call my employer and tell them that 1 had stolen property from them. I
explained to Jennifer that everything in the garage belonged to me and told her where I
got it from. I also told her, that if she felt she was in possession of stolen property, she
should call the police. She also was not truthful about allowing my employer to come to
the house and check the equipment. They tried to set up a time with her and she refused
to allow them to come over. I have a representative from the company on my witness list
who can explain this during the hearing on July 25th.
13947
8 /1 7 / 2 8 1 1
Jennifer is also lying about me not giving her information about my girlfriend, Melissa. I
sent her an e-mail with Melissas phone number and told Jennifer to call her. I have
enclosed a copy of that e-mail. I also told her that Melissa would answer any question she
might have. Melissa has always been willing to sit down and talk to Jennifer. Melissa is
an honest person and always takes responsibility for her actions. The charge against her
was an isolated incident. She is not an angry or violent person. The state prosecutor
wanted to drop the charges against her, but the owner of the property wanted her to pay
for the damages to his shop, even some that she didnt even do. The state and Melissas
attorney hired a private investigator to look into all the damages. I have also enclosed a
copy of the order for the investigator. Melissa has nothing to hide from Jennifer and has
offered to give her a copy of her criminal history. Which only includes this offense and
one when she was nineteen (non-violent offense). There have been several incidents with
Jennifer being violent towards me and our kids. She has tried to say that she is scared of
me but yet I have police reports stating that Jennifer has attacked me.
As for the guns Jennifer says I have in my house, which is also untrue. I gave her all my
guns when 1moved out. Since then I have acquired a shotgun and a youth model rifle for
my son. I keep those guns locked in a safe at my parents home. Melissa doesnt believe
in carrying guns. Jennifer has told me a couple of times that she carries a gun in her purse
so I better watch out. Jennifer continues to do spiteful things and accuses me doing them.
She doesnt see that the things she is doing are wrong. I have tried on numerous
occasions to get Jennifer to go to counseling with me. My employer would have paid for
it. She refused to go. She just keeps saying that as long as I live with another woman she
will never talk to me.
Jennifer has never allowed the kids to bring toys or clothes to my house. I tried to take
the boys to her house to get clothes and she locked the boys out. Our youngest son has
come to my house crying because his mom refuses to let him bring his bike to my house.
I have purchased clothes for the kids, but when the go to their mothers house I never see
those clothes again. I have asked her to send at least one change of clothes so they dont
have to go to school in clothes that they have been wearing all weekend. She also refuses
to do that. It is ridiculous that she doesnt see how badly she is hurting the boys by doing
things like this.
1 am enclosing copies of my unemployment check stubs. I make $267.00 a week after
child support, I am having a hard time paying rent let alone all other expenses, electric,
water and etc. The daycare expense for Hunter could be completely avoided, if Jennifer
would allow me or my parents to take him to school in the mornings. She is being
completely unreasonable about this.
Cty&yn
r lm uiwivin
1384?
dli^ l v^vnuvvj
i58is3tj
---- -------------
STATE O F W A S H IN G T O N - EM PLOYM ENT SECURITY DEPAIj

JASON
W SHIPM AN
P O O R
C |U A b . iT Y
0 5 / 28/11
DETACH AT PERFORATION BEFORE C ASH IN G
STATE O F W A S H IN G T O N - EM PLOYM ENT SECURITY DEPAR M E N T
880372437
IllllllllllllllllllUllllllllllillllil
05/14/11
DETACH AT PERFORATION BEFORE C ASH IN G
STATE O F W A S H IN G T O N - EM PLOYM ENT SECURITY DEPAR

RTM ENT
JASON
III111III1111IIIIII1
W S H IP M A N .
f e ll
770
Wm&t'B viiSSyl
0 4 /2 8 /1 2
0 6 /0 6 /1 1
0 6 /0 4 /1 1
10956
498
9606
50
181
267
~
AYs,:N
, !gs^C\4-NETÂ/v\T
'IypDM
neE
^Îfog
v./ofoTfsTf? ;{2J6sE,n5^ft^!riEW;
2 net&2\TI
06/04/11
, DETACH AT PERFORATION BEFORE CASHIN G
j'
'
STATE O F W A S H IN G T O N - EMPLOYMENT SECURITY DEPARTMENT
WE REDUCED YOUR PAYMENT FOR THE WEEK( S) ENDING 0 6 / 1 1 / 1 1 YOUR WEEKLY B E N E F IT AMOUNT j lS REDUCED BECAUSE:
1.
YOU WORKED AND REPORTED* E A R N IN G S ;
2.
OR
YOU WERE NOT A BLE TO WORK OR A V A IL A B L E FOR WORK ONE OR TWO DAYS DURING THE
WEEK; OR
|
|
3.
YOU R E C E IV E D A P E N S IO N ;! OR
4.
YOU REPORTED 4 0 OR MORE HOURS WORKED DURING THE WEEK C L A IM E D ;
5.
YOU REQUESTED
OR
1 0 * OF YOUR B E N E F IT S W ITHHELD FOR IR S P U R P O S E S .

v
ALSO , !
WE DEDUCTED B E N E F IT S BECAUSE OF A C H IL D SUPPORT ORDER FROM THE DEPARTMENT OF

S O C IA L AND H E A L T H (S E R V IC E S .) I F YOU HAVE Q U ESTIO N S ABOUT T H E ! AMOUNT B E IN G
DEDUCTED, CONTACT I t HE D IV IS IO N :O F C H IL D SUPPORT.
1347
^ 1 7 /2 6 1 i
a63S
Umaii - (no subject)
Page 1 o f 4
g IK
jason shipman <outlaw0015@gmail.com>
tyt'OO^le
(no sub ject)

8 messages
chevygirlOl 5@vzw.blackberry.net <chevygirl015@vzw. black berry .net>
Sat, Oct 2,2010 at 8:52 PM
Reply-To: chevygirlOl 5@vzw.blackberry.net

To: ASSHOLE <outlaw0015@gmail.com>
The stuff you left behind is no longer yours. I think I'm going to file a police report.
Sat, Oct 2, 2010 at 8:53 PM
To: chevygirl015@vzw.biackbeny.net
What r u talking about
[Quoted text hidden]
chevygirl015@vzw.blackberry.net <chevygirl015@vzw.blackberry.net>
Sat, Oct 2, 2010 at 9:02 PM
Reply-To; chevygirlOl 5@vzw. blackberry.net

To: ASSHOLE <outlaw0015@gmai!.com>
I have witnesses you fool
From: iason shioman <outlaw0015f5Jamail.com>
Date: Sat, 2 Oct 2010 20:53:44 -0700
To: <chewairl015fa>vzw. blackberry. net>
Subject: Re:
jason shipman <outlaw00l5@gmail.com>
Sat, Oct 2, 2010 at 9:03 PM
To: chevygirl015@vzw.blackberry.net
I don't know what your problem is this time. What stuff r u making up today. What do you mean stuff I left
behind. Ueft everything behind, i took my clothes and a few personal items. You have everything we
acquired over 16 years. I left it all to be nice. You cant appreciate that. I have always though of you through
this. You treated me awful anyway. Be. Specific what did I leave behind. Oh yea my whole life. You did this.
You wanted this not me. Stop being crazy. Think about the kids. Stop telling them bad stuff about their dad. I
don't do that to you.
On Oct 2, 2010 8:54 PM, <chewQirl015fSlvzw.blackberrv.net> wrote:
> I have witnesses you foo)
> Original Message
> From: jason shipman <outlaw0015@amail.com>
> Date: Sat, 2 Oct 2010 20:53:44
> To: <chewairlQ15@vzw.blackberrv.net>
> Subject: Re:
>
> What r u talking about
> On Oct 2, 2010 8:44 PM, <chevvair1015f5)vzw.blackberrv.net> wrote:

The stuff you left behind is no longer yours. I think I'm going to file a
> police report.
>
https://mail.google.com/mail/?ui=2&ik=8bfal 3ada4&view=pt&searchînbox&th=12b70...
10/14/2010
13847
f e /i7 ^ Z o ll
.8 1 5 8 4 8
Gmail - (no subject)
Page 1 o f 1
hyOooglc'
(no s u b ject)
2 messages
Fri, Oct 1,2010 at 9:12 PM

I'm not going to talk to you until you give me the info l asked.
Fri, Oct 1, 2010 at 11:36 PM
To: chevygirl0l5@vzw.blackberry.net
Melissa's phone number is 253-278-3940. She has nothing to hide. She will give you her name. She is a nice
person. Just ask her anything you want.
hrtps://mail.google.corn/mail/?ui=2&ik=8bfal3ada4&view=spt&search=inbox&th=12b6b...
10/14/2010
13847
& /1 7 /Z 8 1 1
@ 8 64 1
Page 2 o f 4
Sat, Oct 2, 2010 at 9:39 PM
You know what, just fuck off. Lies. That's all you know. You are your fathers son.
From: jason shipman <outlaw0015@amail.com>
Date: Sat, 2 Oct 2010 21:03:09 -0700

Sat, Oct 2,2010 at 9:37 PM
Jennifer please stop acting like this. I will always try to be your friend. I will always do my best to keep the
kidding mind. Please think of them. I wish you could calm down. You have a great man in your life. Two
wonderful kids. You found God. But you still want to make my life miserable. I don't understand. You are
hurting the boys
On Oct 2, 2010 9:31 PM, cchevvQirl015@vzw.blackberrv.net> wrote:
> You know what, just fuck off. Lies. That's all you know. You are your fathers son.
> Original Message
> From, jason shipman <outlawQ015@amail.com>
> Date: Sat, 2 Oct 2010 21:03:09
> To: <chevvairl015@vzw.blackberrv.net>
> Subject: Re:
>
> I don't know what your problem is this time. What stuff r u making up
> today. What do you mean stuff I left behind. I left everything behind. I
> took my clothes and a few personal items. You have everything we acquired
> over 16 years. I left it all to be nice. You cant appreciate that. I have
> always though of you through this. You treated me awful anyway. Be. Specific
> what did I leave behind. Oh yea my whole life. You did this. You wanted
> this not me. Stop being crazy. Think about the kids. Stop telling them bad
> stuff about their dad. I don't do that to you.
> On Oct 2, 2010 8:54 PM, cchevvgirl015@vzw.blackberrv.net> wrote:
Original Message
From: jason shipman cputiawOOl 5@amail.com>
Date: Sat, 2 Oct 2010 20:53:44
To: <chevvairl015@vzw.blackberrv.net>
Subject: Re:

On Oct 2, 2010 8:44 PM, <chewairl015@vzw.blackberrv.net> wrote:
> The stuff you left behind is no longer yours. I think I'm going to file a
police report.
>

To: chevygirl015@vzw.biackberry.net
Sat, Oct 2, 2010 at 9:58 PM
For the last time, fuck off! Why am I like this? Really? U don't know? Well then u never loved me. Be happy
with ur scank. A scank living w/a married man...
I wish you would stop texting me this stuff.
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view^pt&search=mbox&th=12b70...
10/14/2010
13B47
8 i* g 4 2
Page 3 o f 4
On Oct 2, 2010 9:31 PM, <chewairi015@vzw.blackberrv.net> wrote:

> -- Original Message----> From: jason shipman <outlawQ015@amaii.com>
> Date: Sat, 2 Oct 2010 21:03:09
> To: <chevvairl015@vzw.blackberrv.net>
> Subject: Re:
>
> I don't know what your problem is this time. What stuff r u making up
> always though of you through this. You treated me awful anyway. Be. Specific
> what did I leave behind. Oh yea my whole life. You did this. You wanted
> stuff about their dad. I don't do that to you.
> On Oct 2, 2010 8:54 PM, <chewairi015@vzw.blackberrv.net> wrote:
l have witnesses you fool
Original Message
From: jason shipman <outlaw0015@gmail.com>
Date: Sat, 2 Oct 2010 20:53:44
To: <chevvairl015@vzw.blackberry.net>
Subject: Re:

On Oct 2, 2010 8:44 PM, <chevyqirl015@vzw.blackberrv.net> wrote:
> The stuff you left behind is no longer yours. I think Im going to file a
police report.
>

Sat, Oct 2, 2010 at 10:02 PM
You are so immature you text nasty stuff then block my number
III cut and past it. Then put it in email form. I'm done being treated like this. Its all for you. I tolerate you
craziness for our kids. I love you and them. I can't live with you. I'll try to be your friend
On Oct 2, 2010 9:31 PM, <chewQirl015@vzw.blackberrv.net> wrote:
> Original Message
> From: jason shipman <outlawQ015@amail.com>
> Date: Sat, 2 Oct 2010 21:03:09
> To: <chevvairlQ15@vzw.blackberrv.net>
> Subject: Re:
>
> I don't know what your problem is this time. What stuff/ u making up
> always though of you through this. You treated me awful anyway. Be: Specific
> what did ! leave behind. Oh yea my whole life. You did this. You wanted
> stuff about their dad. I dont do that to you.
> On Oct 2, 2010 8:54 PM, <chevvqirl015@vzw.blackberrv.net> wrote:
Original Message
From: jason shipman <outlaw0015@qmail.com>
httDs://mailgoosle.com/mail/?ui=2&ik=8bfal 3ada4&view=pt&search=inbox&th^l 2b70...
10/14/2010
138 4 7
fc/l W Z H l i
88043
Page 4 o f 4
Date: Sat, 2 Oct 2010 20:53:44

To: <chevVQirl015@vzw.blackberrv.net>
' Subject: Re:

On Oct 2, 2010 8:44 PM, <chewairlQ15@vzw.blackberrv.net> wrote:
> The stuff you left behind is no longer yours. I think I'm going to file a
police report.
>
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search=inbox&th-12b70..*
10/14/2010
IJU 4 V
f a / i V / ^ 8 11
00844
Page 7 o f 8
Unbelievable mansion. He treats me well, like a man should treat a woman. I will have him get her last name.
I'm in a good place. Good bye.
From: jason shipman <outlaw0015@.Qmail.com>
Date: Fri, 1 Oct 2010 21:26:03 -0700

Fri, Oct 1, 2010 at 10:18 PM
Do you read what you say. You dont want a divorce but you have a wonderful man in your life. And get
whose last name is that a threat. For the third, time what info do you want l will sigh the papers. The only
thing I ask is stay in the house until it sells. Please don't switch the kids schools. Ill help in any way I can w
work at the house or whatever I can. What info do you need.
On Oct 1, 2010 9:42 PM, <chewairlQ15@vzw.blackberrv.net> wrote:
> I'm done. You didn't give me the info.
>
> I did not and still don't want this divorce. This is 100% your doing. Not mine. You are the one insisting to
ruin our family. You brought that trash into our kids lives. How disgusting.
>
> Im better off without you now. I'm going to church. I'm accepting my faults as well as my goods. My man is
wonderful. He is Marvelous. Excellent job. Well respected in the community. His kids are super. Great cook.
Unbelievable mansion. He treats me well, like a man should treat a woman. I will have him get her last name.
I'm in a good place. Good bye.
> Original Message---> From: jason shipman <outlaw0015faiQmail.com>
Repty-To: chevygirl0l5@vzw.blackberry.net
Fri, Oct 1, 2010 at 10:39 PM
What part of I can't afford the mortgage payments don't you get? I can't.
No threat. I have every right to know about the woman of the month you have around my kids. Just like you
have the same right. What is her name?
From: jason shipm an <o u tlaw 0015@ Q m ail.com >
Date: Fri, 1 Oct 2 01 0 2 2 :1 8 :1 7 -0 7 0 0

Fri, Oct 1, 2010 at 10:37 PM
All you had to do is ask Melissa. What is your boyfriends name. What was your last boyfriends name. The
Guy that took my kids to Seattle. And the Guy before him. Melissa is the only woman around your kids.
Changing schools sucks. Ill help w the house work. Just don't put the kids through that. You r a nurse. I give
you money. Keep them in the same school.
On Oct 1, 2010 10:31 PM, <chevvQirl015@vzw.blackberrv.net> wrote:
> What part of I can't afford the mortgage payments don't you get? I can't.
>
> No threat. I have every right to know about the woman of the month you have around my kids. Just like you
have the same right What is her name?
Vittnc7/mailpooyle.com/mai!/?ui=:2&ik^8bfal3ada4&view=Dt&search=:inbox&th=12b69...
10/14/2010
1384? fe /i V"/2i3i A 888 4S
Page 6 o f 8
You are pathetic. You can't even provide the simple necessities for your children.! have to do that for you.
Hunter left shoes and jeans at your house on wed. Socks and yet another pair of shoes in football bag. I sent
three shirts with Tyler. 1expect them all (2 sets of shoes, 2 sets of jeans, 3 t-shirts & a sweatshirt) back with
Hunter on Monday.
No games. Give me her last name.
From: jason shipman <outlaw0015@Qmaii.com>
Date: Fri, 1 Oct 2010 21:08:46 -0700
To: <chewqirl015@vzw.blackberrv.net>
Subject: Re.

To: chevygirl015@vzw.biackberry.net
Fri, Oct 1, 2010 at 9:26 PM
Again with fights and lies. He left a pair of shoes and pants here Wednesday. I offered to bring them or you
could come get them. He still has no underwear or socks. I pay my child support through support enforcement
like you asked. This fighting only hurts the kids. Why are you being like this it only hurts the kids. I wouldn't
do this to you. You asked for a divorce three times. I gave it to you. You have a "real man" yet you continue
to be so mean to me. Jennifer l will always care about you. I only want to be friends and work as a team to
raise the boys. Again I ask what info do you need.
On Oct 1,2010 9:15 PM, <chewairlQ15@vzw.blackberrv.net> wrote:
> You are pathetic. You can't even provide the simple necessities for your children. I have to do that for you.
Hunter left shoes and jeans at your house on wed. Socks and yet another pair of shoes in football bag. I sent
three shirts with Tyler. I expect them all {2 sets of shoes, 2 sets of jeans, 3 t-shirts & a sweatshirt) back with
Hunter on Monday.
>
> No games. Give me her last name.

> ---Original Message----> From: jason shipman <outlawQ015@amaii.com>
> Date: Fri, 1 Oct 2010 21:08:46
> To: <chevvairl015@vzw.biackberrv.net>
> Subject: Re:
>
> I picked the boys up at 5. You sent them with no clothes. You picked up
> Tyler took him home to get clothes. Brought him back to my house. Yet
> hunter still didn't get any clothes. How is he going to go to school in the
> food stained clothes. What info are you talking about. Ill get you any
> info you want just ask. What game are you playing now.
> On Oct 1, 2010 4:42 PM, <chevvqirlQ15@vzw.blackberry.net> wrote:
chevygirl015@vzw.blackberry.net <chevygirl015@vzw.b!ackberry.net>
Fri, Oct 1, 2010 at 9:50

PM
Reply-To: chevygirl015@vzw.blackberry.net
To: ASSHOLE <outlaw0015@gmai!.com>
I'm done. You didn't give me the info.
I did not and still don't want this divorce. This is 100% your doing. Not mine. You are the one insisting to ruin
our family. You brought that trash into our kids lives. How disgusting.
Im better off without you now. I'm going to church. I'm accepting my faults as well as my goods. My man is
wonderful. He is Marvelous. Excellent job. Well respected in the community. His kids are super. Great cook.
httDs://mail.oode.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search=inbox&th=12b69...
10/14/20)0
X3 B4 V
1 / S Z011
8884b
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> Original M es sa g e
> From- jason shiDman <o u tla w 0 0 1 5 @ a m a il.c o m >
c h e v y g ir l0 l5 @ v z w .b la c k b e r r y .n e t < c h e v y g irl0 1 5 @ v z w .b la c k b e rry .n e t>

R epiy-To: chevygirlOl 5 @ vzw .b lackb erry.net
To: A S S H O L E <out!a w 0 0 1 5 @ g m a il.c o m >
\
F ri, O c t 1 ,2 0 1 0 a t 1 0 :4 6 P M
You checked on Troy. W h a t is h er last nam e?

F ro m : jason shiom an <o u tla w 0 0 1 5 @ a m a it.c o m >
D ate: Fri, 1 O ct 2 0 1 0 2 2 :3 7 :4 3 -0 7 0 0
IQuotod text hidden]
ja s o n s h ip m a n < o u tia w 0 0 1 5 @ g m a il.c o m >

To: chevyg irl015@ vzw .b lackberry.n et
F ri, O c t 1 ,2 0 1 0 a t 1 0 :4 8 P M
I didn't or have no reason to check on Troy . Dont know his last nam e. Let help you need medication. If this
Guy w h o m you haven't told me his n am e is so special why r u being like this. Y o u r going to look up my
girlfriend through your FBI boyfriend. D o you forget who I w ork with. T h a t is abuse of his work. If he is a
normal person he wouldn't get cought up in your dram a. G oodnight Jennifer.
On O c t 1, 2 0 1 0 10:38 PM , <chevvQ irl015@ vzw .blackberrv.net> wrote:
c h e v y g irl0 l5 @ v z w .b la c k b e rry .n e t < c h e v y g irl0 1 5 @ v z w .b la c k b e rry .n e t>

R eply-To: chevygirlOl 5@ vzw .b lackb erry.net
To: A S S H O L E < o u tlaw 0015@ g m ait.co m >
S a t, O c t 2, 2 0 1 0 a t 1 :1 7 A M
Fuck you
F ro m : jason shiDman < o u tia w 0 0 1 5 0 a m a il.c o m >
D ate: Fri, 1 O ct 2 01 0 2 2 :4 8 :3 4 -0 7 0 0
T o : < n h e w a ir!0 15 @ vzw .b lackb errv.net>
S u b je c t: Re:
httDS://mail-google.com/mail/?ui=2&ik=8bfal 3 ada4&view=pt&search=inbox&th=12b69:.'.
1 0 /1 4 /2 0 1 0
fiu . 1
O
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G O

FOR KITTITAS COUNTY
6
7
8
STATE OF WASHINGTON,
Plaintiff,
vs.
10
MOTION AND DECLARATION FOR

ORDER OF APPOINTMENT OF
EXPERT SERVICES RE: MARLENE
GOODMAN, INVESTIGATOR
MELISSA HART,
11
No.: 10-L00121-1
Defendant.
12
13
14
15
16
.17
18
COMES NOW C.K. Powers, Attorney for Defendant, MELISSA HART, and moves the
court for an order appointing the expert services of Marlene Goodman, Investigator, to
investigate and to interview and evaluate parties and witnesses in order to assist in preparing
Defendants defense. This motion is based upon the record and files herein and the declaration
of C,K. Powers, Attorney for the Defendant, subjoined below.
19
20
DATED this
day of July, 2010 at Ellensburg, WA.
21
22
C.K. Powers, WSBA #6705

Attorney for Defendant
23
24
Motion for Appt of Expert

Page 1 o f 2
Law Office of C.K. Powers, P.S.

WSBA# 6705
707 North Pearl St., Suite A
Ellensburg, Wa. 98926
P l i n n o 5 A 0 _ Q - 7 ? i n / ! 7 n ^ CAO A l l - n i l
T 3 rt
1
2
DECLARATION
3
4
C.K. Powers declares as follows:
1.
lam the attorney of record for the above named Defendant in this matter.
2.
Based upon the discovery provided by the State, Defendant is in need of expert
investigator to interview and evaluate parties and witnesses in order to assist in
preparing his case.
3.
Marlene Goodman, Investigator, is available to provide his services in this case.
10
4.
The Defendant believes that these interviews and evaluations and investigative
services are necessary in providing additional information that will be beneficial
11
to preparing his case.
12
13
5.
testimony of the States witnesses.
14
15
16
Investigator testimony at the hearings and at Trial may be required to rebuttal
6.
The Defendant requests a minimum amount of fifteen (15) hours at $60.00 per
hour for a total of $900.00 for the services of Marlene Goodman for this case.
17
18
19

STATE OF WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
20
21
DATED this dis? day of July, 2010 at Ellensburg, WA.
22
23
24
25
Motion for Appt of Expert
Page 2 of 2
Law Office of C.K. Powers, P.S.

WSBA# 6705
Phftiip
cn o oM
1.3a 47-, b / i ? ^ 2 *51 i
130843
FILED
JUL 2 6 2010
JOYGELJULSRUD,CLERK
KITTITASCOUNTYWASHMSTON
/

FOR KITTITAS COUNTY
7 .
8
9
10
11
Plaintiff,
No.: 10-1-00121-1
ORDER APPOINTING EXPERT
SERVICES AND DIRECTING
PAYMENT THEREOF
VS.
MELISSA HART,
Defendant.
12
13
14
ORDER
15
THIS COURT having examined the declaration of counsel for the Defendant and upon
16
the motion of Defendant herein for an order appointing Marlene Goodman, an Investigator, as
17
expert in this case now, therefore;

18
IT IS HEREBY ORDERED, that Marlene Goodman is hereby appointed to perform

19
expert services for the Defendant in the amount not to exceed $900.00, upon completion of
20
services and presentation of itemized invoice.

21
22
DATED this
day of July, 2010.
23
SCOTT R. SPARKS
24
JUDGE
25
Order Appt Expert Services

Page 1 of 2
Law Office of C.K. Powers, P.S..

WSBA# 6705
4 n Q _ < m _ 7 7 1 n /F flT
4 n Q _ < m _ 7 ? 1 1
1384?
6/1722011
Bi1&5B
1
2
PRESENTED BY:
4
5

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Order Appt Expert Services
Page 2 o f2
Law Office of C.K, Powers, P.S.

WSBA# 6705
707 North Pearl St, Suite A
Phone 509-933-7210/Fax 509-933-7211
13847
871 yY Z 611
J306bl
STATE OF WASHINGTON County ol Kitfitasss.
n
'
w ny
' HI: j fi
.fi n' f
r. f CL[{7K

County of
State of W ashington, Plaintiff,
No. 10-1-00121-1
V5.
Felony Judgment and Sentence Jail One Year or Lees
(fjs)
MELISSA J. HART,
Defendant.
10- 9
0 0 7 9 3- 6
[ ] Clerk's Action Required, 2.1, 4.1, 4.3, 5.2, 5.3,

5.5, 5.7
[ ] Defendant Used Motor Vehicle
SID;
DOB; 04-27-77
I. Hearing
1,1 The court conducted a sentencing hearing this date; the defendant, the defendant's lawyer, and the (deputy) prosecuting
attorney were present.
!L Findings
2.1 Current Offenses: The defendant is guilty of the following offenses, based upon
[Xj guilty plea (dale) 11-19-2010 ) jury-verdict (date) ___________ [ \ bench trial (date):
Count
C rim e
RCW
C la s s
(Wsi/6sec/onJ
i
BURGLARY IN THE SECOND DECREE
9A. 52.030
FB
D a te o f
C rim e
04-20-10
C!;iss: FA (Felony-A). FB (Felony-B), FC (Fclony-C),
(If die crime is a drug offense, include the type of drug in the second column.)
[ | Additional current offenses are attached in Appendix 2.1a.
The jury returned a special verdict or the court made a special Gilding with regard to the following:
[ J The defendant used a firearm in the commission of the offense in Count______________. RCW 9.94A.602,
9.94A.533.
[ j The defendant used a deadly weapon other than a firearm in committing the ofTense in Count________
__ ____________________ . RCW 9.94A.602, 9.94A.533.
I ) Count________________is a criminal street gang-related felony offense in which the defendant compensated,
threatened, or solicited a minor in order to involve that minor in the commission of the offense. RCW 9.94A.833.
[ J Count________
is the crime of unlawful possession of a firearm and the defendant was a criminal street gang
member or associate when the defendant committed the crime. RCW 9.94A.702, 9.94A.
[ ] The defendant has a chemical dependency that has contributed to the offensefs). RCW 9.94A.607.
[ j The crime(s) charged in Count_____________ _______ involve(s) domestic violence. RCW 10.99.020.
[) Count________ is a felony in the commission of which the defendant used a motor vehicle. RCW46.20.285.
1384?
b/17^ 28i4
088S2
[ i Counts____________;_____ encompass the same criminal conduct and count as one crime in determining the offender
score (RCW 9.94A.5S9).
[ ] Other current convictions listed under different cause numbers used in calculating the offender score are (list
offense and cause n u m b e r):_____ _____________________________ _______________ ____ ____________
Cause Num ber
Crime
Court (C ounty A State)
1.
2.
( J Additional current convictions listed under different cause numbers used in calculating the offender score are attached in
Appendix 2.1b.
2.2 Criminal History:

Crim e
Date o f
Crim e
Date o f
Sentence
Sentencing Court
(C ounty A State)
A or J
Adult,
Juv.
Type o f
Crim e
3
4
5
[ ] Additional criminal history is attached in Appendix 2.2.
[ J The defendant committed a current offense while on community placement/community custody (adds one point to score).
RCW 9.94A.525.
[ j The prior convictions listed as numbers___________above, or in appendix 2.2, are one offense for purposes of
determining the offender score (RCW 9.94A.525).
a a a 4 v ^ a/. i v / 2 a u
2.3 Sentencing Data:

Count
Wo.
I
Offender
Score
Serious-
Standard
nose
Range (not
Level
0
nt
Plus
Enhancements*
Total Standard
Range (in c lu d in g
Maximum
Term
enhancements)
in c lu d in g
enhancements)
1 - 3 inos.
1 - 3 mos.
10 years
(F) Firearm f (D) Other deadly weapons, (CSG) criminal street gang involving minor.
[ ] Additional current offense sentencing data is attached in Appendix 2.3.
2.4 [J Exceptional Sentence. The court finds substantial and compelling reasons that justify an exceptional
sentence:
[ ] below the standard range for Count(s) _____________ .
[ ] above the stahdurd range for Count(s)______________ .
[ ] The defendant and state stipulate that justice is best served by imposition of the exceptional sentence above the
standard range and the court finds the exceptional sentence litrthers and is consistent with the interests of
justice and the purposes of the sentencing reform act.
[ J Aggravating factors were [ ] stipulated by the defendant, [ ] found by the court after the defendant waived jury
trial. (] found by jury, by special interrogatory.
[ ] within the standard range for Count(s)_________, but served consecutively to C o u n ts)____________.
Findings of fact and conclusions of law are attached in Appendix 2.4. [ ] Jurys special interrogatory is attached.
The Prosecuting Attorney [ ] did [ ] did not recommend a similar sentence.
2.5 Ability to pay Legal Financial Obligations,
rhe court has considered the total amount owing, the

defendant's past, present, and future ability to pay legal financial obligations, including the defendants financial
resources and the likelihood that the defendants status will change. The court finds that:
[ ] The defendant has the ability or likely future ability to pay the legal financial obligations imposed herein, RCW
9.94A.753,
[ ] The following extraordinary circumstances exist that make restitution inappropriate (RCNV 9.94A.753):
[ ] The defendant has the present means to pay costs of incarceration. RCW 9.94A.760.
111. Judgment
3.1
The defendant is g u ilty of the Counts and Charges fisted in Paragraph 2.1 and Appendix 2. L
3.2
^ T h e court dismisses Count 2_in the charging document
IV. Sentence and Order
It is ordered:
4.1 Confinement.
(a)
The court sentences the defendant as follows:
C o n fin e m e n t^ RC^9.94A.539, A term of totul1confinement in the custody of the county jail:
rnonthC on Count l
____________ months on Count________
..months on Count
^months on Count
months on Count
months on Count
J
aAf>
Actual number of manias of total confinement ordered is:
a -A
*Y >
ias4
?y28 i i
seas4
All counts shall be served concurrently, except for the following which shall be served consecutively.
The sentence herein shall run consecutively with the sentence in cause number(s)
but concurrently to any other felony cause not referred to in this Judgment, RCW 9.94A.589.
Confinement shall commence immediately unless otherwise set forth here:_______________________ ___
______ / &
_________________________________________________
M^Partial Confinement The defendant may serve die sentence, if eligible and approved, in purtial confinement
*ln the foiluwing programs, subject to the following conditions:_______________^
_____________ /W
jKJ-work crew RCW4.94A.725
[ ] work release RCW 9.94A.731
[ j home detention RCW 9.94A.731,. 190
| | Conversion of JaU Confinement (Nonviolent and Nonsex Offenses). RCW 9.94A.680(3). The county jail
is authorized to convert jail confinement to an available county supervised community option, to reduce the time
spent in the community option by earned release credit consistent with local correctional facility standards, and may
require the offender to perform affirmative conduct pursuant to RCW 9.94A.
[ J The defendant shall receive credit for time served in an available county supervised community option prior
to sentencing. The jail shall compute rime served.
[ J Alternative Conversion. RCW 9.94A.680, _______________ days of total confinement ordered above are
hereby converted to _______
hours o f community restitution (service) (8 hours = 1 day. nonviolent
offenders only. 30 days maximum) under the supervision of the Department of Corrections (DOC) to be completed
on a schedule established by the defendant's community corrections officer but not less than ___________
hours
per month.
[ | Alternatives to total confinement were not used because of: _____________________________ _
[ ] criminal history [ ] failure to appear (finding required for nonviolent offenders only) RCW 9.94A.680.
(b)
Credit for Time Served: The defendant shall receive credit for time served prior to sentencing if that confinement
was solely under this cause number. RCW 9.94 A.505. The jail shall compute time served.
4.2 Community Custody. RCW 9.94A.505, .702.

(A) The defendant shall serve____ _____ ______________months (up to 12 months) in community custody.
The court may order community custody under the jurisdiction of DOC for up to 12 months if the defendant is convicted
of a violent offense, a crime against a person under RCW 9.94A.411, or felony violation of chapter 69,50 or 69.52
RCW or an attempt, conspiracy or solicitation to commit such a crime. For offenses committed on or after June 7, 2006,
the court shall impose a term of community custody under RCW 9.94 A.701 if the offender is guilty of failure to register
(second or subsequent offense) under RCW 9A.44.130(11 )(a) and for offenses after June 12, 2008 for unlawful
possession of a firearm with a finding that the defendant was a member or associate of a criminal street gang. The
defendant shall report to DOC not later than 72 hours after release from custody at the address provided in open court or
by separate document.
(B) While on community custody, the defendant shall: (l) report to and be available for contact with the assigned
community corrections officer as directed; (2) work at DOC-approved education, employment and/or community
restitution (service); (3) notify DOC of any change in defendant's address or employment; (4) not consume controlled
substances except pursuant to lawfully issued prescriptions; (5) not unlawfully possess controlled substances while on
community custody, (6) not own. use, or possess firearms or ammunition;
(7) pay supervision fees as determined by DOC; (8) perform affirmative acts as required by DOC to confirm compliance
with the orders of the court; and (9) abide by any additional conditions imposed by DOC under RCW 9.94A.7Q4 and
.706. The defendants residence location and living arrangements arc subject to the prior approval of DOC while on
community custody.
13184 V
11
BB9bb
The court orders Uiat during the period of supevision the defendant shall;
l ] consume no alcohol.
t | have no contact with:_______________________________________________ __________________
f ] remain [ J within [ j outside of a specified geographical boundary, to wit:
[ | participate in the following crime-related treatment or counseling services:
f J undergo an evaluation for, and fully comply with, treatment for {] domestic violence [ J substance abuse
[ ] mental health [ ] anger management.
[ ] comply with the following crime-related prohibitions:_____________ ___________________________
[ ] Other conditions;
(C) The conditions of community custody shall begin immediately upon release from confinement unless otherwise set
forth here:___________________ ___________________________
Court Ordered Treatment: If any court orders mental health or chemical depenency treatment, the defendant must notify
DOC and the defendant must release treatment information to DOC for the duration of incarceration and supervision.
RCW9.94A.562.
4.3 Legal Financial Obligations: The defendant shall pay to the clerk of this court:
JASS CODE
FCV
PDV
CRC
pun
500
Victim assessment
RCW 7.68.035
Domestic Violence assessment
RCW 10.99.080
2QQ
Court costs, including RCW 9.94A.760, 9.94/V505, 10.01. 160, 10,46.190
600
Criminal filing fee 5

_ FRC
Witness costs
S
WFR
Sheriff service fees S
SFR'SFS/SFW/WRF
Jury demand fee
$
JFR
Extradition costs S
EXT
Other
$ .
RCW 9.94A.760
Fees for court appointed attorney
Drug enforcement fund of
Court appointed defense expert and other defense costs
DUI fines, fees and assessments
CLP
Crime lab fee f 1 suspended due to indigency
RCW 43.43.690
ONI
DNA collection fee
RCW 43.43.7541
FPV
Specialized forest products
RCW 76.48.140
Other fines or costs for.
. 'U U / F C W
Kittitas County
RCW 9.94 A. 7 60
c d f
S IF -S A D /S D I
WFR
100
RCW 9.94A.760
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S____________ emergency response costs (Vehicular Assault, Vehicular Homicide, Felony DUI only,
$1000 maximum)
RCW J8.52.430
Agency:____ ________________________________________
$ 500________ Restitution to: Seth Grove, 5290 Nelson Siding Rd.. Cle Elum. WA 98922
RTN/RJN
$ 1.250
T&P>
& W-H81.
Restitution to: Straight Arrow NW. PO Box 590. North Bend. WA 98045
Restitution to: Straight Arrow NW. PO Box 590. North Pend. WA 98045
(Name and Address--address may be withheld and provided confidentially
to Clerk of the Courts office.)
Total
KCW9.94A.760
jp^The above total does not include all restitution or other legal financial obligations, which may be set by later order
of the court. An agreed restitution order may be entered. RCW 9.94A.753. A restitution hearing;
j^shail be set by the prosecutor.
f 1 is scheduled for____________________________________________________________ _(date).
[ ] The defendant waives any right to be present at any restitution hearing (sign initials):_____ _______.
( j Restitution Schedule attached.
[ ] Restitution ordered above shall be paid jointly and severally with:
Name of other defendant
C au se Number
(Victims name)
RJN
(Amount-S)
_____ __________________ __________________________
( ] The Department of Corrections (DOC) or clerk of the court shall immediately issue a Notice of Payroll Deduction.
RCW 9.94A.7602, RCW 9.94A.760(8).
j 1All payments shall be made in accordance with the policies of the clerk of the court and on a schedule established by
DOC or the clerk of the court, commencing immediately, unless the court specifically sets forth the rate here: Not
less than $_______ per month commencing______________ _______________ . RCW 9.94A.760.
The defendant shall report to the clerk of the court or as directed by the clerk of the court to provide financial and other
information as requested. RCW 9.94A.760(7)(b).
[ ] The court orders the defendant to pay costs of incarceration at the rate of $__________ per day, (actual costs not to
exceeds 100 per day). (JLR) RCW 9.94 A.760.
The financial obligations imposed in this judgment shall bear interest from the date of the judgment until payment in
full, at the rate applicable to civil judgments. RCW 10.82.090. An award of costs on appeal against the defendant may
be added to the total legal financial obligations. RCW 10.73.160.
4 .4
D N A T e s tin g . The defendant shall have a biological sample collected for purposes of DNA identification analysis
and the defendant shall fully cooperate in the testing. The appropriate agency shall be responsible for obtaining the
sample prior to the defendant's release from confinement. RCW 43.43.754.
[ ] HIV Testing. The defendant shall submit to HIV testing. RCW 70.24.340.
:-1 3 a 4 7
6 ^ 1 7 /2 ^ i i
S a^S -/
4.5 No Contact:
[ ] The defendant shall not have contact with--------------------------------------------------------- -- ----------------__________ _________________ (name) including, but not limited to,
personal' veTbal, telephonic, wri(ten or contact through a third party until__________ _____ _ (which does not
exceed (lie maximum statutory sentence).
[ ] The defendant is excluded or prohibited from coming within ___________________ __ (distance) of:
[j
,
__________ __________
____ (name of protected person(s))'s [} home:/ residence [
] work place [ ] school f ] (other location(s)).......... .......................................................................
__________________ __________________ _ _________________________________________ , or
[ ] oilier location______________________ _______________________________________________ __.
until__________ ____ _______ (which does not exceed the maximum statutory sentence).
[ ] A separate Domestic Violence No-Contact Order or Antiharassment No-Contact Order is Hied concurrent with this
Judgment and Sentence.
4.6 Other:
4.7 Off-Limits Order. (Known drug trafficker). RCW 10.66.020. The following areas are off limits to the defendant
while under the supervision of the county jail or Department of Corrections:
__________
V. Notices and Signatures

5.1 Collateral Attack on Judgment. If you wish to petition or move for collateral attack on this Judgment and
Sentence, including but not limited to any personal restraint petition, state habeas corpus petition, motion to vacate
judgment, motion to withdraw guilty plea, motion for new trial or motion to arrest judgment, you must do so within one
year of the final judgment in this matter, except as provided for in RCW 10.73.100.
RCW 10.73.090.
5.2 Length of Supervision. If you committed your offense prior to July 1, 2000, you shall remain under the court's
jurisdiction and the supervision of the Department of Corrections for a period up to 10 years from the date of sentence or
release from confinement, whichever is longer, to assure payment of all legal financial obligations unless the court
extends the criminal judgment an additional 10 years. If you committed your offense on or after July 1, 2000, the court
shall retain jurisdiction over you, for the purpose of your compliance with payment of the legal financial obligations,
until you have completely satisfied your obligation, regardless of the statutory maximum for the crime. RCW 9.94 A. 760
and RCW 9.94A.505(5). The clerk of the court has authority to collect unpaid legal financial obligations at any time
white you remain under the jurisdiction of the court for purposes of your legal financial obligations. RCW
9,94A.760(4) and RCW 9.94A.753{4).
5.3 Notice of Income-Withholding Action. If the court has not ordered an immediate notice of payroll deduction
in Section 4.1, you are notified that the Department of Corrections (DOC) or the clerk of the court may issue a notice of
payroll deduction without notice to you i f you ore more than 30 days past due in monthly payments in aa amount equal
to or greater than the amount payable for one month. RCW 9.94A.7602. Other income-withholding action under RCW
9.94A.760 may he taken without further notice. RCW 9.94A.7606.
5.4 Community Custody Violation,

(a) If you are subject to a first or second violation hearing and DOC finds that you committed the violation, you may
receive as a sanction up to 60 days of confinement per violation. RCW 9.94A.634,
(b) If you have not completed your maximum term of total confinement and you arc subject to a third violation hearing and
DOC finds that you committed the violation, IXX.' may return you to a state correctional facility to serve up to the
remaining portion of your sentence. RCW 9.94A.714.
i 38 47
8 /1 7 /2 8 1 1
88858
5.5 Firearms. You may liot own, use or possess any firearm unless your right to do so is restored by a superior
court in Washington State, and by a federal court if required. You must immediately surrender any concealed
pistol license. (The clerk of the court shall forward a copy of the defendant's driver's license, identicard, or comparable
identification to the Department of Licensing along with the date of conviction or commitment.) RCW 9.41.040,
9.41.047.
FIREARM RIGHTS STATEMENT: RCW 9.41.040. I acknowledge that my right to own, use or possess any firearm
has been lost due to felony conviction, or crimes involving domestic violence. My right to own, use, or possess a
firearm may only be restored by a court of record. I acknowledge that I must immediately surrender any concealed pistol
license. Owning, using,possessing a firearm before the right u restored is a class C felony, RCW 9.41.040.
Defendants signature
5.6 Reserved.
5.7 Motor Vehicle: If the court found that you used a motor vehicle in the commission of the offense, then the Department
of Licensing will revoke your drivers license. The clerk of the court is directed to immediately forward an Abstract of
Court Record to the Department of Licensing, which must revoke your drivers license. RCW 46.20.285.
5.8 Other:___________________________________________________________________ .
S.y [X] BOND IS HEREBY EXONERATED. Kittitas County Clerk is hereby authorized to repay cash bail to the payor
thereof or his/her designee.
Candace Hooper
C. K. Powers
Melissa J. Hart
Voting! Rights Statement: [ acknowledge that 1have lost my right to vote because of this felony conviction. If I am
registered to vote, my voter registration will be cancelled.
My right to vote is provisionally restored as long as I am not under the authority of DOC (not serving a sentence of
confinement in the custody of DOC and not subject to community custody as defined in RCW 9.94A.Q30). I must re-register
before voting. The provisional right to vote may be revoked if I fail to comply with all the terms of my legal financial
obligations or an agreement for the payment of legal financial obligations.
My right to vote may be permanently restored by one of the following for each felony conviction: a) a certificate of discharge
issued by the sentencing court, RCW 9.94A.637; b) a court order issued by the sentencing court restoring the right, RCW
9.92.066: c) a final order of discharge issued by the indeterminate sentence review board, RCW 9.96.050; or d) a certificate of
restoration issued by the governor, RCW 9.96.020. Voting before the right is restored is a class C felony, RCW 29A.84.660.
Registering to vote befonythe right is restored is a class C felony, RQtf 29A.84.140.
Defendants signature:
I am a certified interpreter of, or the court has found me otherwise qualified to interpret, the_____________
____ _______ ______ _______ language, which the defendant understands. I translated this Judgment and
Sentence for the defendant into that language.
Interpreter signature/Prinl name:
-G s n s z B 'il 0a8S3.
VI. Identification of the Defendant

SID No.
_______
_________________________Date of Birth
(If no SID complete a separate Applicant card

(form FD-258) for Slate Patrol)
FBI No.
Local ID No.
PCN No.
Other
Alias name, DOB:

Race:
[ ] Asian/Pacific Islander
[ ] Black/African-American
\ ] Caucasian
[ ] Native American
[ ] Other:________________________
Ethnicity:
Sex:
[ ] Hispanic
;V ['j Male
[ ] Non-Hispanic
LI female
Fingerprints: 1attest that I saw die defendant who appeared in court affix his or her fingerprints andsignaturc on
this document
a |
Clerk of the Court, Deputy Clerk, ^

Dated:_1
~
O
r
The defendants signature:
f V if | \
Left four lingers taken simultaneously
Left
Thumb
K __ ___ ___________ _
Right four fingers taken simultaneously

Thurnb
1384V
08B&H

KITTITAS COUNTY
No. 10-1-0(1121-1
STATE OF WASHING TON,

Plaintiff...............
VS.
MELISSA J. HART
JUDGMENT AND SENTENCE

(APPENDIX 4.6)
Defendant,
Defendant shall report to the Department of Corrections at 1109 Industrial Way, Ellensburg, Washington, within 72
hours of the commencement of community supervision.
[X]
to
Defendant shall maintain law abiding behavior.
[X] (2)
Defendant shall not associate with codefendant(s) or anyone on active supervision without
permission of his/her supervising Community Corrections Officer.
EX]
(3)
Defendant shall not change his/lver place of residence without first obtaining permission of his/her
Supervising Community Corrections Officer.
1X1
(4)
Defendant shall maintain full-time employment, if unemployed, defendant shall actively seek full
time employment and report weekly to the superv ising Community Corrections Officer until full-time
employment is found. Defendant shall not terminate or change employment without prior approval
from the supervising Community Corrections Officer, Employment can include educational and
training programs.
[ ]
(5)
Defendant shall obtain a substance abuse evaluation through a qualified, certified substance abuse
evaluatiun/treatment agency. Defendant shall enter Into; make reasonable progress in; and
successfully complete any recommended inpatient or outpatient treatment programs resulting from
this evaluation, including any additional recommendations and/or program changes made by
treatment staff during the course of treatment. Defendant shall not terminate treatment without prior
written authority of the program officials in conjunction with the approval of the supervising
Community Corrections Officer. Defendant must follow all rules, regulations, and requirements of
tlic treatment providerfs).
j j
(6)
Defendant will not purchase, possess, or consume any dangerous drugs, narcotics, or controlled
substances without a valid prescription from a licensed physician. Defendant must provide
verification of all prescriptions to the supervising Community Corrections Officer within 72 hours of
receipt.
[ ]
(7)
Defendant shall not associate with persons involved in the use, sales and;or possession of dangerous
drugs, narcotics or controlled substances.
[ ]
(8)
Defendant shall not enter into or remain in areas where dangerous drugs, narcotics, or controlled
substances are being sold/purchascd, possessed, and/or consumed.
] (9)
Defendant shall not purchase, possess, and/or consume any intoxicating liquors.
j (10)
Defendant shall not enter into or remain in establishments where alcohol is the main source of
revenue. This does not include a restaurant which is attached to but separate from a bar/Iounge area.
] (11)
Defendant shall submit to testing of his/her blood, urine, and/or breath as directed by the supervising
Community Corrections Officer to monitor compliance with drug and/or alcohol conditions of
supervision. This testing shall be at the defendants own expense.
1384?
[ I
02)
6 < i ? > 2 e 11
ts ts 8 fa f ;
Defendant shall obtain a batterers treaunent/anger management evaluation. Defendant shall enter
into, make reasonable progress in, and successfully complete any program of treatment
recommended as a result of this evaluation, including any additional recommendations and/or
program chunges made by treatment stall during the course of treatment. Defendant shall not
terminate treatment without prior written authority of the program officials and in conjunction with
the approval of the supervising Community Corrections Officer.
[ 1 03)
Defendant shall undergo a complete psychiatric evaluation by a licensed psychiatrist or psychologist.

Defendant shall enter into and make reasonable progress in any program of treatment recommended
as a result of this evaluation, including any additional recommendations and/or program changes
made by the treatment staff during the course of treatment Defendant sliall not terminate treatment
without prior written authority of program officials and in conjunction with the approval of the
supervising Community Corrections officer.
l 1 (14>
Defendant shall have no direct and'or indirect contact with..............................................................
(15)
Defendant shall obtain a sexual devtariey evaluation from a certified sexual deviancy treatment
provider. Defendant shall enter into, make reasonable progress in and successfully complete any
program of treatment recommended as a result of this evaluation, including any additional
recommendations und/or program changes made by the treatment staff during the course of
treatment. Defendant shall not terminate treatment or change treatment providers without prior
written authorization from the court. Defendant must follow alt rules, regulations, and requirements
of die treatment provider.
l 1 (16)
Defendant shall have no direct and/or indirect contact with minors under the age of 18, without the
prior approval of the treatment provider and the supervising Community Corrections Officer.
( I
07)
Defendant shall not frequent areas where minors are known to congregate including but not limited
to schools, parks, playgrounds, arcades, and swHmming pools.
[ ]
08)
Defendant is not to purchase, possess, or use pornographic material. Pornographic material will be
defined by the treatment provider, the supervising Community Corrections Officer, and the Court.
l 1
O )
Other:__________________________________________________________
13847
b /i? /2 8 ii
88862 -
a p p e n d ix _________
Payment of Legal Financial Obligations

Defendant's compliance with the legal financial obligations ordered herein shall be monitored by the Kittitas County
Collections Deputy Clerk and/or Restitution Specialist. Defendant is required to make n minimum monthly payment
of S100 each calendar month, unless other arrangements are made with the Kittitas County Clerk's Office.
Defendants first payment shall be due 30 days from the date of the Judgment and Sentence was signed in court. If
the defendant fails to make such payment, Defendant shall be sent a summons requiring them to appear at an
Administrative Hearing on an assigned date.
Defendant shall make his/her payment within seven days of the due date thereafter until said legal financial
obligation is paid in full. If the Defendant is unable to pay within seven days of the due dale, or is unable to pay the
full amount, contact with the Kittitas County Collections Deputy Clerk or Restitution specialist is required so other
arrangements can be made.
If Defendant has not made the minimum payment in the preceding calendar month, does not appear at the scheduled
Administrative Hearing and does not contact the Collections Deputy Clerk or Restitution Specialist, he/she shall be
determined to be delinquent with their account and shall be required to appear for a scheduled Show Cause Hearing.
If Defendant does not appear for said hearing, a warrant shall be issued, without further notice to the defendant.
Payments shall be made in person or by mail (cashiers check or money order) to the Kittitas County Superior Court
Clerk, 205 W. 5* Ave Room 210, Ellensburg, WA 98926.
A collection fee of SI 00 will be assessed if the Defendant falls one month past due on his/her legal financial
obligation and/or an order to show cause is entered.
The Defendant must notify the Clerk of the Court within 48 hours of any change in address of employment
status as long as there are legal financial obligations owing.
Felony Judgment and Sentence (FJS) (Jail One Year or Less)

(RCW 9,94A.500, ,505)(WPF CR 84.0400 (7/2009))
Page 12 of 12
3 H 4 V 16/1-7/2-811 0 8 8 6 3
IN THE SUPERIOR COURT OF WASHING ! ON

KITTITAS COUNTY
STATE OF WASHING TON,
Cause No.
Plaintiff.
vs.
ORDER ON SENTENCING
WORK CREW ADDENDUM
TO JUDGEM ENT AND SENTENCE
DOB;
Defendant.
APPENDIX A.5
THIS MATTER HAVING COME ON for a sentencing hearing before the undersigned judge o f the above
entitled Court, it is hereby
ORDERED THAT the defendant shall serve
__days o f this confinement sentence on the
Washington State Department o f Corrections Work Crew (one day of Work Crew equals one day o f confinement)
$4-beginiiing on
-fr*,
/a ,
z*> s < 3
[ | to be completed b y ____________________ ____________ .

[ | as directed by die Department of Corrections.
[ ] as directed by the Kiuitas County Probation Department.
Defendant shall follow all rules and regulations o f the Work Crew. Failure to com ply or failure to
complete Work Crew as directed shall result in defendants arrest and return to the Kittitas County
Correction a! Facility to serve the entire term of confinement ordered. When notified o f defendants failure tn
comply or failure to appear, the monitoring agency is authorized to effect defendant's arrest and return to custody
with the assistance oflaw enforcement if necessary. Defendant shall only receive credit for time served on the work
crew upon successful completion of entire work crew sentence.
IT IS FURTHER ORDERED THAT:
[ resented by .
i ic p u iv IV u s e c .u iin g A tto r n e y . W S B A f#
Appro1,cl!u .- Im [ oiiii h
IF.IKNTYr; TO D F F E S D A S T : YOUR FAII.URF.

TO REPORT FOR OR REMAIN IN WORK
CREW AS DIRECTED MAY RESULT IN
YOUR BEING CHARGED W ITH FIRST
DEGREE ESCAPE.
1364?
6 /1 7 /2 8 1 i
188863
L a w O ffic e o f C.K. P o w e rs , P.S.

707 North Pearl Street, Suite A
Ellensburg, WA. 98926
Tel (509) 933-7210/ Fax (509) 933-7211
July 27,2010
Melissa Hart
109 West 4th
Cle Elum, WA. 98922
Re: 10-1-00121-1
Dear Ms. Hart,
As you know, Ms. C.K. Powers has been appointed to represent you in the case listed
above. Enclosed please find your copies of the following documents:
Motion and Declaration for Order of Appointment of Expert Services
Order Appointing Expert Services
The special investigators name is Marlene Goodman and she will be in contact with you.
Please cooperate with her fully as she was hired to assist in your defense.
As part of the co u rt-a p p o in ted a tto rn e y program* yo u are req u ire d to m a in ta in
weekly contact with our office. If you do not stay in weekly contact with our office
then the Judge will be notified.
Should you have any questions or concerns, please do not hesitate to contact our office.
Sincerely,
Legal Assistant to
C.K. Powers
Enclosures
'1 3 8 4 ?
& /'!? '2a i l
8806S
CiX
C D
CO
C IO

KITTITAS COUNTY
6
7
NO. 10-1-00121-1
Plaintiff,
9
10
11

ORDER AMENDING THE ORDER
ON SENTENCING ON THE FELONY
JUDGMENT AND SENTENCE
vs.
MELISSA HART,
Defendant
12
COMES NOW C.K. POWERS Attorney for the Defendant, and moves the Court for an order
13
Amending the Order on Sentencing on the Felony Judgment and Sentence for the above named
14
defendant. This date on the Judgment and Sentence that was entered on November 19,2010.
15
This motion is based upon the record and files herein and the declaration of C.K. Powers,
16
Attorney for the Defendant, subjoined below.

17
18
19
20
DATED this
of December, 2010.
21
Law Office of C. K. Powers P.S.
22
23
24
C. K. Powers WSBA No. 6705

Attorney for the Defendant
25
Law Office o f C.K. Powers, P.S.

Motion for Order Amending Order on Sentencing
Page 1 of 2
W.S.B.A. #6705
707 N. Pearl, Ste A
130 4 /
b / j . 7 'S z n i . X i i H 8 U &
DECLARATION
C.K. Powers declares as follow s:
1.
I am the attorney o f record for the above named Defendant in this matter.
2.
The defendant was going to com plete her sentence by doing work crew in Pierce
County. Pierce County only allow s people to do work crew w ho are referred by
their district court. They do not allow felony work crew or out o f tow n persons.
3.
The defendant in a single Mother who works full tim e. She needs additional tim e
to make arrangements for her son w hile she is incarcerated. She also needs tim e
to make arrangements with her employer.
10
11
12

13
14
DATED this 2
day o f December, 2010 at Ellensburg, WA.
15
16
C.K. Powers, W SBA #6705

17
18
19
20
21
22
23
24
25

Motion for Order Amending Order on Sentencing
Pflpp. 2 n f 2
W.S.B.A. #6705
707 N. Pearl, Ste A
t 7 /Z g l i
B15#b {
DEC 03 2010
Cv
jnflSLMSRUO,ClK
KITTITASCOUNTY,WASHINGTON
2
0

KITTITAS COUNTY
<y>!
6
7
8
NO. 10-1-00121-1
Plaintiff,
AGREED ORDER AMENDING THE

ORDER ON SENTENCING ON THE
FELONY JUDGMENT AND
SENTENCE
vs.
MELISSA HART,
Defendant
10
*Clerks Action Required
11
12
13
The attorney, C.K. Powers, for the Defendant, MELISSA HART, having filed a Motion
14
and Declaration for and an agreed Order Amending the Order on Sentencing on the felony
15
judgment and sentence on December 1, 2010, and the Prosecuting Attorney, agreeing hereto;
-/p
fkri/hAStf
IT IS HEREBY ORDERED that the Order
Sentences^ be amended from December
16
17
10, 2010 to January 3, 20/^. The clerks office is ordered to provide the Kittitas County
18
Corrections Center with the new signed order on sentencing.
19
20
DATED this
day of December, 2010.
21
22
Judge
23
24
25

Agreed Order for Amendment to Order o f Sentencing
Page 1 of 2
W .S .B .A . # 6 7 0 5
7 0 7 N. Pearl, S te A
E lle n sb u rg , W a. 9 8 9 2 6
P h o n o ^ n Q - Q T i^ i n /F a v FnQ-QT?-7"5l 1
6 / 1 ? -2 '8 i .088633
Presented by:
2
3
4

5
6
Agreed to and Approved

Notice of Presentation Waived:
7
8
-9
Candace HoopeT, WSBA # 16325

Deputy Prosecuting Attorney
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
25
Law Office o f C.K. Powers. P.S.

Agreed Order for Amendment to Order o f Sentencing
Page 2 of 2
W.S.B.A. #6705
707 N. Pearl, Ste A
Phone 509-933-777n/Fav
3384 V
S /^
AJ/xH.
/o l
l(
Middle
No. D10-6
4/27/1977
Temporary Order for Protection and

Notice of Hearing (TMORPRT)
{Clerk's Action Required)
11/6/1978
|fl
Next Hearing Date/Time: MAY #,2010 AT 10:30

AM
At: Upper Kittitas County District Court
700 East First Street
Cle Elum, WA 98922
Respondent Identifiers
Names of Minors: EjlNo Minors Involved

First
District Court o f W ash in g to n

For U pper Kittitas C ounty
HART. MELISSA JILL,
Petitioner
vs.
GROVE. SETH LOUIS.
Respondent
88883
J / z & i l
Last
Sex
dob
N/A
Height
Race
U 3
Weight
Hair
Eyes
ftu u _
2 T5
Respondents Distinguishing Features:
C aution:
Access to weapons: yes no D unknown
The Court Finds:

The court has jurisdiction over the parties, the minors, and the subject matter. The respondent will be served notice
of his or her opportunity to be heard at the scheduled hearing. RCW 26.50.070, For good cause shown, the court
finds that an emergency exists and that a Temporary Protection Order should be issued without notice to the
respondent to avoid irreparable harm.
The Court Orders:
__ ______ _______________________ ____
i n . Respondent is Restrained from causing petitioner physical harm, bodily injury, assault, including sexual
assault, and from molesting, harassing, threatening, or stalking ^petitioner CDthe minors named in the
table above G these minors only:
&T2. Respondent is Restrained from coming near and from having any contact whatsoever, in person or
through others, by phone, mail, or any means, directly or indirectly, except for mailing or service of process
of court documents by a 3rd party or contact by respondents lawyers) with [^petitioner G the minors
named in the table above Q these minors only:
Additional no contact provisions are on the next page.
The terms of this order shall be effective until
the end of the hearing, noted above.
Temp Ord for Protection/Nt o f Hrg (TMORPRT) - Page 1 o f 3

WPF DV-2.015 Mandatory (7/2007) - R C W 26.50.030
1 iJ-S 4 /2
hcZ:j 2..-Z
0 & .& / !
J^T 3. Respondent is Restrained from going onto the grounds of or entering petitioner's ^residence
^w orkplace school D the day care or school o fD the minors named in the table above
these minors only:
other:
Petitioner's address is confidential. S f Petitioner waives confidentiality o f the address which is:
IO 9
kJ 'HsCg-
\-e
r(.^ ,/> f
o (/y f
4. Petitioner shall have exclusive right to the residence petitioner and respondent share. The respondent
shall immediately V a c a te the residence. The respondent may take respondent's personal clothing
and respondent's tools o f trade from the residence while a law enforcement officer is present. This
address is confidential. Petitioner waives confidentiality o f this address which is:
J 5 5. Respondent is
Prohibited from knowingly coming within, or knowingly remaining within
O Cj ^ __________ (distance) of: petitioner's-Sjesidence workplace school the day
care or school o f the minors named in the table above these minors only:
other:
6. Petitioner shall have possession of essential personal belongings, including file following:
Q 7. Petitioner is granted use of the following vehicle:

Year, Make & Model________________________________________ License No.,
8.
~
Other.
-.1 f"L- '*:'R
-.- ..;r- - ri'1v,'.I!I)i.'ipj"'lw;(11 j,-jil--t
|ft 1'M J.I''la--(tl}ls'fjj!>
:j-JU,f Iit->Jl, TI-/.^..n.
.Gonipletfefhe'ffiillowmgjdhlydfipffitectidh^ânt^jihvolyihgîmjnor::#,
12. Petitioner is
above
Granted the temporary care, custody, and control
nL't,,-,j-.vij..;:->.j,,j,iu,,,,,
o f the minors named in the table
these minors only:
13. Respondent is Restrained from interfering with petitioner's physical or legal custody of the
minors named in the table above these minors only:
14. Respondent is Restrained from removing from the state the minors named in the table above
these minors only:
The respondent is directed to appear and show cause why this temporary order should not be made effective for
one year or more and why the court should not order the relief requested by the petitioner or other relief which
may include electronic monitoring, payment of costs, and treatment. Failure to Appear at the Hearing
May Result in the Court Granting Such Relief. The Next Hearing Date is Shown on
Page One.
WPF DV-2.015 Mandatory (7/2007) - R C W 26.50.030
Warnings to Respondent: A violation of provisions 1 through 5 of this order with actual notice of its
terms is a criminal offense under chapter 26.50 RCW and w ill subject you to arrest I f the violation of the
protection order involves travel across a state line or the boundary of a tribal jurisdiction, or involves conduct
within the special maritime and territorial jurisdiction of the United States, which includes tribal lands, you may
be subject to criminal prosecution in federal court under 18 U.S.C. 2261,2261A, or 2262.
A violation of provisions 1 through 5 of this order is a gross misdemeanor unless one of the following conditions
appty: Any assault that is a violation of this order and that does not amount to assault in the first degree or second
degree under RCW 9A.36.011 or 9A.36.021 is a class C felony. Any conduct in violation of this order that is
reckless and creates a substantial risk of death or serious physical injury to another person is a class C felony.
Also, a violation of this order is a class C felony if you have at least two previous convictions for violating a
protection order issued under Titles 7, 10, 26 or 74 RCW.
If the court issues a final protection order, and your relationship to the petitioner is that of spouse or former
spouse, parent of a common child, or former or current cohabitant as intimate partner, you may not possess a
firearm or ammunition for as long as that final protection order is in effect 18 U.S.C. 922(g)(8). A violation of
this federal firearms law carries a maximum possible penalty of 10 years in prison and a $250,000 fine. An
exception exists for law enforcement officers and military personnel when carrying department/govemment-issued
firearms. IS U.S.C. 925(a)(1). I f you are convicted of an offense o f domestic violence, you w ill be forbidden
for life from possessing a firearm or ammunition.
18 U.S.C. 922(g)(9); RCW 9.41.040.
You Can Be Arrested Even if the Person or Persons Who Obtained the Order Invite or
Allow You to Violate the Order's Prohibitions. You have the sole responsibility to avoid or refrain
from violating the orders provisions. Only the court can change the order upon written application.
Pursuant to 18 U.S.C. 2265, a court in any of the 50 states, the District of Columbia, Puerto Rico, any United
States territory, and any tribal land within the United States shall accord full faith and credit to the order._______
It is further ordered that the clerk of the court shall forward a copy of this order on or before the next judicial day 1
to
KITCOM
W here P etitio n er Lives which shall enter it in a computer based criminal intelligence system available in this
state used by law enforcement to list outstanding warrants.
D The clerk of the court shall also forward a copy of this order on or before the next judicial day to
KITTITAS COUNTY SHERIFFS DEPARTMENT

Where R espondent Lives which shall personally serve the respondent with a copy o f this order and shall
promptly complete and return to this court proof of service.

petitioner has made private arrangements for service of this order.
Law enforcement shall assist petitioner in obtaining:
Possession of petitioner's D residence CDpersonal belongings located at: CDthe shared residence
CDrespondent's residence D other:______________________________________________
Custody of the above-named minors, including taking physical custody for delivery to petitioner (if
applicable).
D Other:
_________ ________________ __________________________________________ .
Dated
^ ~7j (
at
.nyp.m.
Judge/Ccmmissioner
A Law Enforcement Information Sheet (LEIS)
must be completed.

WPF DV-2.Q15 Mandatory (7/2007) - R C W 26.50.030
1384?
6^17^2811
138872
State of Washington
KITTITAS SHERIFFS OFFICE
Civil Division
Ellensburg, WA 98926
Process Number: S10-00369
Court Number: DIO 6
I, GENE DANA, SHERIFF of KITTITAS SHERIFFS OFFICE do hereby certify that I

received the within and foregoing TEMP ORDER FOR PROTECTION - DV on 27th'day of
April, 2010, and that I served the same o n :
SETH LOUIS GROVE
(Respondent
)
109 HAWTHORNE
EASTON, WA 98925
Served on: 28th day of April, 2010 at 11:30:00
Served to: SETH LOUIS GROVE
by MARX, BERT
231 HAWTHORNE
EASTON, WA 98925
Returned on the 30th day of April, 2010
Service attempted on 28th day of April, 2010 at 11:30:00

Dated the 30th day of April, 2010
Fees;
Service:
Mileage :
OtKer
Total
:
20.00
3.5.00
-55.00
0.00
GENE DANA, SHERIFF

KITTITAS. SHERIFFS OFFICE, Washington
BY:
Authori
Civil D
resentative
13847
04/30/10
10:42
SETH LOUIS GROVE (Respondent)

109 HAWTHORNE
EASTON, WA
Seq Docno
1
2
3
4
Page:
155
1
[ Process Number: S10-00369

[ Court Case No.: D10 6
[ TEMP ORDER FOR PROTECTION - DV
MELISSA JILL HART (Petitioner)

109 W 4TH ST
CLE ELUM, WA
04/30/10
04/30/10
04/30/10
04/30/10
13 88 7 3
Kittitas County Sheriffs Office

Statement o f P r o c e s s C o s t s
Responsible Party:
MELISSA JILL HART
109 W 4TH ST
CLE ELUM, WA 98922
Date
6 /1 7 /2 8 1 1
98922
98925
Typ Description
1
2
3
4
CHG
CHG
CHG
CHG
Affidavit
Mileage Charge
TEMP ORDER FOR PROTECTION - DV
Fee Waiver - PO DV
FINAL REFUND DUE :
I hereby certify that the refund due is correct and payable.

within ten days, this statement will be considered correct.
GENE DANA, SHERIFF
KITTITAS COUNTY SHERIFF OFFICE
Kittitas County Sheriff
Ellensburg, Washington 98926
Amount
10.00
35.00
20.00
-65.00
0.00
If not contacted
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
June 20 2011
1
KEVIN ST
COUNTY C
NO: 10-3-0
3
4
5
6

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10
J A S O N W . S H IP M A N
11
P e titio n e r
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v.
13
J E N N IF E R K . S H IP M A N
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C A S E N O .: 1 0 -3-00961-1
)
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N O TIC E OF A PPEA R A N C E
)
)
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R e sp o n d e n t,
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TO: CLERK OF THE ABOVE-ENTITLED COURT; and
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TO:
Ja s o n W . S h ip m a n , P ro Se.
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COMES NOW, Timothy M. Greene, attorney at Law, on behalf of the

Law Offices of Greene & Lloyd, P.L.L.C., hereby enters their Notice of Appearance
22
as attorneys for the Respondent, without waiving objections, defenses, or

23
24
affirmative allegations as to lack of personal jurisdiction, lack of subject matter
25
jurisdiction, improper service, or improper venue, and requests that all further
26
papers or pleadings, exclusive of original service, be served upon the undersigned

attorney at the address below stated.
1 of 2

P.O. Box 731063 / 4115 S. Meridian # B
(253) 770-0808, Fax (253) 770-0259
1
2
SIGNED and Dated this
20 th
day of
June______, 2011.
3
4
GREENE & LLOYD, P.L.L.C.
5
6
By:
/s/ T im o th y M . Greene
Timothy M. Greene
WSBA #17499
8
9
10
11
12
13
14
15
16
17
18
19
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21
22
23
24
25
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2 of 2

P.O. Box 731063 / 4115 S. Meridian # B
(253) 770-0808, Fax (253) 770-0259
b '2 i -'2 8 il
10*3-00961-1
36633014
ANWRGR2
14838
BSBSS
06-21-11
IN COUNTYtJtlR^'S OFFWE
KU JUN 20 2011 p.n

n~f
_1

County o f Pierce
In re the marriage of.

No.
10-3-00961-1
Petitioner,
SECOND ANSWER TO WRIT OF

GARNISHMENT FOR CONTINUING
LIEN ON EARNINGS
and
Respondent.
Garnishee Defendant
SECTION I
ANSWER SECTION II OF THIS FORM WITH RESPECT TO THE TOTAL AMOUNT OF
EARNINGS WITHHELD UNDER THIS GARNISHMENT, INCLUDING THE AMOUNT, IF ANY,
STATED IN YOUR FIRST ANSWER, AND WITHIN TWENTY (20) DAYS AFTER YOU
RECEIVE THESE FORMS, MAIL OR DELIVER THEM AS DIRECTED IN THE WRIT
Amount due and owing stated in
the first answer
$ S F
. 7
Second Answer To Writ Of Garnishment For Continuing Lien On

Earnings -1
WPF GARN 01 0770 (7/2003) - RCW 6 27 190, 350
S \CASESl\Shipman, Jason dtsso\Gamishment\Second Answer doc
FAUBION, REEDER,
FRALEY & COOK, P S
5920- 100th St SW #25
Lakewood, WA 98499
253-581-0660
fe /'2 1 / 2 S 11
1
2
Amount accrued since first answer
TOTAL AMOUNT WITHHELD
$_
14S 3B
S B lB iS
<2- 2 .
3
4
SECTION II
5
6
7
8
9
10
11
12
At the time of service of the Writ of Garnishment on the Garnishee, there was due and owing
from the Garnishee to the above-named defendant $ _____________
This writ attaches a maximum of 25 percent of the Petitioner / Respondents disposable
earnings (that is, compensation payable for personal services, whether called wages, salary,
commission, bonus, or otherwise, and including periodic payments pursuant to a
nongovernmental pension or retirement program) Calculate the attachable amount as follows
Gross Earnings
$ ______________ (1)
14

withholding tax, etc Do not include deductions for child
support orders or government liens here Deduct child
support orders and liens on line 7)
$ _______________ (2)
15
Disposable Earnings (subtract line 2 from line 1)
$ _______________ (3)
16
Enter 75 % (percent) of line 3
$ _______________ (4)
17
Enter one of the following exempt amounts*
$ _______________ (5)
18
If paid Weekly
Bi-weekly
13
$_____
$_____
Semi-monthly $_____
Monthly
$_____
19
*These are minimum exempt amounts that the__ (employee Pet / Resp) must be paid If your
20
21
22
23
24
25
answer covers more than one pay period, multiply the preceding amount by the number of pay
periods and/or fraction thereof your answer covers If you use a pay period not shown, prorate
the monthly exempt amount
Subtract the larger of lines 4 and 5 from line 3.
$ _______________(6)

ongoing government liens such as child support $ _______________(7)
Earnings - 2
WPF GARN 01 0770 (7/2003) - RCW 6 27 190, 350
S \CASESl\Shipman, Jason dissoXGamishmentXSecond Answer doc
FAUBION, REEDER,
FRALEY & COOK, P S
5920 - 100tfl St SW #25
Lakewood, WA 98499
253-581-0660
2 1 / Z 31.1
Subtract line 7 from line 6 This amount must be held

out for the___ Petitioner / Respondent.
1403B
$ ____________
(8)
This is the formula that you will use for withholding each pay period over the required 60-day
garnishment period Deduct any allowable processing fee you may charge from the amount
that is to be paid to the___ Petitioner / Respondent.
If there is any uncertainly about your answer give an explanation on the last page or on an
attached page
SECTION III
An attorney may answer for the Garnishee
Under penalty of perjury, I affirm that I have examined this answer, including accompanying
schedules, and to the best of my knowledge and belief, it is true, correct and complete
____________________
-A S ~ - / /
Date
Signature of Person Answering for Garnishee
Connection with Garnishee

y - ^ ir ^ - 7
s of Garnishee
Phone Number
3Uc H ealth
Initiatives
jshment Department
If necessary, use the space below to supplement your answer from the first and second pages

Earnings - 3
WPF GARN 01 0770 (7/2003) - RCW 6 27 190, 350
S \CASES1\Shipman, Jason disso\Gamishment\Second Answer doc
FAUBION, REEDER,
FRALEY & COOK, P S
5920-1 0 0 th St SW #25
Lakewood, WA 98499
253-581-0660
Employee
Payment Nbr
14S 3S
MB
PR277 Date 06/14/11

Time 12 54
ff*lCase
File Number /
tf*.. ..........
10-3-00961-1
Company 8900
Report Sequence Employee Name
55218
23546907
FIPS
SHIPMAN, JENNIFER K
Gross Pay
3071 34
Disposable
Income
Exempt Wages
2333 88
1750 41
Page
SSN 536-88-2306
Garn
Ded
G20P
Amount
583 47
ClrHse
Fee
0 00
Art
Court Fee Ded
0 00
Amount
0 00
Court
Fee
Arreas Fee Ded
0 00
Amount
0 00
yi
^Payment Nbr
^Case
^ F 1 1e Numbe r /
23588817
FIPS
Gross Pay
3007 40
^10-3-00961-1
Disposable
Income
Exempt Wages
2289 05
1716 78

Garn
Ded
G20P
Amount
572 26
ClrHse
Fee
0 00
Arr
Court Fee Ded
0 00
Amount
0 00
Court
Fee
Arreas Fee Ded
0 00
Amount
0 00
sO
Payment Nbr
Case
File Number /
23630632
FIPS
10-3-00961-1
Payment Nbr
Case
File Number /
Gross Pay
3198 54
23672421
FIPS
10-3-00961-1
Di sposable
Income
Exempt Wages
2423 06
1817 29

Garn
Ded
G20P
Gross Pay
3062 85
Disposable
Income
Exempt Wages
2327 93
1745 94
Amount
605 77
ClrHse
Fee
0 00
Ari
Court Fee Ded
0 00
Amount
0 00
Court
Fee
Arreas Fee Ded
0 00
Amount
0 00

Garn
Ded
G20P
Amount
46 63
ClrHse
Fee
0 00
Arr
Court Fee Ded
0 00
Amount
0 00
Court
Fee
Arreas Fee Ded
0 00
Amount
0 00
Garnishment balance has been reached

Employee Total
1,808 13
0 .00
0 00
0 00
Company 8900 Total
1,808 13
0 00
0 00
0 00
'1 /k
h u u d j &
lr\L &
J p jL h tji/x
r fm
o /
L---------------------------------------------------------------- ----------------------------------
J _ r ig ju t a f j/ y y i_
June 21,2011 9:30 AM

PT COM DAVID H JOHNSON
9 - 5
. f l)
Clerk
Courtroom number 2-A
) b
- b

Ixcrtrpt pbl djoumal_entry_showcause_report
Calendar C1- SHOW CAUSE/FAMILY LAW
S /2 2 /2 g il
10-3-00961-1
36638947
ORRE
,
06-22-11
I404S
FILED
43014
COURT COMMISSIONER
IN OPEN COURT
JUN 2 J aw
PIERCE
^
nEPI ITV
THIS MATTER having come before the Court upon the moving party's Motion, and the
C \Documents and Settings\hkinne\Loca! Settings\Temporary Internet

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DAVID H. JOHNSON
COURT COMMISSIONFR
Dated
- ^ - l - < /
Judge/ C ourt C o m m is
Approved for entry
Notice of presentation waived
iqnature/WSBA #
Print Name
Ordei (OR) - Page 2 of 2

WPF DRPSCU 01 0150 (6/2006)
C \Documents and Settings\hkinne\Local Settings\Temporary Internet
Files\Content Outlook\90DT1D4X\Blank order #2 DOC
3 hfet*. a ^
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10-3-00961-1
36697014
TMORSW
S * /-rn4
I?
07-01-11
_
T FILED
A.M.
PIERCE COUNTY WASHINGTON

KEVIN:STQg<. County Clerk
JUN 30 2011 RM
8Y----- ------------ --------- -DEPUTY
5
6
7

County of Pierce
No. 10-3-00961-1
Order of Child Support
Petitioner,
10
and
11
Respondent.
12
13
[x ] Temporary (TMORS)
[] Final Order (ORS)
Clerk's Action Required
I. Judgment Summary
1.1
Judgment Summary for Non-Medical Expenses
14
[X ]
[]
Does not apply.

Applies as follows:
15
A.
B.
C.
Judgment creditor
___________
Judgment debtor
___________
Principal judgment amount (back child support/other obligations) $
from (date)____________ through (date)____________
$
Attorney fees
$
Costs
$
$
Principal judgment shall bear interest at________ % per annum
Attorney fees, costs and other recovery amounts shall bear interest at______ % per annum
Attorney for judgment c r e d i t o r _________________________ ___
________________________ ____
Other:
16
D.
E.
F.
G.
H.
I.
J.
K.
L.
17
18
19
20
21
22
1.2
23
Judgment Summary for Medical Support
[X ]
Does not apply.

(253) 770-0808, Fax (253) 770-0259
[]
Applies as follows:
A.
B.
C.
Judgment creditor
___________
Judgment debtor
___________
Judgment for medical support
$
from (date)____________ through (date)_____________
$
Attorney fees
$
Costs
$
Principal judgment shall bear interest at_________ % per annum
Attorney fees, costs and other recovery amounts shall bear interest at_____ %per annum
Attorney forjudgment c r e d i t o r _______________________ _____
Attorney for judgment d e b t o r ________________________ ____
Other
D.
E.
F.
G.
H.
I.
J.
K.
II. Basis
2.1
Type of Proceeding
This order is entered under a petition for dissolution of marriage or domestic partnership, legal
separation, or declaration concerning validity:
[]
[]
[X ]
[]
[]
[]
2.2
decree of dissolution, legal separation or a declaration concerning validity.

order for modification of child support.
hearing for temporary child support
order of adjustment.
order for modification of a custody decree or parenting plan.
other:
Child Support Worksheet
The child support worksheet which has been approved by the court is attached to this order and is
incorporated by reference or has been initialed and filed separately and is incorporated by reference.
2.3
Other
III. Findings and Order
It Is Ordered:
3.1
Child(ren) for Whom Support is Required
Name (first/last)
Age
TS
16
HS

(253) 770-0808, Fax (253) 770-0259
# a4 O A n
> .
f
j. a
1
3.2
2
3
Person Paying Support (Obligor)
Name (first/last): Jason Shipman

Birth date: August 20,1972
Service Address: 881 l-133rf St Ct E, Puyallup, WA 98373
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 R C W 26.23.050.
The Obligor Parent Shall Update the Information Required by Paragraph 3.2
Information Continues as long as any Support Debt Remains due Under
This Order.
8
9
10
income:
A.
[X ]
Actual Monthly Net Income: $ 2.075.67

OR
11
12
B.
[]

Actual monthly gross income $ ____ _________ from which the court
excludes $ _____________ because the court finds that the obligor earned that
[]
[]
[]
that the income will cease when the obligor has paid off his or her debts.
13
14
15
16
Monthly net income after allowed exclusion: $
17
OR
18
C.
[]
The net income of the obligor is imputed at $ _____________ because:
19
20
21
22
23
[]
[]
[]
the obligors income is unknown.

the obligor is voluntarily unemployed.
the obligor is voluntarily underemployed.

[]
[]
current rate of pay.

reliable historical rate of pay information.
(253) 770-0808, Fax (253) 770-0259
4 4 n n i)
[]
[]
[]
[]
3.3
4 4
+V -1*- ' /Ofi
i-V A
X

parents past earnings.
t]
has a recent history of minimum wage jobs,
[]
recently came off public assistance, general assistanceunemployable, supplemental security income, or disability
[]
[]
is a high school student.
Other:
Person Receiving Support (Obligee)
Name (first/last): Jennifer Kay Shipman

Birth date: February 16,1974
Service Address: 2323 7thST SE, Apt B203, Puyallup, WA 98374
The Obligee Must Immediately File With the Court and the Washington
State Child Support Registry and Update as Necessary the Confidential
Information Form Required by RCW 26.23.050.
The Obligee Shall Update the Information Required by Paragraph 3.3
Information Continues as Long as any Monthly Support Remains Due o r
any Unpaid Support Debt Remains Due Under This Order.
income:
A.
[X ]
Actual monthly Net Income: $ 6.192.00_____________ .

OR
B.
[]

excludes $ _____________ because the court finds that the obligee earned that
[]
[]
(253) 770-0808, Fax (253) 770-0259
*.<4n n r ^
[]

that the income will cease when the obligee has paid off his or her debts.
Monthly net income after allowed exclusion: $_______________ .

OR
C.
[]
The net income of the obligee is imputed at $ _____________ because:

[]
[]
[]
the obligees income is unknown.

the obligee is voluntarily unemployed.
the obligee is voluntarily underemployed.

[]
t]
[]
[]
[]
[]
current rate of pay;

reliable historical rate of pay information;
parents past earnings;
[]
has a recent history of minimum wage jobs;
[]
recently came off public assistance, general assistanceunemployable, supplemental security income; or disability
[]
[]
is a high school student;
Other:
The obligor may be able to seek reimbursement for day care or special child rearing expenses not
actually incurred. RCW 26.19.080.
3.4
Service of Process
Service o f Process on the Obligor at the Address Required by Paragraph

3.2 or any Updated Addresst or on the Obligee at the Address Required by
Paragraph 3.3 o r 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 o f Written Notice to the
Obligor or Obligee at the Last Address Provided.

(253) 770*0808, Fax (253) 770-0259
A"t -C-?
4<
t * JLr *7Q
O X i
*7/4
Transfer Payment
2
3
The obligor parent shall pay the following amounts per month for the following child(ren):
Name
Amount
IS_______________________________________
HS_______________________________________
$_____________________
$_____________________
_______________________________________
_______________________________________
$____________________
$____________________
Total Monthly Transfer Amount
$460.96_________________
[]
The parents combined monthly net income exceeds $12,000 and the court sets child
support in excess of the presumptive amount for $12,000 because:
[]
The court finds that the obligors child support obligations owed for all his or her
biological or legal children exceed 45% of his or her net income and it is [ ] just
[ ] unjust to apply the 45% limitation based upon the best interests of the child(ren) and
the circumstances of each parent as follows:
[]
If one of the children changes age brackets, the child support shall be as follows:
[]
This is a downward modification that has caused an overpayment of $ _______

This amount shall be repaid or credited as follows:
[]
This is an upward modification that has caused an underpayment of $________

This amount shall be paid as follows:
[]
Other:
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
The Obligor Parent's Privileges to Obtain o r Maintain a License, Certificate ,

Registration , Permit, Approval, or Other Similar Document Issued by a
Mailing: P.O- Box 731063
(253) 770-0808, Fax (253) 770-0259
/r 4
v *>i2 4 aavann
X ^ .11 4. JL U W U < U
V 'S '
Licensing Entity Evidencing Admission to or Granting Authority to Engage

in a Profession , Occupation, Business, Industry, Recreational Pursuit, or
the Operation o f a Motor Vehicle m ay Be Denied or may Be Suspended if
the Obligor Parent is not in Compliance With This Support Order as
Provided in Chapter 74.20A Revised Code o f Washington.
2
3
4
3.6
$ 460.96
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Standard Calculation
3.7
per month. (See Worksheet line 17.)
Reasons for Deviation From Standard Calculation
[X ]
The child support amount ordered in paragraph 3,5 does not deviate from the standard
calculation.
[ ] The child support amount ordered in paragraph 3.5 deviates from the standard calculation for
the following reasons:
[ ] Income of a new spouse or new domestic partner of the parent requesting a deviation for
other reasons;
[ ] Income of other adults in the household of the parent requesting a deviation for other
reasons;
[ ] Child support actually paid or received for other children) from other relationships;
[] Gifts;
[ ] Prizes;
[ ] Possession of wealth;
[ ] Extraordinary income of children);
[ ] Tax planning which results in greater benefit to the child(ren);
[ ] Income from overtime or second jobs that was excluded from income of the parent
requesting a deviation for other reasons;
[ ] A nonrecurring source of income;
[ ] Extraordinary debt not voluntarily incurred;
[ ] A significant disparity in the living costs of the parents due to conditions beyond their
control;
[ ] Special needs of disabled children);
[ ] Special medical, educational, or psychological needs of the child(ren);
[ ] The child(ren) spend(s) a significant amount of time with the parent who is obligated to
make a support transfer payment. The deviation does not result in insufficient funds in
the receiving parents household to meet the basic needs of the children). The
children) do(es) not receive public assistance;
[ ] Children) from other relationships;
[ ] Costs incurred or anticipated to be incurred by the parents in compliance with courtordered reunification efforts or under a voluntary placement agreement with an agency
supervising the children);
[ ] The obligor has established that it is unjust to apply the presumptive minimum payment
of $50.00 per child;
[ ] The obligee has established that it is unjust to apply the self-support reserve.
22
[ ] Other reason(s) for deviation:

23
(253) 770-0808, Pax (253) 770-0259
-* 4 n n a
The factual basis for these reasons is as follows:
1
2
3
3.8
Reasons why Request for Deviation Was Denied
[]
[X ]
[]
4
5
Does not apply. A deviation was ordered.

A deviation was not requested.
The deviation sought by the [ ] obligor [ ] obligee was denied because:
[]
no good reason exists to justify deviation.
[j
other:
6
7
3.9
Starting Date:
Day(s) of the month support is due:
8
9
Starting Date and Day to Be Paid
3.10
10
Incremental Payments
[]
[]
11
12
13
3.11
May 1.2011 __________________

______________________
Does not apply.

This is a modification of child support. Pursuant to RCW 26.09.170 (9)(a) and (c), the
obligation has been modified by more than 30 percent and the change would cause
significant hardship. The increase in the child support obligation set forth in Paragraph
3.5 shall be implemented in two equal increments, one at the time of this order and the
second on (date)_____________ six months from the entry of this order.
Making Support Payments
14
Select Enforcement and Collection, Payment Services Only, or Direct Payment;
15
[X ]
16
17

P. O. Box 45868
Olympia, WA 98504
Phone: 1-800-922-4306 or
1-800-442-5437
18
19
20
21
22
23
Enforcement and collection: The Division of Child Support (DCS) provides support
enforcement services for this case because: [ ] this is a public assistance case, [ ] this is
a case in which a parent has requested services from DCS, [ ] a parent has signed the
application for services from DCS on the last page of this support order. (Check all
that apply.) Support payments shall be made to:
[]
Payment services only: The Division of Child Support will process and keep a record of
all payments but will not take any collection action. Support payments shall be made to:
P. O. Box 45868
Olympia, WA 98504
Phone: 1-800-922^306 or
1-800-442-5437
Law Offices of G reene & Lloyd, PLLC
Street; 4115 S. M eridian
Puyallup, W ashington 98373
(253) 770-0808, F ax (253) 770-0259
<*5 n n
[]
' X ' ^ <J X J. U d u u u
Direct Payment: Support payments shall be made directly to:

N a m e ___________________________
Mailing Address________________________
A party required to make payments to the Washington State Support Registry will not receive
credit for a payment made to any other party or entity. The obligor parent shall keep the registry
informed whether he or she has access to health insurance coverage at reasonable cost and, if so,
to provide the health insurance po)icy information.
Any time the Division of Child Support is providing support enforcement services under
RCW 26.23.045, or if a party is applying for support enforcement services by signing the
application form on the bottom of the support order, the receiving parent might be required to
submit an accounting of how the support, including any cash medical support, is being spent to
benefit the children).
3.12
Wage Withholding Action
Withholding action may be taken against wages, earnings, assets, or benefits, and liens enforced
against real and personal property under the child support statutes of this or any other state,
without further notice to the obligor parent at any time after entry of this order unless an
alternative provision is made below:
[If the court orders immediate wage withholding in a case where Division of Child Support does
not provide support enforcement services, a mandatory wage assignment under Chapter 26.18
RCW must be entered and support payments must be made to the Support Registry.]
[]
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.
[]
the Division of Child Support provides support enforcement services for this
case [see 3.11] and there is good cause [as stated below under "Good Cause"]
not to require immediate income withholding which is in the best interests of the
children) and, in modification cases, previously ordered child support has been
timely paid.
[]
the Division of Child Support does not provide support enforcement services for
this case [see 3.11] and there is good cause [as stated below under "Good
Cause"] not to require immediate income withholding.
Good Cause:

S treet: 4115 S. M eridian
(253) 770-0808, Fax (253) 770-0259
rj <
' . "
i- U
A -
J
nQaQn
nti
^JL
UJ
Unn
11
u J4
1
3.13
Termination of Support
Support shall be paid:
[X ]
[ ]
5
[ ]
6
f]
7
[]
8
9
[]
3.14
10
Post Secondary Educational Support
[]
11
[ ]
12
provided that this is a temporaiy order, until a subsequent child support order is entered
by this court.
until the children) reach(es) the age of 18 or as long as the child(ren) remain(s) enrolled
in high school, whichever occurs last, except as otherwise provided below in Paragraph
3.14.
until the children) reach(es) the age of 18, except as otherwise provided below in
Paragraph 3.14.
after the age of 18 for (name!
who is a dependent
adult child, until the child is capable of self-support and the necessity for support ceases.
until the obligation for post secondary support set forth in Paragraph 3.14 begins for the
child(ren).
Other:
[ ]
[X ]
The right to request post secondary support is reserved, provided that the right is
exercised before support terminates as set forth in paragraph 3.13.
The parents shall pay for the post secondary educational support of the children). Post
secondary support provisions will be decided by agreement or by the court.
No post secondary educational support shall be required.
Other: Reserved
13
14
15
Id
3.15
Payment for Expenses not Included in the Transfer Payment

[ ]
[X l
17
18
19
20
Does not apply because all payments, except medical, are included in the transfer
payment.
The petitioner shall pav 28.72
%and the respondent 71.28 % teach
parents proportional share of income from the Child Support Schedule Worksheet, line
6) of the following expenses incurred on behalf of the children) listed in Paragraph 3.1:)
pC ]
day care within 30 days of presentation of receipts by petitioner, respondent
shall reimburse
[ ]
educational expenses.
[ ]
long distance transportation expenses.
pC ]
other; Boys organized sports activities that the parties agree upon in writing
Payments shall be made to [ ] the provider of the service [ ] the parent receiving the
transfer payment.
21
22
The obligor shall pay the following amounts each month the expense is incurred on
behalf of the child(ren) listed in Paragraph 3.1:
23
11
[ ]
day care: $
payable to the f 1day care provider f 1other

M ailing: P.O. Box 731063
(253) 770-0808, Fax (253) 770-0259
1
[J
2
[]
[]
parent;
educational expenses: $
payable to the [ ] educational
provider [ ] other parent;
long distance transportation: $
payable to the
[ ] transportation provider [ ] other parent,
other:
4
5
3.16
Periodic Adjustment
[X ]
[]
Does not apply.

Child support shall be adjusted periodically as follows:
[]
Other:
7
8
3.17
10
Income Tax Exemptions
[]
[X ]
Does not apply.

Tax exemptions for the children) shall be allocated as follows: Reserved
t]
[]
The parents shall sign the federal income tax dependency exemption waiver.
Other:
11
12
13
14
15
16
17
18
19
20
3.18
Medical Support - Health Insurance
Each parent shall provide health insurance coverage for the children) listed in paragraph 3.1, as
follows:
3.18.1 Health Insurance (either check box A(1 )>or check box A(2) and complete sections B
and C. Section D applies in all cases.)
A.
Evidence
(1) [ ] There is insufficient evidence for the court to determine which parent must
provide coverage and which parent must contribute a sum certain. Therefore, the
court is not specifying how insurance coverage shall be provided. The
petitioners and respondents medical support obligations may be enforced by
the Division of Child Support or the other parent under RCW 26.18,170 as
described in paragraph 3.18.2, below.
21
OR
22
23
(2) [ ] There is sufficient evidence for the court to determine which parent must provide
coverage and which parent must contribute a sum certain. Fill in B and C below.
P uyallup, W ashington 98373
(253) 770-0808, Fax (253) 770-0259
B.
2
Findings about insurance:

[]
[]
Does not apply because A (1) is checked, above.

The court makes the following findings:
r
4
(Parents Name)
(Parents Name)
5
[]
6
[ 3
7
8
[ 3
9
[ 3
10
11
[3
12
E3
13
14
15
[ 3
E3
[ 3
[ 3
16
17
Check at least one of the following findings

for each parent
Insurance coverage for the child(ren) is available and
accessible to this parent at $
cost
(child(ren)s portion of the premium, only).
Insurance coverage for the children) is available and
accessible to this parent at $
cost
Insurance coverage for the child(ren) is available but
not accessible to this parent at $
cost
Insurance coverage for the child(ren) is available but
not accessible to this parent at $
cost
Neither parent has available or accessible insurance
through an employer or union; but this parent is able to
provide private coverage at a cost not to exceed 25% of
this parents basic support obligation.
Neither parent has available or accessible insurance
through an employer or union; but this parent is able to
provide private coverage at a cost not to exceed 25% of
this parent's basic support obligation.
(Check only one parent) Both parties have available and
accessible coverage for the child(ren). The court finds
that this parent has better coverage considering the
needs of the children), the cost and extent of each
parents coverage, and the accessibility of the coverage.
Other:
18
19
20
21
C.
Parties obligations:
[]
[]
Does not apply because A (1) is checked above.

The court makes the following orders:
22
23
Street: 4115 S. M eridian
(253) 770-0808, Fax (253) 770-0259
1
2
(Parents Name)
(Parents Name)
[]
[ ]
[]
[]
4
5
6
7
Check at least one of the following options for each

parent.
This parent shall provide health insurance coverage for
the children) that is available through employment or
is union-related as long as the cost of such coverage
does not exceed 25% of this parents basic support
obligation._________________________________
This parent shall provide health insurance coverage for
the children) that is available through employment or
is union-related even though the cost of such
coverage exceeds 25% of this parents basic support
obligation. It is in the best interests of the child(ren) to
provide such coverage despite the cost because:
8
9
This parent shall provide private health insurance

coverage for the child(ren) as long as the cost of such
coverage does not exceed 25% of this parents basic
__________________ support obligation._____________ ___________
This parent shall provide private health insurance
[]
coverage for the child(ren) even though the cost of
such coverage exceeds 25% of this parents basic
support obligation. It is in the best interests of the
children) to provide such coverage despite the cost
because:
[]
[ ]
10
11
[]
12
13
14
[
[ ]
[ ]
[ ]
[ ]
15
16
17
18
19
20
This parent shall pay $_______ towards the health

insurance premium being paid by the other parent.
This amount is this parents proportionate share of the
premium or 25% of this parents basic support
obligation, whichever is less. This payment is only
required if this parent is not providing insurance as
described above.
This parents contribution to the health insurance
premium is calculated in the Worksheet and included
in the transfer payment.
This parent shall be excused from the responsibility to
provide health insurance coverage and from the
responsibility to provide monthly payment towards the
premium because:
21
22
(Only one parent may be excused.)
23
Street: 4115 S. M eridian
(253) 770-0808, P ax (253) 770-0259
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.
The parent(s) shall maintain health insurance coverage, if available for the children)
listed in paragraph 3.1, until further order of the court or until health insurance is no
longer available through the parents employer or union and no conversion privileges
exist to continue coverage following termination of employment.
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.
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.
3.16.2 Change of Circumstances and Enforcement
A parent required to provide health insurance coverage must notify both the Division of Child
Support and the other parent when coverage terminates.
If the parents* circumstances change, or if the court has not specified how medical support shall
be provided, the parents medical support obligations will be enforced as provided in
RCW 26.18.170. If a parent does not provide proof of accessible coverage for the child(ren)
through private insurance, a parent may be required to satisfy his or her medical support
obligation by doing one of the following, listed in order of priority:
1) Providing or maintaining health insurance coverage through the parents employment or
union at a cost not to exceed 25% of that parents basic support obligation;
2) Contributing the parents proportionate share of a monthly premium being paid by the
other parent for health insurance coverage for the children) listed in paragraph 3.1 of
this order, not to exceed 25% of the obligated parents basic support obligation; or
3) Contributing the parents proportionate share of a monthly premium paid by the state if
the children) receives state-financed medical coverage through DSHS under RCW 74.09
for which there is an assignment.
A parent seeking to enforce the obligation to provide health insurance coverage may apply for
support enforcement services from the Division of Child Support; file a motion for contempt (use
form WPF DRPSCU 05.0100, Motion/Declaration for an Order to Show Cause re Contempt); or
file a petition.

(253) 770*0808, F a i (253) 770*0259
3.19
Both parents have an obligation to pay their share of uninsured medical expenses.
The petitioner shall pay 28,72_______ % of uninsured medical expenses (unless
stated otherwise, the petitioners proportional share of income from the Worksheet, line
6) and the respondent shall pay 71.28________%of uninsured medical expenses
(unless stated otherwise, the respondents proportional share of income from the
Worksheet,
line 6).
2
3
4
5
6
Uninsured Medical Expenses
3.20
7
8
Back Child Support
[]
[]
Back child support that may be owed is not affected by this order.
(Name)____________ __________
(name)_______________________
child support for the period from (date)
(Name)_______________________
(name)_______________________
interest for die period from (date)____
9
n
10
________ is awarded a judgment against

in the amount of $ _____________ for back
__________ through (date) ____________ .
____ is awarded ajudgment against
_ in the amount of $ ___________ for back
________through (date)_______________.
11
12
[]
[]
No back child support is owed at this time.

13
PC]
Other: Not Addressed and Reserved
14
3.21
15
16
Past Due Unpaid Medical Support
[]
[]
Unpaid medical support that may be owed is not affected by this order.
[]
(Name)__________________________is awarded a judgment against

(name)______________________ in the amount of $ _____________ for past due
unpaid medical support for the period from (date)_______ through (date)_______ .
(Name)_____________________ _is awarded ajudgment against
(name)______________________in the amount of $ _____________ for back
interest for the period from (date)____________ through (date)______________ .
17
[]
18
19
20
[]
[]
No past due unpaid medical support is owed at this time.

21
[]
Other:
22
3.22
Other Unpaid Obligations
23
(253) 770-0808, Fax (253) 770-0259
[]
[]
Other obligations that may be owed are not affected by this order.
[]
(Name)_____________________________ is awarded a judgment against

(name)_______________________in the amount of $ ______________ for [ ] child
care [ ] ordered contributions to extracurricular activities [ ] long distance transportation
costs [ ] educational expenses [ ] post secondary [ ] other_______________________
for the period from (date)____________ through (date)_________________
(Name)______________________is awarded a judgment against
in the amount of $
(name)__________________
for back
through (date) __
interest for the period from (date)
[]
3.23
[]
[]
No other obligations are owed at this time.

[]
Other:
IN COUNTY CLERK'S OF :ICE
AM JUN 3 0 2011
Pl KEwfsTOCK, County*TerH
.DEPUTY
Other
Dated:
imissioner
Approved tot entry^

Notice oPpresentOTion waived:
wyerAVSBA No.
e of Party or Lawyer/WSBA No.

\ctz?ofn
Print Name
Print Name
[]
I apply for full support enforcement services from the DSHS Division of Child Support (DCS).
(Note: If you never received TANF, tribal TANF, or AFDC, an annual $25 fee applies if over
$500 is disbursed on a case, unless the fee is waived by DCS.)
Signature of Party
[]
Approval required in Public Assistance cases. The DSHS Division of Child Support received
notice required by RCW 26,23.130. This order has been reviewed and approved as to:
[]
[]
[]
[]
P.M.
GTON
Current Child Support

Back Child Support
Medical Support
Other:
Deputy Prosecuting Attomey/WSBA No.
(253) 770-0808, Fax (253) 770-0259
/
*4 tj ^L! *1
* r
44
JL X
n oo
nu
n rut
liu
E-FILED
IN COUNTY CLERK'S O FFICE
May 18 2011 11:24 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
W ASHING TO N STATE C H ILD S UPPO RT S CHEDULE W O RKSHEETS

[ X proposed by
[ ] Mother [ X ] Father ( ] State of WA [ ] Other___________________.(CSWP)
Or, [ JStgned by the Judiclal/Reviewing Officer. (CSW)

MOTHER
COUNTY

PIERCE
FATHER
SUPERIOR COURT/OAH CASE NO. 10-3-00961-1
_____________________ CHILD SUPPORT ORDER SUMMARY REPORT___________________

A. The order [ ] does [ X Jdoes not replace a prior court or adminstr&tfvB order.
B. The STANDARD CALCULATION listed on line 15e of the Worksheet for the paying parent is: $460.96.
C. The TRANSFER AMOUNT ordered by the Court from foe Order of Child Support
[ ] Does not apply
J J Nonrecurring income
[ J Sources of income and tax planning
( ] Split custody
| ] Residential schedule (including shared custody)
[ j High debt not voluntarily incurred and high expenses for the child(ren)
E. Income for the Father is [ ] imputed [ X ) actual Income.

Income for foe Mother is [ ] imputed [ X ] actual income.
Part II.
WORKSHEETS
Children and Ages Tyler 16, Hunter 9
Part I: Basic Support Obligation (See instructions, page 1)
Father
Mother
$2,075.67
$6,192.00
$0.00
$0.00
c. Business Income
$0.00
$0.00
$0.00
$0.00
e. Other Income
$0.00
$0.00
$2,075.67
$6,192.00
f. Total Monthly Gross Income (add lines 1a through 1e)

WSCSS-Woriesheets - M andatory (CSW/CSWP) 6/2008 page 1 o f 5
O riginal

5/162011 4:04PM
Father
Mother
$207.57 !
$1,475.78
b. F1CA (Social Security plus Medicare)/Self-Employment Taxes
$0.00
$0.00
$0.00
$0.00
d. Mandatory Union/Professiona! Dues
$0.00
$80.00
$0.00
$0.00
f. Maintenance Paid
$0.00
$0.00
$0.00
$0.00
h. Total Deductions from Gross Income (add lines 2a through 2g)
$207.57
$1,868.10
3. Monthly Net Income (line 1f minus line 2h)

4. Combined Monthly Net Income (add parent's monthly net incomes from line 3)
(If combined monthly net income is less than $600, skip to line 7.)
S. Basic Child Support Obligation (enter total amount in box
Tyler
$887
Hunter
$1,555.78
$4,636.22
$6,504,32
>)
$1,605.00
$718

(each parent's net income from line 3 divided by tine 4)
7. Each Parent's Basic Child Support Obligation
(multiply each number on fine 6 by tine 5)
. (If combined net monthly Income on fine 4 is less than $600, enter each parent's support
obligation of $25 per child. Number of children: 2. Skip to line 15a and enter this amount)
(advisory)
28.72%
$460.06
$1,144.04
Part tl: Health Care, Day Care, and Special Child Rearing Expenses (See instructions, page 3)
0.00
$0.00
$0.00
0.00
$0.00
$0.00
$0.00

$B0.25
e. Maximum Ordinary Monthly Health Care (multiply line 5 times 0.05)
0.00
f. Extraordinary Monthly Health Care Expenses

(fine 8d minus Be, if V or negative enter 0*)
0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
e. Total Day Care and Special Expenses (add fines 9a through 9d)
10. Combined Monthfy Total of Day Care and Special Expenses
W SCSS-W orfrsheets-M andatory (CSW/CSWP) 6/2008 page 2 o f 5
0.00
vi.
^ c*
11. Total Extraordinary Health Care, Day Care, and Special Expenses
(line 8f plus line 10)
Father
12. Each Parent's Obligation for Extraordinary Health Care, Day Care, and Special Expenses
(multiply each number on tine 6 by line 11)
$0.00
Mother
$0.00
Part III: Gross Child Support Obligation

13. Gross Child Support Obligation (line 7 plus fine 12)
Part IV: Child Support Credits
$460.96 J
$1,144.04
...
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$460.96
$1,144.04
c. Amount on line 15b adjusted to meet 45% net income limitation
$840.65
$2,086.30
d. Amount on tine 15b adjusted to meet need standard limitation
$737.10
$3,505.22
e. Enter the lowest amount of lines 15b, 15c or 15d.
$460.96
$1,144.04
c. Other Ordinary Expense Credit (describe)

Part V: Standard Caiculailon/Presumptlve Transfer Payment (See Instructions, page 4)
15. Standard Calculation
a. Amount from line 7 if fine 4 Is below $600. Skip to part VI.
b. Line 13 minus line 14d, if line 4 is over $600 {see below if applicable).
Limitation standards adjustments
Part VI: Additional Factors for Consideration (See Instructions, page 4)

16. Household A ssets (List the estimated present value of all major household assets.)
a. Real Estate
b. Stocks and Bonds
c. Vehicles
d. Boats
e. Pension/)RAs/Bank Accounts
f. Cash
g. Insurance Plans
h. Other (describe)
17. Household Debt (List Gens against household assets, extaordinary debt)
WSCSS-Worksheets - Mandatory (CSW /CSW P) 6/2008 page 3 o f 5
Fathers
Household
Mother's
Household
(Household Debt continued)
Fathers
Household
ii
i

Name
Name
Name
Name
c. Income of Children (If considered extraordinary)
Name
Name
d. Income From Child Support
Name
Name
e. Income From Assistance Programs
Program
Program
f. Other Income (describe)
20. Child Support Paid For Other Children

Name/Age
Name/Age
21. Other Children Living In Each Household (First names and ages)
W SCSS-W orksheets - Mandatory (CSW/CSWP) 6/2008 page 4 o f 5
i
I
Mother's
Household
WSCSS-W orksheets - Mandatory (CSW/CSWP) 6/2008 page 5 o f 5
2001-08 THOMAS E. JAFPE
E-FILED .
July 06 2011 2:06 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
IN THE S U P ER IO R COURT OF THE STATE OF W ASHINGTON

IN AND FO R THE C O U N TY OF PIERCE
No. 10-3-00961-1

Petitioner,
and

__________________________Respondent.
LIMITED NOTICE OF APPEARANCE
PLEASE TAKE NOTICE that Daniel N. Cook, of FAUBION, REEDER, FRALEY

& COOK, P.S., pursuant to CR 70.1(b), enters a limited appearance as the attorney of
record for JASON WILLIAM SHIPMAN, Respondent, herein.
This appearance is exclusively for the purpose of representing the

Respondent regarding garnishment of Petitioners wages. This representation will
terminate without notice or leave of court at close of business on July 10, 2011. The
undersigned hereby requests that he receive notices of all matters relating to said
garnishment until entry of close of business on said date.
For purposes of service of process, the last known address of Respondent is:
Jason Shipman
8811 - 133rd St Ct. E.
Puyallup, W A 98373
DATED t h i s J a y of July 2011.
By Daniel N. Cook, WSBA 34866

Limited Attorney for Respondent
Limited Notice Of Appearance - Page 1 of 1
S:\CASES1\Shipman, Jason disso\Word\PLEADINGS\Disso\Limited NOA.doc
FAUBION, REEDER,
FRALEY & COOK P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
14X36
10-^-00961-1
3672B8B7
MTJ
7 /8 /2 6 1 1
958315
07-06-11

A.M.
JUL 0? 2011
RM.
rKEVIN STOCrfûntyClerk^
Superior C ourt of W ashington

County o f Pierce
10
11
12
Petitioner,
13
and
14
15
16
17
No.
10-3-00961-1
M O TIO N AND DECLARATION

FOR JUDG M ENT AND ORDER
TO PAY
Respondent.
18
I.
19
MOTION
20
COMES NOW the Respondent, JASON SHIPMAN and moves the Court for entry
21
Judgment against Defendant in the amount of $286.23 for recoverable costs as shown
25
below. This motion is based on the subjoined Declaration and CR 55.
24
Judgment against Garnishee in the nonexempt amount of $1,808.13; and
VMI IU
23
of an order as follows:
MOTION AND DECLARATION FOR JUDGMENT AND ORDER TO

PAY Page -1
S:\CASES1\Shipman, Jason disso\Gamishment\paymotdoc
FAUBION, REEDER, FRALE

& COOK, P.S.
5920-1 0 0 th St. SW #25
Lakewood, WA 98499
253-581-0660
22
41^8
7 /8 X 2 81 1
95B323
Dated this
day of June, 2011.

& COOK, P.S.
4
5
DANIEL N. COOK, W SBA #34866

II. DECLARATION
8
9
10
11
12
I, DANIEL N. COOK, attorney for Respondent, hereby declare as follows:

A Writ of Garnishment was served upon Garnishee, FRANCISCAN HEALTH SYSTEM,
on March 30, 2011. The Answer of Garnishee indicates that the sum of $1,808.13 is
being held pursuant to the Writ. Respondents prior judgment sum and costs of suit for
13
the garnishment are listed as follows:
14
15
Prior Judgment Sum
16
Interest of 12% from 2/15/11 TO 3/23/11
17
18
$1,500.00
$ 18.13
Recoverable Costs This Garnishment Action

Writ Issuance/Filing Fee
$20.00
Service and Affidavit Fees
$0.00
Postage & Costs of Certified Mail
$16.23
Answer Fee or Fees (if applicable)
$0.00
Clerks Trust Check Fee
$0.00
24
Garnishment Attorneys Fee
$250.00
25
Other: (describe)
$0.00
19
20
21
22
23

PAY Page-2
S:\CASESl\Shipman, Jason disso\Gamishment\paymot.doc

& COOK, P.S.
5920-1 0 0 th St. SW #25
Lakewood, WA 98499
253-581-0660
14199
7 /8 ^ 2 9 1 1
95B321
2
$286.23
Total Recoverable Costs

3
The undersigned further states that more than twenty (20) days have elapsed
since service of the Writ of Garnishment and Garnishees answer thereto; that a signed
affidavit or return of service of the Writ of Garnishment plus the following checked
documents, indicating service upon the Judgment Debtor either by personal service or
by Certified Mail, is on file herein:
Superior Court Garnishment: Copy of the Judgment entered by the Court.
10
11
12
the foregoing is true and correct.

Dated this
day of June,
13
14
DANIEL N. COOK
15
16
17
18
19
20
21
22
23
24
25
PAY P age-3
S:\CASES1\Shipman, Jason disso\Garnishment\paymot.doc

& COOK, P.S.
5920 - 100th St. SW #25
Lakewood, WA 98499
253-581-0660
i4 1 9 8
Request for Military Status
Department of Defense Manpower Data Center
7 /8 /2 8 1 1
9S 8322
Page 1 o f2
Jun-22-20l 1 11:55:51
Military Status Report

Pursuant to the Service Members Civil Relief Act
Active Duty
Active Duty End
Service
Status
Date
Agency
0ct-06-2004
JENNIFER KAY
No
SHIPMAN
Apr-13-2011
Army
Based on the last name and Date of Birth you have provided, the individual is currently on Active Duty.
However, the first name, or middle name, or both provided do not match the individual against whom
the last name and Date of Birth is assigned.___________ _____________________________
Last Name
First/Middle
Begin Date
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard). HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF
DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT
THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE
OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL.
Y fa b fy y k .
Mary M. Snavely-Dixon, Director

Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members 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 a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the persons status by contacting that person's Service via the
"defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the
person is on active duty 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).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
https://www.dmdc.osd.mil/appj/scra/popreport.do
6/22/2011
Request for Military Status
14198
7 /8 /2 8 1 1
SBS3Z3
Page 2 of 2
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-ofcontact.
M ore inform ation on "A ctive D u ty Sta tu s "
Active duty status as reported in this certificate is defined in accordance with 10 USC 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage U nder the S C R A is B roader in S o m e Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
Report ID:LM71E02QQC
https://www.dmdc.osd.mil/appj/scra/popreport.do
6/22/2011
44158
7 ^8/2 8 11
958324
1
2
3
4
5
6
7
County of Pierce
8
9
In re the m arriage of;
10
No.
J E N N IF E R KAY S H IP M A N
10-3-00961-1
11
Petitioner,
12
and
F IR S T A N S W E R T O W R IT O F
13
J A S O N W IL L IA M SHIPMAN
C O N T IN U IN G L IE N O N
E A R N IN G S (A N W R G R )
14
15
GARNISHM ENT FOR
Respondent.
16
Garnishee Defendant
17
18
19
20
21
22
23
24
25
SECTION I
O n the date the Writ of G arnishm ent w as issued as indicated by the d a te
ap p earin g on the last page of the writ,
(A )
The Petitioner [*f w as [ ] w as not em ployed by G arnishee. If not
em p lo yed , and you have no possession or control o f a n y funds o f Petitioner, indicate
the last d ay of em ploym ent: _____________________ ; and com plete Section III of this
A n sw er and mail or delivepthe forms as directed in the Writ.
(B )
Petitioner M did M /did not m aintain a financial account with G a rn is h e e ..
(C )
T h e G arnishee [*f did [ ] did not have possession o f or control over any
funds, personal property, or effects of Petitioner. (List all of the P etitio n er's personal
property or effects in your possession or control on the bottom o f the last page of this
an sw er form or attach a schedule if necessary.)
If you are withholding the P e titio n e r's nonexem pt earnings under a previously
ANSW ER: W PF GARN 01.0750 (7/2003) - RCW 6.27.190, .340
S:\CASESlVShipman, Jason disso\Garnishment\answer.doc

& COOK, P.S.
5920 - 100th St. SW #25
Lakewood, WA 98499
253-581-0660
14138
7 / ^2 0 1 1
358325
served writ for a continuing lien, answer only Sections I and III of this form and mail or
deliver the forms as directed in the writ. Withhold from the Petitioner's future
nonexempt earnings as directed in the writ, and a second set of answer forms will be
forwarded to you later.
ANSWER: l am presently holding the Petitioner s nonexempt earnings under a
____________________(date).
directed in the writ. A second set of answer forms will be forwarded to you later for
SECTION II
At the tim e of service of the W rit of G arnishm ent on the G arnishee, there w as
d u e and owing from the G arnishee to the ab o ve -n a m e d P etitioner $_________________ /
This writ attaches a m axim um of 25 percent o f the P etitioner s disposable
earnings (that is, com pensation payable for personal services, w h eth er called w ag es ,
salary, com m ission, bonus, or otherwise, and including periodic paym ents pursuant to a
nongovernm ental pension or retirem ent program ). C alcu late the attachable am ount as
follows:
G ross Earnings:
$__________________ (1)
support orders or governm ent liens here. Deduct child
DisposabJe Earnings (subtract line 2 from line 1 ):
E n ter 75 % (p ercent) of line 3:
E n ter one of the following exem pt am ounts*:
If paid W e e k ly $ _______
Sem i-m onthly
$_
B i-w eekly
$_______
Monthly
. $
*T h e s e are m inim um exem pt am ounts that the P etitioner m ust be paid. If
your an sw er covers m ore than one pay period, multiply the preceding am o u n t
by the num ber of pay periods and/or fraction thereof your an sw er covers. If
you use a pay period not shown, prorate the m onthly exem pt am ount.
E n ter am ount (if any) withheld from this paycheck for
ongoing g overn m en t liens such as child support:
(6)
(7)
(8)
S ubtract line 7 from line 6. This am ount must be held

out for the Respondent:
A N S W E R : W PF G A R N 01 .075 0 (7 /2 0 0 3 ) - RCW 6.27.190 , .340

S:\CASES1VShipman. Jason disso\Garnishmenl\answer.doc

& COOK, P.S.
5920-1 0 0 th St. SW #25
Lakewood, WA 98499
253-581-0660
1 4 I3 &
7 /8 ^ 2 g iI
950326
1
This is the form Lila that you will Lise for withholding each pay period over the
z
required 60-day garnishment period. Deduct any allowable processing fee you may
3
4
charge from the amount that is to be paid to the Petitioner.

If (here is any uncertainty about your answer, give an explanation on the last
5
6
page of this answer form, or on an attached page.

SECTION Ml
7
8
A n a tto rn e y m ay answ er for the G arnishee.
U n d e r penalty of perjury, I affirm that
10
11
12
I have
exam ined this answ er, including
accom panying schedules, and to the best of my know ledge and belief, it is true, correct
a n d com plete.
Dated:
//
13
14
S ignature o f G arnishee Defendant
15
16
C onnection with Garnisfjjfee
-j
f /
17
18
S ignature of P erson Answering for

G arn ish ee
19
20
Print n am e of person signing
21
24
Phnnft Numhfir
3900 Olympic Blvd., Suite 400
Erlanger,KY 41018-1099
25
pages
22
23
w to supplem ent your answ er from the first and second
ANSWER: W PF GARN 0 1.0750 (7/2003) - RCW 6.27.190, .340

S:\CASESHShipman, Jason disso\Garnishment\answer.doc

& COOK, P.S.
5920 -1 0 0 m St. SW #25
Lakewood, WA 98499.
253-581-0660
PR27? net* 04SD&/11
Process Level 51103
55218
23516909
Employee
Payment Nht
Case
Fiie Number /
FIPS
Department
ST CLARE HOSPITAL
3091.31
LQ-3-00961-1
Disposable
Income
Exempt Wages
2333.B8
1750-11
3136
ORTHOPEDIC SURGICAL
SSN 536-86-2306
Gross Pay
Page
company B900
Time 06:29
Garn
Ded
G2 0P
Amount
583 .19
ClrHse
Fee
Arr
Court Fee Ded
0.00
0.00
Amount
0.00
Fee
Court
Arreas Fee Oed
0.00
Amount
0.00
583.19
0 .00
0,00
0.00
583.19
0 .00
0.00
0.00
Process Level 51103 Total
583.19
0 .00
0.00
0.00
Company B900 Total
583 .19
0 .00
0.00
0.00
Employee Total
Department 3136
Total
A*
h*
KO
CO
"0
X
CP
\
CP
k*<
M
-'
\
\
Ui
si
tii
M
Aj
\\
-J
*1
\
\
i4 i9 8
7 ^8 /2 8 i i
5S8328
2
3
4
5
6
7
8
County o f Pierce
9
10
In re the m arriage of:
11
No.
J E N N IF E R KAY S H IP M A N
1 0 -3 -0 0 9 6 1 -1
12
Petitioner,
13
14
SEC O N D A N S W E R TO W R IT OF
G ARNISHM ENT FO R CO NTINUING
LIEN ON EARNING S
and
J A S O N W IL L IA M S H IP M A N
15
R espondent
16

17
Garnishee Defendant
18
19
SECTION I
20
21
22
23
24
25
ANSW ER S EC TIO N II OF THIS FORM WITH R ESPEC T TO THE TOTAL AM O U N T O F

EARNING S W ITHHELD UNDER THIS GARNISHMENT, INCLUDING TH E AMOUNT, IF ANY,
STATED IN YOUR FIRST ANSWER; AND W ITHIN TW ENTY (20) DAYS AFTER YOU
RECEIVE THESE FORMS, MAIL OR DELIVER THEM AS DIRECTED IN THE WRIT.
Amount due and owing stated in

the first answer
. 9

Earnings -1
WPF GARN 01.0770 (7/2003) - RCW 6.27.190, .350
S:\CASES1\Shipman, Jason disso\GamishmenRSecond
Answer.doc
7
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 - 100th S t SW#25
Lakewood, WA 98499
253-581-0660
4198
1
Amount accrued since first answer
$ /2 -Z V
TOTAL A M O U N T W ITHHELD
/ e a r . / 3
? y Qy 2 8 i I
958329
(*>
3
4
SECTION II
At the time of service of the Writ of Garnishment on the Garnishee, there was due and owing
from the Garnishee to the above-named defendant $ _________________ .
7
This writ attaches a maximum of 25 percent of the Petitioner / Respondents disposable
8
earnings (that is, compensation payable for personal services, whether called wages, salary,
9
commission, bonus, or otherwise, and including periodic payments pursuant to a
10
nongovernmental pension or retirement program). Calculate the attachable amount as follows:
11
Gross Earnings:
$ __________________ (1)
12
14
Less deductions required by law {Social Security, federal

$ _______________
( 2)
15
Disposable Earnings (subtract line 2 from line 1):
(3)
16
Enter 75 % (percent) of line 3:
(4)
17
Enter one of the following exempt amounts*:
(5)
18
If paid Weekly
Bi-weekly
13
$_
$_
Semi-monthly $_
Monthly
$_
19
These are minimum exempt amounts that th e ___ (employee Pet / Resp) must be paid. If your
20
answer covers more than one pay period, multiply the preceding amount by the number of pay
21
periods and/or fraction thereof your answer covers. If you use a pay period not shown, prorate
22
the monthly exempt amount.
23
$ __________________ (6)
24
25

$

Earnings - 2
WPF GARN 01.0770 (7/2003) - RCW 6.27.190, .350
S:\CASES1\Shipman, Jason disso\GamishmenftSecond
Answer.doc
(7)
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 -1 0 0 th St. SW #25
Lakewood, WA 98499
253-581-0660
141^8 7^8^2811 3t>0336
1
2

out for th e ____ Petitioner / Respondent:
$ ______________ _
(8 )
This is the formula that you will use for withholding each pay period over the required 60-day
garnishment period. Deduct any allowable processing fee you may charge from the amount
that is to be paid to th e ____ Petitioner / Respondent.
6
If there is any uncertainly about your answer give an explanation on the last page or on an
attached page.
SECTION III
10
Under penalty of perjury, I affirm that I have examined this answer, including accompanying
11
schedules, and to the best of my knowledge and belief, it is true, correct and complete.
12
____________________________
14
15
6 - a s *"- / / ________
Date
/ ty y < e .d >
Signature of Person Answering for Garnishee
Connection with Garnishee
//e
16
Print nam eof person signing
y
tfr ?
18
19
- s '?
y -ir
ess of Garnishee:
Phone Number
tfhoUc Health Initiative

îshmentDepartmen
mo Olympic Blvd., Sui
20
21
if necessary, use the space below to supplement your answer from the first and second pages:
*
23
24
25

Earnings - 3
WPF GARN 01.0770 (7/2003) - RCW 6.27.190, .350
S:\CASES1\Shipman, Jason dis$o\GamishmenPSecond Answer.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920 - 100th St. SW #25
Lakewood, WA 98499
253-581-0660
PR277 Dace 06/14/11

Time 12 :S4
SS21G
23546907
Employee
Payment Nbr
350331
Case
File Number /
FIPS
SHIPMAN, JENNIFER K .
Gross Pay
3071 ,34
10-3-00961-1
23S00017
Payment Nbr
Case
File Number ;/
FIPS
Gross Pay
23630632
Case
File Number /
FIPS
Payment Nbr
Case
File Number /
Gross Pay
23672421
FIPS
10-3-00961-1
2333.BB
1750.41
Ga rn
Ded
G20P
Di sposable
Income
Exempt Wages
2289.05
1716.78
Di sposable
Income
Exempt Wages
2423 .06
18 17.29
3062.85
Di sposable
Income
Exempt Wages
2327.93
ClrHse
Amount
583 .47
Ga rn
Ded Amount
G20P
Fee
Arr
Court Fee Ded
0.00
0.00
Amount
0, 00
Court
Fee
Arreas Fee Ded
0 .00
Amount
0.00
572,26
ClrHse
Fee
Arr
Court Fee Ded
0.00
0.00
Amount
0.00
Court
Fee
Arreas Fee Ded
0.00
Amount
0.00

Garn
Ded
G20P
Amount
605.77
ClrHse
Fee
Arr
Court Fee Ded
0,00
0.00
Amount
0.00
Court
Fee
Arreas Fee Ded
0.00
Amount
0.00
Grogs Pay
3190.54
10-3-00961-1
Di sposable
Income
Exempt Wages
Page
SSN 536-89-2306
payment Type Direct Deposit
3007.40
10-3-00961 -1
Payment Nbr
Company 0900
Report Sequence Employee Name
Ga rr.
Ded
1745.94
G20P
Amount
46.63
ClrHse
Fee
Arr
Court Fee Ded
0.00
0.00
Amount
0.00
Court
Fee
Arreas Fee Ded
0,00
Amount
0,00
Garnishment balance has been reached

Employee Tota 1
1.808.13
0,00
0.00
0.00
Company 3900 Total
1,808.13
0,00
0.00
0.00
14138
7SB/2&11
358332
1
10-3-00961-1
36728093
JDOAGD
07-08-11
2
3
IN COUNTY ClI
4
5
r K'S OFFICE
A.M. JUL o 7 20)1
6
7
8
Superior C ourt o f W ashington

County o f Pierce
9
10
11

No.
12
Petitioner,
10-3-00961-1
13
and
JUD G M EN T A N D ORDER TO
PAY
14
(Clerk's Action Required)
15
16
17
Respondent.
Garnishee Defendant
18
19
K JUDGM ENT SUMMARY

Judgment Creditor: JASON WILLIAM SHIPMAN
21
Garnishment Judgment Debtor (Garnishee): FRANCISCAN HEALTH SYSTEM

Garnishment Judgment Amount:
$1,808.13
22
23
Costs Judgment Debtor (Defendant): JENNIFER KAY SHIPMAN

Costs Judgment Amount (Costs & Attorney Fees):
$286.23
24
Judgments to bear interest at 12% per annum.
25
Attorney for Judgment Creditor:
JUDGMENT AND ORDER TO PAY P ag e -1
WPF GARN 01.0800 (7/2003); RCW4.64.030; 6.27.__
S:\C ASE S 1\Shipman, Jason disso\Gamishment\payorderemp.doc
DANIEL N. COOK
ORIGINAL
20

& COOK, P.S.
5920 100th St SW #25

Lakewood, WA 98499
253-581-0660
14138
7 /S /2 8 1 1
358333
II. BASIS
IT APPEARING TH A T Garnishee was indebted to Petitioner in the nonexempt
amount of $1,808.13; that at the time the Writ of Garnishment was issued, Petitioner
was employed by Garnishee, or Garnishee had in its possession or control funds,
personal property, or effects of Petitioner; and that Respondent has incurred
recoverable costs and attorney's fees of $286.23, it is NOW, THEREFO RE,
III. ORDER
ORDERED that Respondent is awarded judgment against Garnishee in the
amount of $1,808.13; that Respondent is awarded judgment against Petitioner in the
amount of $286.23 for recoverable costs; that Garnishee shall pay its judgment amount
to through the Registry of the Court, and the Clerk of the Court shall note receipt thereof
and forthwith disburse such payment to DANIEL N. COOK, Attorney for Respondent.
Garnishee is advised that the failure to pay its judgment amount may result in execution

& COOK, P.S.
AM.
JUL 0 7 2D11 RM.
DANIEL N. COOK, W S B 7 n m 8 6 6
JUDGMENT AND ORDER TO PAY Page - 2

WPF GARN 01.0800 (7/2003); RCW 4.64.030; 6.27.__
S:\CASESl\Shipman, Jason disso\Gamishment\payorderemp.doc

& COOK, P.S.
5920 100th St. SW#25
Lakewood, WA 98499
253-581-0660
1428&
1&&634
IN THE SU P ER IO R COURT O F W A SHING TO N, GOUTY OF PIERCE
Cause No. 10-3-00961-1

Petitioner(s) ,
SETTLEMENT CONFERENCE STATUS

vs.
[tfÊTTLEM ENT CONF HELD (STLCON)
[ ] SETTLEMENT CONF HELD-SETTLED
(STLCON)
[ ] FAILED TO APPEAR PARTY(IES) (SCR)
[ ] CANCELLED/STRICKEN (SCR)

Respondent(s) .
Assigned to Judge: ELIZABETH MARTIN

This case is set for TRIAL in Department 12 on 7/25/2011
Scheduled for hearing on Monday, July 11, 2011 at 4:00 p.m.
CONTINUED to________________________________ (date) a t __________________________ (time).
p tL iX ^ L ) p J U lS A k . J
NOTES:
HOLD FORM UNTIL HEARING

HELD OR CANCELLED
Rev. (3/04)
Judicial Assistant Dea Finigan
E-FILED
July 14 2011 8:56 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
IN THE SUPER IO R CO URT OF THE STATE OF W ASHINGTON


No. 10-3-00961-1
Petitioner(s),
NOTE FOR MOTION DOCKET
vs.

Respondent(s)
TO THE CLERK OF THE SUPERIOR COURT AND TO OPPOSING PARTY:

Name: Daniel N Cook
Address: 5920 100th St SW Ste 25 LAKEWOOD, WA 98499-2751
Phone: (253) 770-0808

Phone: (253) 581-0660
Please take notice that the undersigned will bring on for hearing a motion for:
Motion
Nature of Hearing: In Limine
Calendar: STEPHANIE A. AREND
CALENDAR DATE: Friday, July 22, 2011
9:00 AM
WORKING COPIES SHALL BE DELIVERED TO THE COURT PURSUANT TO PCLR 7 (a) (7)
PARTY SETTING HEARING SHALL CONFIRM BY NOON TWO COURT DAYS PRIOR TO HEARING
Submitted by:
DATED:
July 14, 2011.
Signed:
NAME:
TIMOTHY M. GREENE
Phone:
(253) 770-0808
WSBA#:
For:
17499
ADDRESS: 4115 S MERIDIAN

PO BOX 731063
PUYALLUP, WA 98373
Note for Motion Docket (ntmtsup.rptdesign)
1 of
e - f il e :
IN COUNTY CLERI
PIERCE COUNTY, W
July 14 2011 9
KEVIN SIC
COUNTY CL
NO: 10-3-0C
2
3
4
5

COUNTY OF PIERCE
6
7
In re : th e m a rria g e o f
8
NO.
J E N N IF E R K A Y S H IP M A N
9
P e titio n e r,
an d
10
11
1 0 -3-00961-1
P E T IT IO N E R S M O T IO N
I N L IM IN E T O E X C L U D E C E R T A IN
T E S T IM O N Y R E : P A R E N T IN G
R e sp o n d e n t.
12
P e titio n e r, th ro u g h u n d e rsig n e d co u n se l, m o v e s in lim in e to e x c lu d e th e te stim o n y o f H u n te r an d
13
T y le r S h ip m a n , th e p a rtie s 10 y e a r o ld a n d 16 y e a r o ld c h ild re n en tirely , a n d to e x c lu d e th e
14
te s tim o n y o f th e p a te rn a l g ra n d m o th e r o f th e ch ild re n , B e c k y R a m b o , re g a rd in g p a r e n ts
15
p e rfo rm a n c e o f p a re n tin g fu n c tio n s, th e c h ild re n s b o n d in g a n d a tta c h m e n t w ith b o th p a re n ts .
16
P e titio n e r h a s n o o b je c tio n to M s. R a m b o te stify in g re g a rd in g th e ab ility o f h e r s e lf an d
17
R e s p o n d e n t to c o o rd in a te b e fo re a n d a fte r sch o o l ca re fo r th e ch ild ren . P e titio n e rs co n c e rn s
18
a b o u t th e n a tu re o f th e te stim o n y she m o v e s to e x c lu d e co m e s fro m th e d e sc rip tio n o f te stim o n y
19
o f re s p o n d e n ts w itn e sse s, as sta te d in R e s p o n d e n ts W itn e ss L is t file d o n M a y 18, 2011.
20
21
22
Petitioners Motion In Limine To Exclude

Certain Testim ny Re: Parenting
1 f 2
LAWOFFICES OF GREENE &LLOYD, PLLC

Street Address: 4115 S. Meridian, Ste. B
Mailing Address: P. O. Box 731063
P u y a llu p , W ashington 983 73
P h : (253) 770-0808, F a x (253) 770-0 259
T rial is set fo r M o n d a y , Ju ly 25, 2011.
2
3
U n d e rs ig n e d co u n se l is a w are th a t m o tio n s in lim in e are n o rm a lly h e a rd o n th e d ay o f trial, b u t
in th e in s ta n t ca se h e h a s set th e m o tio n o n th e m o tio n s c a le n d a r b e c a u se o f P e titio n e rs co n c e rn
o f h e a rin g th e m o tio n o n tria l d ay w ith th e c h ild re n p re se n t re ad y to testify , w h ic h co u n sel
b e lie v e s w o u ld b e p o te n tia lly h a rm fu l to th e ch ild ren . In th e a lte rn a tiv e to d e c id in g th e m o tio n
to d ay , i f th e c o u rt fe els th a t th e m o tio n sh o u ld b e d e c id e d b y th e tria l ju d g e , p e titio n e r
re sp e c tfu lly re q u e sts in th e a lte rn a tiv e th a t th e c o u rt ru le th a t th e c h ild re n n o t b e b ro u g h t to c o u rt
to te s tify u n til th e tria l ju d g e ru le s o n th e m o tio n .
10
11
D a te d : Ju ly 14, 2011_________________
R e sp e c tfu lly su b m itted ,
G R EEN E & LLOY D, PLLC
12
13
/s / T IM O T H Y M . G R E E N E
T im o th y M . G re en e, W S B A # 1 7 4 9 9
A tto rn e y fo r P e titio n e r
Je n n ife r K a y S h ip m a n
14
15
16
17
18
19
20
21
22
Petitioners Motion In Limine To Exclude

Certain Testimony Re: Parenting
2 of 2
LAWOFFICES OF GREENE &LLOYD, PLLC

Mailing Address: P. O. Box 731063
P u y a llu p , W ashington 983 73
P h : (253) 770-0808, F a x (253) 770-0 259
E-FILE
IN COUNTY CLEI
PIERCE COUNTY,
July 15 2011
KEVIN ST
COUNTY C
NO: 10-3-C
3
4
5
6

COUNTY of PIERCE

9
10
Jennifer Kay Shipman,

Petitioner,
and,
11
12
Jason William Shipman,

Respondent.
NO. 10-3-00961-1
AGREEMENT (STIPULATION) RE:

RESPONDENTS WITNESS LIST;
PETITIONERS MOTION IN LIMINE
RE: WITNESSES STRICKEN
13
The parties agree that the children of the parties, Hunter and Tyler, will not be testifying.
14
The parties agree that the paternal grandmother, Becky Rambo, will not be testifying.
15
Petitioners motion regarding the testimony of the above parties, set for hearing on July 22, 2011,
16
is stricken.
17
DATE: July 15,2011.
18
OYD, PLLC
19
20
reene, WSBA #17499

Attorney for Petitioner Jennifer Shipman
21
22
AGREEMENT (STIPULATION) RE:

RESPONDENTS WITNESS LIST;
PETITIONERS MOTION IN LIMINE
RE: WITNESSES STRICKEN

Ph: (253) 770-0808, Fax (253) 770-0259
07-19-11
r-ii r r \
* JUL 18 2011 PM
:RCE COUNTY WASHINGTON
KEVIN Ô C K^junty Clerk

County of
______ ______________ deputy
In re:
No. 10-3-00961-1

Petitioner,
and
Respondents
Domestic Relations
Pre-Trial Information
Form

Respondent.
Date: July 15, 2011
Petitioner /Wife/Mother
Respondent/Husband/Father
Name: Jennifer Kay Shipman Age: 37
Name: Jason William Shipman Age: 38
Address: 2323 7thSt SE #B203

Puyallup, Wa 98374
Address: 8811 133rdstCtE.

Puyallup, Wa 98373
Date of Marriage: April 24, 1994
Respondents
Domestic Relations
Date of Seperation: February 27, 2011
f^
tl-v
tali
r. ~ 'A
I
_L
3BS x2 3
DEPENDENT CHILDREN:
Per Cent Res. Time
This Marriage
Prior Marriage Pet.
Resp.
Name:
Age:
Since
Tyler
16
Yes
no
80
20
8/24/10
Hunter
10
Yes
no
80
20
8/24/10
CHILD SUPPORT
L
NET INCOME
Petitioner
$4, J46.17
Respondent
$1868.10
SUPPORT
$460.96
The Respondent objects to modification of the Petitioners finacial declaration. The order that was filed
on June 30, 2011 is correct. The respondent has not filed for a motion at the time of trial,
So the Respondent furthers his objection to any modification.
Respondent's
Domestic Relations
Pre-Tnai Information
2. Tax exemption to be allocated as follows

Even years to the Mother Odd years to the Father, The mother already claimed tax exemption for 2010.
3. Exceptional support consideration:
Child care (daycare) has been ordered, the Respondent has requested that the requirement to pay
childcare expenses be removed under the right of first refusal concept. The respondent is available
To care for the children during the petitioners work hours. The petitioner has objected to this because of
the respondents choice of roommates. However the petitioner does not object to leave the the children
with the Respondend for regulary scheduled visitation in the same household.
The Respondent objects to changing the August 24th2010 order reguarding the childrens sports activities.
4. Retroactive Child Support.
The Petitioner has been over paid child support since May 1,2011. The respondent Requestes an order
applying this amount to futur support payments.
5. Summary of proposed residential arrangement for children.
The Respondent object, Requests full custody of the children. With visitation outlined in the
respondents Parenting Plan.
ATTACHMENTS
. Proposed Parenting Plan
.Finacial Declaration
PROPERTY DEVISION
The community home was foreclosed upon. The Petitioner was granted the use and primary care of the
home by the court on August 24th2010. The petitioner failed to make the payments on the home. The
Petitioners actions resulted in Loss of community property and equity.
The Responded Sold a 1991 Ford F-150 and a 1985 Toyota 4-Runner and actually earned 2,700 from
these vehicles. The petitioner traded in a 2007 Chevy 2500 hd and got a late model Mercedes benz.
Respondents
Domestic Relations
Pne-Tnal Information
^ .; ? I. t; j a
x m *2 x -x j e o i ,-?r7
The respondent claims that the 2009 tax return was used to pay community debt. The respondent gave
half of what was left to the petitioner.
Property Devision
The petitioner has other unlisted community property as follows.
Jewelry $20,000.00
Pool Table $1500.00
Antique Furniture - nick nacks $ 15,000.00
3 Dogs $3,500.00
15 guns $15,000.00
Pepsi Macine $1,000.00
Household Furniture $10,000.00
Dishes Small Aplfiances $2,000.00
Large Appliances $3,000.00
3 Plasma Televisions $2,500.00
Tools $5,000.00
Video Games $3,000.00
Computer $3,000.00
Camera Equipment $5,000.00
Stereo System $1,000.00
CCTV Securtity System $5,000.00
Race Equipment $10,000
Total: $105,500.00
Respondents
Domestic Relations
Pre-Tnal Information
Debt Devision
All commutiy debt was paid by the respondent with 2009 tax return. The respondent object to any other
debt obligation as it was obtained by the petitioner outside of the marriage.
Date: July 15, 2011
Se
ason Shipman
Respondents
Domestic Relations
I
10-3-00961-1
36786820
FNDCLR
07-19-11

C ounty of
In re
|C/l^
4-es
J) I?,
/0
No.
Petitioner,
and
A W p tvitu A
Respondent.
Name*
U r a *t
3 M
R ,/-'
[ ] Petitioner
^ [R e s p o n d e n t
(FNDCLR)
fy
~7
Date of Birth'

g/
Declarants Total Monthly Net Income (from 3 3 below)

Declarants Total Monthly Household Expenses (from 59 below)
Declarants Total Monthly Debt Expenses (from 5 11 below)
Declarants Total Monthly Expenses (from 5 12 below)
Estimate of the other partys gross monthly income (from 3 If below)
$_3 5 <5
$
$
n$
[ ] unknown

2 1
Occupation
22
The highest year of education completed
23
Are you presently employed? [ ] Yes

a If yes
1-e^.W/
(1)
I 2^
No
Where do you work Employers name and address must be listed on the
Confidential Information Form
Financial Declaration (FNDCLR) - Page 1 o f 6

WPF DRPSCU 01 1550 (6/2006) - R C W 26 18.220(1)
a otj i 3 3
j~^ _l j j-'. rr *
f
\
i
b If no
(2)
When did you start work there (month/year)7
(1)
When did you last work (month/year)?
(2)
(3)
What were your gross monthly earnings7

Why are you presently unemployed7
cXo /(
HI. Income Information

If child support is at issue, complete the Washington State Child Support Worksheet(s), skip Paragraphs 3 1 a n d 3 2
If maintenance, fees, costs or debts are at issue and child support is N ot an issue this entire section sh o u ld be
completed (Estimate of other partys income information is optional )
3 1
Gross Monthly Income

If you are paid on a weekly basis, multiply your weekly gross pay by 4 3 to determine your monthly wages
and salaries. If you are paid every two weeks, multiply your gross pay by 2 15. If you are paid twice
monthly, multiply your gross pay by 2 If you are paid once a month, list that amount below
Name
Name
Wages and Salaries
$ a o 7 .s tz -
Interest and Dividend Income
Business Income
Spousal Maintenance Received

From
Other Income
-e
f.
Total Gross Monthly Income (add lines 3 la though 3 le) $
g*
Actual Gross Income (YeaMo-date)
s2,o 7 5 ^

a
Income Taxes
FICA/Self-employment Taxes
c.
State Industrial Insurance Deductions
Mandatory Union/Professional Dues
s 3Y
Pension Plan Payments
f.
Normal Business Expenses
s IXXo
(add lines 3 2a though 3 2g)
Monthly Net Income (Line 3 If minus line 3 2h or

line 3 from the Child Support Worksheet(s))

WPF DRPSCU 01 1550 (6/2006) - RCW 26 18.220(1)
[>*JfilifaM
y^gi*1wy*yn
7 V 'i:~ )y T 'E i ."
V
\
34
i 4 4 *. 3
Miscellaneous Income
a
Child support received from other relationships
Ocher miscellaneous income (list source and amounts)
$ _________
$
$
$
c
Total Miscellaneous Income ( a d d
lin e s
4 a th ro u g h 3 4 b )
$
$
.t / S e e
3.5
Income o f Other Adults in Household
36
If the income of either party is disputed, state monthly income you believe is correct and explain below ;

4 1
Cash on hand
4.2
On deposit in banks
4.3
Stocks and bonds, cash value o f life insurance
4.4
Other liquid assets;

Monthly expenses for myself and
dependents are; (Expenses should be calculated for the
after separation, based on the anticipated residential schedule for the children)
5.1
Housing
..&
$ /3?r
Installment payments for other mortgages or encumbrances
Taxes
&
insurance (if not m monthly payment)
Total Housing
5.2
13
Utilities
Heat (gas
&
oil)
Electricity
Financial Declaration (hNDCLR) - Page 3 of 6
WPF DRPSCU 01 1550 (6/2006) - R C W 26 18 220(1)
(0 o , 0^-
3 - o o X -3 4
Telephone
$
$
$
$
Cable
Other
Total Utilities
5.3
fc>
Food and Supplies

Food for
persons
So
/ fc>Q
Meals eaten out

Other
j rj& -
Total Food Supplies
5.4
Children
Clothing
Tuition (if any)
Total Expenses. Children
5.5
$
M $
$ &
0
$
$h o #
T ransportation
4''g o
JC n
A o o **'
Parking
5.6
Health Care (Omit if fully covered)

Insurance
Uninsured dental, orthodontic, medical, eye care expenses
Total Health Care
5.7
Personal Expenses (Not including children)

Clothing
Hair care/personal care expenses

WPF DRPSCU 01 1550 (6/2006) - R C W 26 18 220(1)
Clubs and recreation

Education
Books, newspapers, magazines, photos
Gifts
Other
5.8
Miscellaneous Expenses
Other ______________________________________________
Other ______________________________________________
$ I S I S
5.9
Total Household Expenses
5 .1 0
Installm ent Debts Included in Paragraphs 5.1 Through 5.8
Creditor
(The total of Paragraphs 5 ! through 5 8)
Descnption
of Debt
Balance
^
Month of
JjfLast Payment
1 ? ____ _
uh J1 j f
if
f
5.11
Other Debts and Monthly Expenses not Included in Paragraphs 5.1

Through 5.8
Description
of Debt
Creditor
(W < e k /
Sill* <A-
/ . . / A ______
c*
Balance
________ p o o
Month of
Last Payment
a o if
_________iL ______
900
Amount of
M onthly
Payment
$
f oc> ^
$ lo p *
_______________ _
______________
________
________________ _
_________________
__________ __________
$_______
_______________ ___ _
___________________
___________ ___________
$ ________
_________________ __
____________________
_________________
__________ __________ $_______
_________________ ________________________ $
Total Monthly Payments for Other Debts and Monthly Expenses

W PF DRPSCU 01 1550 (6/2006) - RCW 26 18 220(1)
________
s______
%
i-j. J&Lft-Js
A 4
. ^
^.OX
a
JL
'\
-3
rinc
JGO
The cost o f this process sh all be allocated between the parties as follows.
[]
[]
JVo p etitio n er d *S
% respondent
based on each p a r ty s proportional share o f income from line 6 o f the child support
worksheets
as determined in th e dispute resolution process
The dispute resolution p ro cess shall be commenced by notifying the other party by [ ] written
request [ ] certified mail [ ] other*
In the dispute resolution p ro cess
(a)
(b)
(c)
(d)
(e)
[]
Preference shall b e given to carrying out this Parenting Plan.

Unless an em ergency exists, the parents shall use the designated process to resolve
disputes relating to implementation o f the plan, except those related to financial support.
A written record sh all be prepared o f any agreement reached in counseling or mediation
and o f each arbitration award and shall be provided to each party.
If the court finds th a t a parent has used or frustrated the dispute resolution process
without good reason, the court shall award attorneys fees and financial sanctions to the
other parent.
The parties have th e right o f review from the dispute resolution process to the superior
court
No dispute resolution process, except court action is ordered.
[]

There are the following o th er provisions:
Parenting Plan (PPP, PPT, PP) - Page 10 o f 11

WPF DR 01.0400 Mandatory (6 /2 0 0 8 )-R C W 26 09 016, .181, 187, 194
5.12
$ 3 Z lF
VI. Attorney Fees

6 1
Amount paid for attorney fees and costs to date
6.2
The source of this money was
6.3
F ees and c o s ts in c u rred to date*
64
A rra n g e m e n ts fo r atto rn ey fees and costs are
65
Other
s 756$'
I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and correct.
The follow ing financial records are being provided to the other party and filed separately with the court.
Financial records pertaining to myself.
dividual [ ] Partnership or Corporate Income Tax returns for the years
including all W-2s and schedules;
[ ] Pay stubs for the dates o f
[ j Other
Do not attach these financial records to the financial declaration. These financial
records should be served on the other party and filed with the court separately
using the seated financial source documents cover sheet (WPF DRPSCU
09.0220). if filed separately using the cover sheet, the records will be sealed to
protect your privacy (although they will be available to all parties in the case,
their attorneys, court personnel and certain state agencies and boards.) See G R
22 (C)(2).

WPF DRPSCU 01 1550 (6/2006) - R C W 26.18 220(1)
10-3-00961-1
36796824
07-19-11
PPP
IN c o u n t y t i l o
O FFICE

County of
[ ] In re the M arriage of:
[ ] In re the Dom estic Partnership o f
No. / O - 3 . 0 O f W - /
e.
o r -f-t. *
1^
Petitioner,
and
Respondent.
Parenting Plan
{4 Proposed (PPP)
[ ] Temporary (PPT)
[ ] Final Order (PP)
T his parenting plan is:

[]
[]
[]
^
the final parenting plan signed by the court pursuant to a decree o f dissolution, legal
separation, or declaration concerning validity signed by the court on this date or
d a te d ___________________________ .
the final parenting plan signed by the court pursuant to an order signed by the court on
this date or d a te d ____________________________ , w hich m odifies a previous parenting
plan or custody decree.
a tem porary parenting plan signed by the court
proposed by (nam e) T T /a s o n w'.II.'am.
Mn r

T his parenting plan applies to the follow ing children.
N am e
Age
iG
'T J ? j e s
^ k, P r * * \A

W PF DR 01 0400 Mandatory (6/2008)-R C W 26 09 016, 181; 187, .194
10

Under certain circumstances, as outlined below, the court may limit or prohibit a parent's
contact with the child(ren) and the right to make decisions for the child(ren).
2.1
^
[]
Does not apply.

The [ ] petitioners [ ] respondents residential time with the child(ren) shall be limited or
restrained completely, and mutual decision-making and designation of a dispute
resolution process other than court action shall not be required, because [ ] this parent
[ ] a person residing with this parent has engaged in the conduct which follows:
[]
[]
[]
2.2
Willful abandonment that continues for an extended period of time or substantial

refusal to perform parenting functions (this applies only to parents, not to a
person who resides with a parent).
Physical, sexual or a pattern of emotional abuse of a child
A history of acts of domestic violence as defined in RCW 26.50.010(1) or an
assault or sexual assault which causes grievous bodily harm or the fear of such
harm.
[]
Does not apply.

The [ ] petitioners [ ] respondents involvement or conduct may have an adverse effect
on the children)s best interests because of the existence of the factors which follow:
[]
[]
[]
[]
[]
[]
[]
Neglect or substantial nonperformance of parenting functions.

A long-term emotional or physical impairment which interferes with the
performance of parenting functions as defined in RCW 26.09.004.
A long-term impairment resulting from drug, alcohol, or other substance abuse
that interferes with the performance of parenting functions.
The absence or substantial impairment of emotional ties between the parent and
child.
The abusive use of conflict by the parent which creates the danger of serious
damage to the childs psychological development.
A parent has withheld from the other parent access to the child for a protracted
period without good cause.
Other:

WPF DR 01 0400 Mandatory (6/2008)-R C W 26 09 016, 181, 187, 194
.1 ~1~i- -LO
HI. Residential Schedule

The re s id e n tia l sched ule m u s t s e t forth w here the child(rert) shall reside each d a y o f the y e a r,
in c lu d in g p ro v is io n s fo r h o lid a ys, birth d a ys o f fa m ily members, vacations, an d o th e r sp e cia l
occasions, a n d w h a t contact th e child(ren) sh a ll have with each p a re n t P a re n ts are encouraged
to c re a te a re s id e n tia l s c h e d u le th at m eets the developm ental needs o f the child(ren) a n d
in d iv id u a l n e e d s o f th e ir fa m ily P a rag ra phs 3.1 through 3 9 are one w a y to w rite y o u r
re s id e n tia l s c h e d u le I f y o u do n o t use these paragraphs, write in y o u r ow n sched ule in
P a ra g ra p h 3 13.
3.1
[]

P rior to enrollm ent in school, the child(ren) shall reside with the [ ] petitioner
[ ] respondent, except for the following days and times when the child(ren) will reside
w ith or be with th e other parent:
from (day and tim e )______________________ to (day and tim e )_____________________
[]
[]
every w eek [ ] every other week [ ] the first and third week o f the month
the second and fourth week o f the month [ ] other:
from (day and tim e )_______________________ to (day and tim e )______________

[]
[]
3.2
every w eek [ ] eveiy other week [ ] the first and third week o f the month
School Schedule
Upon enrollm ent in school, the child(ren) shall reside with the [ J petitioner
M respondent, except for the following days and times when the child(ren) will reside with or be
w ith the other parent'
from (day and tim e)
[]
[]
to (day and tim e)
eveiy w e e k ^ every other week [ ] the first and third week o f the month
From (day and tim e)

[]
[]
3 &Q
to (day and time)
every w eek [ ] every other week [ ] the first and third week o f the month
the second and fourth week o f the month [ ] other

WPF DR 01 0400 Mandatory (6/2008)-R C W 26 09 016, 181, 187, 194
& 'Q
[]
3.3
The school schedule w ill start when each child begins [ ] kindergarten [ ] first grade
[ ] other.
Schedule for W inter Vacation

The child(ren) shall reside w ith the [ ] petitioner
respondent during w inter vacation, except
for the follow ing days and tim es when the child(ren) will reside with or be with the other parent
I
ah.
3.4
^
fW
)r I i 11
oM
/W
&V4_<a

The child(ren) shall reside with the [ ] petitioner [ ] respondent during other school breaks,
except for the following days and times when the child(ren) will reside with or be with the other
parent:
/
3.5
. *3)
Sum m er Schedule
Upon completion o f the school year, the child(ren) shall reside with tine [ ] petitioner
respondent, except for the following days and times when the child(ren) will reside with or be
Same as school y ea r schedule.
O ther
k<ilf
7" W
& >ry
of
Waif 3.6

^4[]
Does not apply

The schedule for vacation with parents is as follows

WPF DR 01 0400 Mandatory (6/2008) - RCW 26 09 016, 181, 187, 194
w /f W
{a
yioj-hes
Second
3 0 0 i'i
r~
\\
3.7

The residential schedule fo r the child(ren) for the holidays listed below is as follow s1
With Petitioner
(Specify Y ear
O dd/Even/Every)
With Respondent
(Specify Year
Odd/Even/Every)
6 OP
New Y e ars Day

M artin L uther King Day
P residents Day
M em orial Day
July 4th
Labor D ay
V eterans Day
Thanksgiving Day
C hristm as Eve
Christm as Day
prr \/" cl
oO P
o D D
t2 \f <tv\
to V P
(n O D
o O P
o D P ____________
n DP
ft D P
oOP
&se>A
______ & \s e .n _________
______________
/ W W R M ________
__
o O D _____________
O O P _________
oO O
____Q P fi__________
F or purposes o f this parenting plan, a holiday shall begin and end as follows (set forth
tim es):
vnoasnlhf ,
pWxf- 4aKI c*\ a.
o\r <
{
H olidays which fall on a Friday or a M onday shall include Saturday and Sunday.
[]
3.8
Other:

The residential schedule fo r the child(ren) for the following special occasions (for example,
With Respondent
With Petitioner
(Specify Year
(Specify Y ear
Odd/Even/Everv)
Odd/Even/Everv)
A /
S
?i/evV
M others Dav
Fathers Day
f
{
fa frs r $
W tfY h A o -Y
ps
P t\(
B
l- fu rj T c /"
f]
f t *)
>\t^ W */'
^ X
B v
O ther

WPF DR 01 0400 Mandatory (6/2008) - RCW 26 09 016, 181; 187, 194
e ^ y e -V
o P f > _______________
____ o D j 2 . _______________
3.9

[]
[J
Does not apply b ecau se one parent has no visitation or restricted visitation.
Paragraphs 3.3 - 3 .8 , have priority over paragraphs 3.1 and 3.2, in the following order
Rank the o rd e r o f priority, with 1 being given the highest priority
3
[]
3.10
Other:
Restrictions
[]
3.11
7 holidays (3.7)
~7 special occasions (3 8)
1? vacation with parents (3 6)
w in te r vacation (3.3)
sch o o l breaks (3 4)
sum m er schedule (3 5)
Does not apply because there are no limiting factors in paragraphs 2 .1 or 2 2.

The [ ] petitioner s [ ] respondents residential time w ith the children shall be limited
because there are lim iting factors in paragraphs 2.1 and 2,2 The following restrictions
shall apply when th e children spend time with this parent:
There are lim iting factors in paragraph 2.2, but there are no restrictions on the
[ ] petitioners [ ] respondents residential time with the children for the following
reasons:
Transportation Arrangem ents

Transportation costs are included in the Child Support W orksheets and/or the Order o f Child
Support and should not b e included here.
Transportation arrangem ents for the child(ren), between parents shall be as follows'
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WPF DR 01 0400 Mandatory (6 /2 0 0 8 )-R C W 26 09 016, .181, 187, 194
r'ect ev/^
3.12
The children named in this parenting plan are scheduled to reside the majority o f the time with
the [ ] p e t i t io n e r ^ respondent. This parent is designated the custodian of the child(ren) solely
for purposes o f all other state and federal statutes which require a designation or determination of
custody. This designation shall not affect either parents rights and responsibilities under this
parenting plan.
3.13
Otherr
3.14
Sum m ary of RCW 26.09.430 - .480, Regarding Relocation o f a Child
S ^ i-
b-e.
This is a sum m ary only. For the full text, please see RCW 26 09.430 through 26,09.480.
If the person with whom the child resides a majority o f the time plans to move, that person shall
give notice to every person entitled to court ordered time with the child
If the m ove is outside the childs school district, the relocating person must give notice by
personal service or by m ail requiring a return receipt. This notice must be at least 60 days before
the intended move If the relocating person could not have known about the move in time to give
60 days notice, that person m ust give notice within 5 days after learning o f the move. The
notice m ust contain the inform ation required in RCW 26 09.440 See also form DRPSCU
07 0500, (N otice o f Intended Relocation o f A Child).
If the m ove is within the sam e school district, the relocating person must provide actual notice by
any reasonable means. A person entitled to time with the child may not object to the move but
may ask for m odification under RCW 26.09 260
Notice m ay be delayed for 21 days if the relocating person is entering a domestic violence shelter
or is m oving to avoid a clear, immediate and unreasonable risk to health and safety

WPF DR 01 0400 Mandatory (6/2 0 0 8 )-R C W 26 09 016, 181, 187, 194
If inform ation is protected under a court order or the address confidential it}' program, it may be
A relocating person may ask the court to waive any notice requirem ents that may put the health
and safety o f a person or a child at risk.
Failure to give the required notice may be grounds for sanctions, including contempt
If no objection is filed within 30 days after sendee of the notice of intended relocation, the
relocation will be permitted and the proposed revised residential schedule may be
confirmed.
A person entitled to tim e w ith a child under a court order can file an objection to the childs
relocation whether or not he or she received proper notice
An objection may be filed by using the m andatory pattern form WPF DRPSCU 07 0700,
(Objection to R elocation/Petition for Modification of Custody Decree/Parenting Plan/Residential
Schedule). The objection m ust be served on all persons entitled to tim e with the child.
The relocating person sh all not move the child during the time for objection unless: (a) the
If the objecting person schedules a hearing for a date within 15 days o f timely service of the
objection, the relocating p erso n shall not move the child before the hearing unless there is a
clear, immediate and unreasonable risk to the health or safety o f a person or a child.
(V. Decision Making

4.1
Day-to-Day D ecisions
Each parent shall make decisions regarding the day-to-day care and control o f each child while
the child is residing w ith th at parent. Regardless o f the allocation o f decision making in this
parenting plan, either parent m ay make emergency decisions affecting the health or safety o f the
children.
4.2
Major Decisions
M ajor decisions regarding each child shall be m ade as follows:
Education decisions
Non-em ergency health care
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[]
U
[]
[]
[3
[]
[]
[]
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
petitioner
[]
[3
[]
[]
[]
[]
[]
[]
[]

WPF DR 01 0400 Mandatory (6/2 0 0 8 )- RCW 26 09 016, 181, 187; 194
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
respondent
K
A
X
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[]
[]
[]
[]
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joint
joint
joint
joint
joint
joint
joint
joint
joint
4.3

K
[]
Does not apply b ecause there are no limiting factors in paragraphs 2.1 and 2.2 above
Sole decision m aking shall be ordered to the [ ] petitioner [ ] respondent for the
following reasons:
[]
[]
[]
A lim itation on the other parents decision making authority is mandated by

RCW 26.09.191 (See paragraph 2 1)
Both parents are opposed to mutual decision making.
One parent is opposed to mutual decision making, and such opposition is
reasonably based on the following criteria:
(a)
(b)
(c)
(d)
[]
T h e existence o f a limitation under RCW 26 09.191;

T h e history o f participation o f each parent in decision making in each of
th e areas in RCW 26.09.184(4)(a);
W hether the parents have demonstrated ability and desire to cooperate
w ith one another in decision making in each o f the areas in
R C W 26.09.184(4)(a); and
T he parents geographic proximity to one another, to the extent that it
affects their ability to make timely mutual decisions.
There are lim iting factors in paragraph 2.2, but there are no restrictions on mutual
decision making fo r the following reasons:
The p u rp o s e o f this d ispute re s o lu tio n p ro ce ss is to resolve disagreem ents about carrying out
this p a re n tin g p la n This d is p u te re solu tion p ro c e s s may, an d u n d e r som e lo cal c o u rt rules o r
the p ro v is io n s o f th is p la n m u s t be u se d before filin g a petition to m o d ify the plan o r a m otion for
contem pt fo r fa ilin g to fo llo w th e p la n
[]
D isputes between the parties, other than child support disputes, shall be submitted to (list person
or agency)
counseling by
*_/
Levite'S
& ^^
^ ^
[]
m ediation by ________________________________________, if this box is checked and

issues o f dom estic violence or child abuse are present, then the court finds that the victim
requested m ediation, that mediation is appropriate and that the victim is permitted to
haye a supporting person present during the mediation proceedings, or
[]
arbitration by
________________________________________
Parenting Plan (PPP, PPT , PP) - Page 9 of 11

WPF DR 01 0400 Mandatory (6 /2 0 0 8 )-R C W 26 09 016, 181, 187, 194
[]
D oes not apply

(O nly sign if this is a proposed parenting plan.) I declare under penalty o f perjury under the laws
o f the state o f W ashington that this plan has been proposed in good faith and that the statements
in Part IT o f this Plan are true and correct.
Date and Place o f Signature
Petitioner
at
w/y
Date and Place o f Signature
ispondent

It is ordered, adjudged and decreed that the parenting plan set forth above is adopted and approved as an
order o f this court.
W A R N IN G : Violation o f residential provisions o f this order with actual knowledge o f its term s is
punishable by contem pt o f court and may be a crim inal offense under RCW 9A 40.060(2) or
9A.40.070(2). Violation o f this order may subject a violator to arrest.
W hen m utual 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 o f this plan, the other parents obligations under the plan are
not affected.
Dated*_____________________________________
_________________________
Judge/Commissioner
Presented by:
Approved for entry.
Signature o f Party or Law yer/W SBA No.
Signature o f Party or Lawyer/W SBA No.
Print Name
Print Name

WPF DR 01 0400 Mandatory (6/2008)- R C W 26 09 016, 181, 187, 194
7^26^2815
1 4 4 8 ?
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IN THE SUPERIOR COURT OF WASHINGTON
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)
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,

Petitioner,
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and
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Respondent.
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CASE No.: 10-3-00961-1

Petitioners
Domestic Relations
Pre-Trial information
Form
F ILE D
A.H.
JUL 2 2 2011
PiaflGU6SMTY
Date: July 5, 2010.
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PETITION ER/WIFE/M OTHER:
RESPONDENT/HUSBAND/FATHER:
Name: Jennifer Kay Shipman
Name: Jason William Shipman Age: 38
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Age: 37
Address: 2323 7th St. SE #B203

Puyallup, WA 98374
Address: 881 1 133rd St. Ct. E.

Puyallup, WA 98373
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Date of Marriage: April 24, 1994
Date of Separation: Februaiy 27, 2010.
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Petitioners
Domestic Relations
Form 1

Street Address 4115 S Meridian
Mailing Address P O Box 731063
(253) 770-0808. Fax (253) 770-0259
6 / 2 4 3 J.1
14
1
2
DEPENDENT CHILDREN.
Per Cent Res. Time
This Marriage Prior Marriage
Name:
Age:
Tyler
16
yes
Hunter
10
yes
Pet.
Resp.
no
80
20
08/24/10
no
80
20
08/24/10
Since
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CHILD SUPPORT
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11
NET INCOME
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Petitioner
$ 4,146.17
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Respondent
$ 1,868.10
SUPPORT
$ 460.96 *
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*The child support of $ 460.96, which was entered as a revised temporary child support order on
June 21 and June 30, 2011 (June 21 being the date the child support was set by Commissioner
and June 30 being the date the order was filed), is based on respondents calculation of
petitioners net income of $ 4,636.22, instead of our calculation of $ 4,146.17. Petitioner did
not challenge this calculation, because she did not timely file her revised financial declaration,
but obtained language in the Commissioners order that she could move for a correction of
the child support order at the time of trial, based on the revised financial declaration. We are
accordingly presenting a settlement offer which includes a proposed corrected support figure
that we propose to be effective August 1, 2011, without retroactive effect. The child support
figure that we are proposing is $ 546.29, and is supported by the attached proposed
child support worksheets and attached financial declaration.
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Petitioners
Domestic Relations
Form 2
LAW OFFICES OF GREENE &LLOYD, PLLC

Mailing Address P 0 Box 731063
(253) 770-0808, Fax (253) 770-0259
7 r'ZffSZ&ll
3 .4 4 8 7
2 Tax exemptions to be allocated as follows;
Odd years to the mother and even years to the fathei or, as an alternative to the fathers
reluctance to pay for the childrens daycare and extracurricular expenses, the mother
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maybe willing to assume those expenses, but take the tax exemption every year.
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3. Exceptional support considerations;

Child care (daycare) expenses have been ordered to be paid on a proportionate basis by each
10
parent, and the mother wishes to keep it that way. The father recently petitioned to temporarily
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eliminate, the child care expenses, under the right of first refusal concept, until he obtains
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employment from his union hall or elsewhere, because he is available during the day to care for
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the children, having been laid off at the beginning of May. Mother is opposed to this because the
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father is now cohabiting with a girlfriend who has an admitted record of domestic violence
(burglary and malicious mischief) against her former boyfriend. This issue was reserved at the
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June 21 hearing on temporary orders for trial. Father has failed to pay daycare expenses, despite
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the presentation of daycare payment check carbon copies by the mother to the father via certified
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mail. Mother and her attorney are reviewing the mailing address for father that mother used
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because it may be incorrect. Nevertheless, the father owes the money.
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Petitioners
Domestic Relations
Form 3

Mailing Address PO Box 731063
(253) 770-0808, Fax (253) 770-0259
7 A 2 ^ 2 S :U .
1 -4 4 8 7
1
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Mother also objects to the language of the August 24, 2010 temporary order in this matter, under
which the father pays a proportional share of the costs of the boys organized sports activities, if
the parties agree in writing. In practice, the father has resisted sharing these costs Mother
5
wishes the language to be mandatory that the father pay a proportional share of the costs of the
boys organized sports activities and extracurricular activities that they may be involved in
On the other hand, as stated above, mother may be willing to waive expenses for the children if
the father agrees to waive income tax exemption for the children
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4. Child support currently being paid by father is $ 460.96/month, retroactive to May 1,2011.
(June 30, 2011 second temporary child support order).*
*The first child support order was entered on August 24, 2010 with a starting date of
September 1,2010. That order was based on fathers net income of $ 3,240.48, and
resulted in a transfer payment of $ 780.02. The second order was entered on account
of fathers unemployment as of May 1, 2011.
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5. Summary of proposed residential arrangements for children: The present parenting plan of
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visitation for father is visitation 5:00 p.m. Friday to Monday morning every other weekend
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and Wednesday evening from 5:00 p.m. to 8.00 p.m. every week Five weeks of summer
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vacation starting when school is out Miscellaneous holidays and special occasions.
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Petitioners
Domestic Relations
Form 4

Matting Address PO Box 731063
(253) 770-0808, Fax (253) 770-0259
S i
? * # s i i 1M n%? UtS
Mothei is concerned with this arrangement because of recent revelation that the fathers
significant other (cohabitating girlfriend) has a criminal record of domestic violence in which she
was convicted of burglary and malicious mischief, given that there is a shotgun and at least one
other weapon in the fathers home. The father also has not m the past respectfully responded to
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the mothers expression of hei concerns. At the very least, the mother would want leports
compliance by the girlfriend with the requirements of her sentence.
ATTACHMENTS:
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o
Proposed Child Support Order, Support Worksheets, and current Paystubs
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Complete Financial Declaration. Form WPF DR 01-055
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Proposed Parenting Plan
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PETITIONER INCOME:
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Employer
Length
Gross Income
Net Income
$ 5,845.38/mo
$ 4,214.68/mo.
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Franciscan Health
2 /2 mo.
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RESPONDENT INCOME:
Employer
Length
Gross Income *
Net Income *
Unemployed
2 V2 months
$ 2,075.67/mo.
$ 1,868.10/mo.
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*When employed, fathers gross income was $ 4, 299.00 a month, and his net income was
$ 3,240.48. Since father is dispatched to work from a union hall, we anticipate that he
will be returning to work at an income comparable to the income he had in his previous
employment.
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Petitioners
Domestic Relations
Form 5

(253) 770-0806, Fax (253) 770-0259
7^26^2811
Factors relating to award of maintenance:
Neither party is requesting maintenance
14487
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PROPERTY DIVISION:
5
The community home was foreclosed upon, and there was no deficiency judgment
The community property has already been divided
The wife is claims that the husband sold the communitys
1991 Ford F-150 and 1986 Toyota 4-Runner and earned $ 6,100 from those deals.
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Husband says he received $ 2,200, not S 6,100 for the vehicles, and used the money to buy a
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2002 Toyota Truck. The husband never filed a Financial Declaration, so it is unclear what
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vehicles he has (he has also kept a motorcycle), and what his payments, if any, are on them The
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wife has a Cadillac Escalade and she owes $ 30,000 on it.
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The wife also claims that the husband took the $ 12,281 2009 community tax return and spent the
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money, giving her only $ 790.45 out of it, when she was entitled to $ 6,140 of it. The husband
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claims he spent the money on paying down three credit cards, a personal loan from a friend,
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a house payment, and two months worth of power bills. (Please see Debt Division below).
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The wife withdrew her retirement money about five years ago when she was laid off as
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compensatory income for the community. She withdrew $ ______________ .
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She currently has $ ______________ in retirement monies in her account. It is unknown, how
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much, if any, funds the husband has in his retirement plans because the husband never filed a
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Financial Declaration.
Petitioners
Domestic Relations
Form 6

(253) 770-0808, Fax (253) 770-0259
7/
2 h s 2
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144B7
IB B
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Because the father never filed a Financial Declaration, it is unknown how much income his
significant other earns and whether that should be a factoi in settling this dissolution
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DEBT DIVISION*
5
The wife wishes that the husband agree to pay half of the unpaid community related bills that
accrued before the husband left the home. These bills are as follows.
Verizon cell:
Cable:
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Water.
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Garbage:
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House phone*
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Auto insurance:
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The credit cards on which the husband claimed he partially paid the outstanding balances with
the communitys 2009 tax return were a Frontier credit card, a Chase credit card, and a
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Home Depot credit card, with balances of $ 8,960.73, $ 6,885.62, and $ 6,737.80 respectively, as
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of the entry of the Temporary Order on August 24, 2010. The father presumably is assuming
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payment of these community debts, as the Temporary Order stated that each party was to be
21
responsible for their own debts after the date of August 24, 2010. The Mothers debts are Red
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Canoe Bank (financing for her Cadillac Escalade), her $ 8,000 Sallie Mae student loan, and her
Verizon cell phone, as well as attorneys fees.
Petitioners
Domestic Relations
Form 7

(253) 770-0808, Fax (253) 770-0259
7 S Z t-y 2& 1 1
1 .4 -4 IS 7*
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CONCLUSION
Despite the fact that the husband nevei filed a Financial Declaration, because of the fact that the
4
parties have a relatively simple asset and liability situation, resolution of this matter should be
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achievable at the Settlement Conference.
8
9
Much of the issues in this matter relate to the execution of the Parenting Plan, regarding
time and location of exchanges, situational bargaining between the parties over going off the
10
Parenting Plan for emergencies, holidays, special occasions. There is still much anger between
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the parties and they have yet to get involved in court ordered co-parenting counseling.
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Petitioners
Domestic Relations
Form 8

(253) 770-0808, Fax (253) 770-0259
10-3-00961-1
36820479
PIF
4 4 B?
07-25-11
IN THE SUPERIOR COURT OF WASHINGTON

Petitioner,
and
Respondent.
)
)
)
)
)
^
CASE No.: 10-3-00961-1

Petitioners Supplemental
Domestic Relations
Form
4. Child support: The modification the mother suggests is related to the parenting plan in terms
of joint decision-making regarding where the children go to school. This has been a hotly
contested area, and the mother was found in contempt in Februrary, 2011, over the issue of
where the children go to school. The mother points out that although the father wants the right
of first refusal to lower what he deems are unnecessary day-care expenses while he is
unemployed, the only reason why the younger boy, Hunter, is in daycare is because of the school
which Jason insists he go to, which is Woodland Elementary (all the schools named are within
the same school district). Woodland Elementary is the school that Hunter attended before the
mother moved out of the community home, leaving it vacant (it was subsequently foreclosed
upon), and into her present residence.
Domestic Relations
Form 1

Street Address' 4115 S Meridian, Ste. B
Mailing Address. P.O. Box 731063
Ph (253) 770-0808, Fax (253) 770-0259
2 .3 .&1
j. 4 4 3 3* 2 fee
From where mother presently lives, Hunter would attend Wildwood Elementary, according to
school district policy. The mother accordingly proposes, to save daycare expenses, that she be
allowed to place Hunter in the school in her present geographical area.
4
5
The father owes the mother his proportion of daycare expenses for the following dates, pursuant
to the August 24, 2010 temporary order: October 2010, November 2010, December 2010,
January 2011, February 2011, March 2011, April 2011, May 2011, and June 2011. The father is
ordered to pay a proportional amount of his earnings for the daycare expenses for Hunter.
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The father also did not pay daycare expenses for June, 2010, although he was not in violation of
n
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an order for not doing so. The reason why the father would arguably not be found in contempt for
13
violating the August 24 Order is that the mother may not have had the fathers mailing address
14
correct. However, the father was aware that the children were in daycare, so he bears some
15
responsibility for this failure to make payment.
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5. Summary of proposed residential arrangements for children: Mother wants a full

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background check done on fathers significant other Melissa. Presumably this means a JIS
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check. Mother also wants a copy of the police report taken on the incident leading to Melissas
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conviction for burglary and malicious mischief. Mother is concerned that there has been no
22
evidence presented that Melissa underwent any anger management counseling after her
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conviction. Mother also wants information on Jasons guns, as she is concerned about their
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involvement in any domestic violence situation (at this point, potentially involving Melissa).
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Domestic Relations
Form 2

Street Address 4115 S Meridian, Ste B
Ph (253) 770-0808, Fax (253) 770-0259
ZB i X
The mother wants the make, model, and serial number of the guns and proof they are in his
mothers home, as he has stated The mother is concerned that the father bought 9 year old
Hunter a gun (the mother had disapproved of this purchase) and the father has yet to enroll
Hunter in a gun safety course.

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6
7
Mother is also concerned that Melissa has a 16-17 year old boy that has been suspended from
school for truancy/insubordination, and has impregnated his girlfriend. She is concerned about
his potential influence on Tyler, the parties 16 year old boy, who has delinquency issues of his
10
own . At this point, again, the mother wants communication from the father, perhaps what steps
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the father and Melissa are taking to educate this boy on responsibility, as the mother is doing in
working with Tyler.
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There are no detailed specifications for visitation exchanges in the parenting plan. At the present
time, the exchanges are taking place at the parents house for the father. This has proven
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inconvenient for the paternal grandfather, as the mother picks up the children at 8:00 p.m., and
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the paternal grandfathers bedtime is shortly after 8:00 p.m. Accordingly, if the mother is a few
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minutes late, which unfortunately happens on occasion, as she attends an evening support group,
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it upsets the paternal grandfather, and creates tension between the parties. The mother proposes
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an exchange point to be written into the parenting plan, and one that would be a commercial
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business parking lot. She suggests Sharis on Meridian, which is next to Top Foods.
Domestic Relations
Form 3

Street Address 4115 S Mendian, Ste. B
Ph (253) 770-0808, Fax (253) 770-0259
S a fi
The mother also would like to tweak the parenting plan as far as holiday visitation exchanges.
Holiday visitation is from 8 a.m. to 10 p.m. Often the mother, being a nurse, has to work on
holidays. She has to be at work at 7 a.m. In the past, the father has threatened to call the police if
the mother did not adhere to the plan, which has forced her to take family crisis time off of
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work. For the Fourth of July, the mother suggests that the visitation be extended on that day to
midnight, in order that the children can enjoy the fireworks and the holiday with one parent.
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PROPERTY DIVISION:
10
RetirementHusband and wife both cashed out their retirement fund once during the marriage.
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At the time of separation, wife had around $ 2,000 in retirement, and husband had around
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$ 21,000. The wife proposes a 50/50 split of the retirement funds, which would probably be
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accomplished most easily by a Qualified Domestic Relations Order giving the wife $ 9,500 of
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the husbands retirement.
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Vehicles: The 4-runner for the husband was purchased with funds from the cash-out of the wifes
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retirement fund for $ 4,000. The husband then sold it for $ 4,500 cash. He also sold the Ford F-
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150 for $ 600, and kept the money. The wife wants $ 2,550 from the husband.
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Domestic Relations
Form 4

Ph (253) 770-0808, Fax (253) 770-0259
7 '
2 {)''7 , 8
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Miscellaneous Personal Property: The wife notes that the husband took the bulk of big-ticket
community property items when he moved out, primarily a 23 enclosed trailer purchased for
$ 4,000, a 10 enclosed trailer purchased for $ 2,000 (see Frenchys loan under Debt Division), a
mountain bike purchased for $ 1,700, a hot tub purchased for $ 4,106, a bow flex purchased for
5
$ 1,800, 2 race cars, 5 go karts, an engine tool (aka cherry picker) purchased for $ 800, a
video camera purchased for $ 800, guns, stainless steel bbg, GPS, numerous tools, and hunting
and camping gear. The wife notes that the husband accrued considerable airline mileage on his
credit cards, and although those miles are probably not transferable, she notes this is a
10
community benefit which he retains exclusively.
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Items Personal to Wife: The husband took all of the photo albums, which includes pictures of
14
wife's family including pictures of the parties children. The wife wants all pictures of her family
15
back and half of the pictures of the parties children.
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The husband took the wifes grandfathers pocket watch which dates from the late 1800s-early
1900s. He also took the wifes wedding ring.
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Domestic Relations
Form 5

Ph (253) 770-0808, Fax (253) 770-0259
7 / 2 6 /2 8 1 1
44B
DEBT DIVISION:
Credit Cards: The wife wishes to correct the balances stated in her Petitioners Pre-Trial
Domestic Relations Information Fonn for the three credit cards that the husband said that he paid
off, the Frontier, Chase, and Home Depot credit cards. The actual balances, according the wife,
5
were between $ 1,000 and $ 3,000 on each card, not the amounts stated.
8
9
Frenchys Personal Loan to Husband: This money was used to buy the 10 enclosed trailer
that is now in the possession of the husband.
10
11
12
IRS garnishment: The IRS took $ 2,376.40 out of the wifes tax refund this year (since she
13
filed first) for a mistake made on the communitys 2008 tax return. The husband owes the wife
14
half of the money for that deduction, or S 1,188.20.
15
16
Wifes Saliie Mae student loan repayment: The loan, with a current balance of $ 8,000,
17
18
19
enabled the wife to earn a nurses salary, which benefited the marital community for several
years. The wife is asking that the husband to pay back $ 4,000 of that loan.
20
21
22
23
24
25
26
Domestic Relations
Form 6

Street Address 4115S Meridian, Ste B
Mailing Address. P O Box 731063
Ph (253) 770-0808, Fax (253) 770-0259
8 ^ 1 ^ 2 8 1 -1
10-3-00961-1
36855444
14S7S
CFR
Fujij^meadiness Checklist-for Reassignment
JENNIFER KAY SHIPMAN VS JASON WILD

SHIPMAN
Cause No 10-3-00961-1
Dissolution with Children
Plaintiff/Petitioner Counsel:
Defendant/Respondent Counsel:
ROBERT D LLOYD
253-770-0808
Additional Counsel (Name and phone number)
Daniel N Cook
253-581-0660
Self-Represented* Petitioner/Respondent?
1
2.
Original Trial Department: RONALD E CULPEPPER Trial Date.7/26/2011 10 00 00 AM

Case age 499 Continuances 0 Jury size
Counsels Trial Length Approximation &
Settlement Conference held (date)? 7/11/2011 4 00 00 PM

Settlement Conference Judge MARTIN, ELIZABETH
Alternative Dispute Resolution hearingîeld?
(Yes) (No)
_days
(unknown) Date
Guardian Ad litem Report filed |YsJ ^(N o)/
(unknown) Date Filed_______
Parenting Seminar Completecj^ Y es)
If No", waiver signed? (Yes)
7.
Joint Statement of Evidence filed (Date)?___
Priority Status?
Any consideration for giving this case priority?
Recommend case for Trailing Docket for
10
Readiness remarks
(No)
(No)
days?
Judge/JA
Reassignment
at
5S243
The above entitled case is reassigned for Trial to Dept No

Judge
______________________ , this _______day of_______
AM/PM. All parties are to report immediately to the above Judge for trial
, 20
tetunp to department for:
Trial/Motion to Continue / Case Settled / Parties FTA / Unable to Assign / Form Incomplete
fading of the Record / Formal Proof / Motion for Default / No Settlement Conference Held
All parties DID / DID NOT comply with Rule
PRIORITY SETTING IS / IS NOT recommende
Days.
(3) by waiting Jntil properly excused

trrfled for: n
]2cDays [
ftC 4 < o
Calen
Last update January 27, 2010
]3
ii
Additional Counsel (Name and phone number)
Self-Represented Petitioner/Respondent?
1
2
Original Trial Department. STEPHANIE A AREND Trial Date 7/25/2011 9 00 00 AM

Case age: 494 Continuances 0 Jury size:
Counsels Trial Length Approximation^
4.
Settlement Conference held (date)? 7/11/2011 4.00 00 PM

Settlement Conference Judge MARTIN, ELIZABETH
(Yes) (No)
Alternative Dispute Resolution hearing held?
days
(unknown) Date___
5.
Guardian Ad litem Report f\\e6^[ye^ a
(unknown) Date Filed___________
6.
Parenting Seminar Completes? (YespVNo)
If No", waiver signed? (Yes)
Joint Statement of Evidence filed (Date)?___________________________________
Priority Status?
Any consideration for giving this case priority?______________________________
Recommend case for Trailing Docket for 3
10
Readiness remarks______
days?
(No)
(jY e s fo (No)
Reassignment
e$Wor/Trial to
se is reassigne
q L Ij >day c
I parties are to report immediately Yc^he above
Return to department for:
Trial / Motion to Continue / Case Settled / Parties FTA / Unable to Assign / Form Incomplete
Reading of the Record / Formal Proof / Motion for Default / No Settlement Conference Held
All parties DID / DID NOT comply with R ule/0
PRIORITY SETTING IS / IS NOT recommende^jSi
Days.
Cale
Last update January 27, 2010
[3) by waiting
trilled for: [
^1 properly excused
*y 'I
]2 Days [
]3
& /iszers
.1.
fN THE SUPERIOR COURT, PIERCE COUNTY, WASHINGTON

Cause Number
10-3-00961-1
Petitioner(s)
vs
Page 1 of 3

Respondent(s)
Judge/Commissioner RONALD E. CULPEPPER
Court Reporter KARLA JOHNSON
Judicial Assistant/Clerk ANGELA EDWARDS
ROBERT D LLOYD
TIMOTHY M GREENE
SHIPMAN, TYLER
SHIPMAN, HUNTER
Proceeding Set Trial

Proceeding Outcome Non-Jury Trial
Resolution
Outcome Date 07/27/2011 16 38
Clerk's Scomis Code:NJTRIAL

Proceeding Outcome code NJTRIAL
Resolution Outcome code
Amended Resolution code
Report run date/time 07/27/11 4 38 PM

Ixcalcivtl pbl d_civiljoumal_report_cover
S 2 r-

Cause Number 10-3-00961-1

MEMORANDUM OF
JOURNAL ENTRY
vs
Page 2 of 3
Judge/Commissioner
RONALD E CULPEPPER
MINUTES OF PROCEEDING
Start Date/Time: 07/27/11 1:52 PM
Court reconvenes Trial commences in Dept 17.

Atty Greene presents a packet of documents that were given to respondent on 7/25/11
(customer receipt from lens crafters; IRS Refund document; Sallie Mae student loan
document, Statement of Earnings Detail) marked as PET EXH #1.
Respondent voices his objection to the Lens Crafters receipt.
01:55 PM Petitioner
July 27, 2011 01:51 PM
02 07 PM Opening statements by pro se

respondent.
02.12 PM PET WIT Jennifer K. Shipman, sworn/testified under direct
examination by Atty Greene. 02:23 PM Court takes a brief break to allow Judge Culpepper
to assist in taking a verdict in Dept 11.
opening statements bv Attv Greene.
End Date/Time: 07/27/11 2:23 PM
Court Reporter.KARLA JOHNSON
July 27, 2011 02:49 PM Court reconvenes. PET WIT Jennifer Shipman retakes the stand,
direct exam continues 03:10 PM Cross examination by respondent.

03:19 PM Re-direct by Atty Greene. 03:20 PM Follow up inquiry by respondent.
0323 PM Court inquiry of witness for clarification. 03:30 PM Follow up inquiry by resp and
counsel
03 32 PM RESP WIT Jason W. Shipman, respondent, testifies under oath.
03:48 PM Cross exam of respondent by Atty Greene
03:56 PM Atty Greene asks
permission to recall his witness for a couple questions - granted. PET WIT Jennifer K
Shipman reminded of oath and responds to further inquiry by Atty Greene. 03:59 PM
Continued cross of respondent by Atty Greene.
04:01 PM Petitioner closing arguments by Atty Greene. 04:11 PM Court rules: Visitation
exchange will be done at Grandmother's house (respondent's mother).
Nine year old son shall be enrolled in gun safety course w/in 10 days of today.
JUDGE/COMMISSIONER RONALD E CULPEPPER Year 2011
* *


MEMORANDUM OF
JOURNAL ENTRY
vs
Page: 3 of 3
Judge/Commissioner
RONALD E CULPEPPER
________________________________ MINUTES OF PROCEEDING______________________________
04:13 PM 4th of July visitation hours addressed

04:18 PM Closing argument by
respondent. 04:27 PM Rebuttal argument by Atty Greene. 04:29 PM Court adjourns for
the day; court will need time to review. Atty Greene offers PET EXH #1 and PET EXH #2 granted ; Court decision set for tomorrow at 10am.
8 ^ 1 ^ 2 8 1 1 1 ^ 5 2 5 SS024.8
1 0 -3 -0 0 9 6 1 -1
36Br>5468
CME
07-29-11

Cause Number
Petitioners)
10-3-00961-1
vs
Page 1 of 3

Respondent(s)
Judge/Commissioner RONALD E CULPEPPER
Court Reporter LESLIE THOMPSON
ROBERT D LLOYD
TIMOTHY M GREENE
SHIPMAN, TYLER
SHIPMAN. HUNTER
Proceeding Set Trial

Proceeding Outcome
Resolution.
Outcome Date
Clerk's Scomis Code:
Proceeding Outcome code

Resolution Outcome code*
Report run date/time 07/27/11 10 23 AM
Ixcalcivtl pbl d_civiljournaljroport_cover
B ^ j U J2 I l
14S7S


MEMORANDUM OF
JOURNAL ENTRY
vs.
Page 2 of 3
Judge/Commissioner
RONALD E CULPEPPER
________________________________MINUTES OF PROCEEDING_______________________
Atty Tim Greene present on behalf of petitioner. Petitioner not

here today; unable to get off work. This case has been trailing in admin since yesterday and
yesterday was the only available day she had. Respondent present pro se. 10.35 AM
Parties addressed the court Atty Greene moves for a continuance; respondent objects
10:36 AM Atty Greene will check with his client re her availability for tomorrow. Atty Greene
advises court of case issues. 10.38 AM Respondent addresses court re his late notice/
petition to be primary residential/custodial parent (filed the day after settlement conference).
10:43 AM Reply response from Atty Greene. 10:52 AM Court addresses parties re this
July 26, 2011 10:31 AM
late development and how to proceed. 10:58 AM Due to new issue that has arisen (that
apparently original trial department did not have knowledge of) court finds this matter is not
ready for trial and a GAL should be appointed. Court reviews respondent's petition filed
7/18/11. 11:01 AM Respondent addresses court re possible visitation suggestions in order
to resolve this case today. 11.02 AM Atty Greene objects to any parenting plan issues
being decided today as his client is not present. 11.07 AM Court will recess this trial until
tomorrow at 9:30 a.m. whether petitioner is here or not.
Court Reporter.LESLIE THOMPSON
Court reconvenes on this matter. All parties present. Court will

not be able to commence trial today due to a criminal trial assigned.
After argument, court directs that minor "Hunter" will remain in Wildwood Elementary and
minor "Tyler" will attend Rogers High School for the remainder of the year. Court sends
matter back to administration to continue trailing.
July 27, 2011 10:00 AM


MEMORANDUM OF
JOURNAL ENTRY
vs
Page 3 of 3
Judge/Commissioner.
RONALD E CULPEPPER
___________________________ MINUTES OF PROCEEDING___________________

z s .ti
10-3-00961-1
36855470
TRMM
ssiB ss-a
0 7 -2 9 -1 1
2
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7
8
)
)
)
)
)
)
)
)
)
9
10
JENNIFER SHIPMAN,
Petitioner,
11
And,
12
JASON SHIPMAN,
____________ Respondent,
Case No.: 10-3-00961-1

PETITIONERS TRIAL MEMORANDUM
13
I. INTRODUCTION
14
15
16
17
18
19
20
21
22
Petitioner is 37 years of age, and respondent is 38 years of age. The parties separated after 16
years of marriage, the date of marriage being April 24, 1994, and the date of separation being
February 27, 2010. Petitioner is a nurse, and has been so employed for 10 years; until recently
respondent was employed as an installation and maintenance technician and had been so
employed for seven years (respondent was laid off on May 1, 2011, but hopefully his active
union hall membership will enable him to find another job shortly). When respondent was
employed, the parties had comparatively equal incomes, with petitioner slightly ahead
(respondent had been earning 41.14% of the total income, and petitioner had been earning
r -=
58.86 % of the total).
Petitioners Trial Memorandum
crv
1 of 10

Street Address: 4115 S Meridian, Ste B
Mailing Address: P O. Box 731063
Ph (253) 770-0808, Fax (253) 770-0259
8^1^2841
1_4?5 ,5S
The parties have two boys, Tyler, who is 16 years of age and will be turning 17 years of age next
month, and Hunter, who is 10 years of age. Petitioner has been the primary residential parent
throughout these proceedings.
4
5
Petitioner lives in the southern part of Puyallup, and respondent lives in South Hill. The parties
live (by undersigned counsels estimate) between 2 Vi miles to 3 miles from each other.
Both parties vacated the community home, the respondent having vacated first, at the time of the
parties separation on February 27, 2010, and the petitioner having vacated in the beginning of
October, 2010. Both parties moved to a location within 2 Vi to 3 miles of the community home,
10
which had been close to the boundary line between Puyallup and South Hill. The house was
11
foreclosed upon in April, 2011 without any deficiency judgment. There was little, if any, equity
12
in the home. Both parties now live in multi-bedroom rental units.
13
14
The parties separated by the respondent moving out of the community home to a temporary
15
residence, and then informing petitioner that he had moved, on February 27, 2010.
16
17
18
19
20
21
22

Street Address. 4115 S Meridian, Ste B
Mailing Address. PO. Box 731063
Ph (253) 770-0808, Fax (253) 770-0259
&
5 5 *
II. PROCEDURAL HISTORY
1
2
Petitioner filed and served her petition, financial declaration and proposed child support
worksheets, and proposed parenting plan on March 15, 2010. She was represented by
undersigned counsel at that time, and has been so represented ever since. No proposal for the
division of property and liabilities was laid out in the petition.
6
7
Respondent filed his response on March 31, 2010. He indicated that he would prefer mediation
for property division instead of a court proceeding , that the child support worksheet should be
modified to fathers actual income, and that child support covers all expenses to support the
10
children including daycare. His only objection to the parenting plan proposed by petitioner is
11
that he wanted six weeks of summer vacation with the boys.
12
13
The parties initially attempted an amicable dissolution without court process, but by summer the
14
parties decided to resort to the court process. Respondent retained counsel and the parties
15
were in court for a hearing on a temporary order on August 24, 2010. Respondent indicated that
16
he generally agreefd] with the proposed [parenting] plan, but wanted more time with the boys
17
in the summer. His primary dispute with petitioner was over division of property and petitioner
18
falling behind in the payment of house payments.
19
20
21
22

Ph: (253) 770-0808, Fax (253) 770-0259
1
2
A temporary parenting plan was entered which gave respondent additional time in the summer
with the boys and some additional time on his regularly scheduled visitation. A temporary child
support order was also entered. The petitioner was also ordered to make the monthly mortgage
payments on the home.
6
7
Petitioner, however, was unable to make the house payments and petitioner further was unable to
stop mold growing in the family home. She moved out to her present location, and continued to
try to sell the home (as apparently did respondent). Neither party was successful, and the house
10
was foreclosed on in April, 2011. Petitioner moved within the same school district, but the boys
11
were now in different schools as a result. Petitioner was found in contempt for this (although she
12
and undersigned counsel maintained that they had notified respondent and respondents counsel
13
about the move), and petitioner was ordered to put the boys back in the schools that they were in
14
before they moved, which she did.
15
16
Respondent was laid off on May 1, and moved to modify the child support schedule accordingly.
17
His attorney withdrew shortly thereafter. Petitioner did not oppose this move, and a modification
18
was granted, retroactive to May 1, at a June 21 hearing. However, petitioner did oppose the
19
respondents request that he be given a right of first refusal to supervise the boys in lieu of
20
daycare, since he was unemployed. Petitioner opposed that request, for reasons that she will
21
advise the court of in her testimony.
22

Street Address- 4115 S Meridian, Ste B
Mailing Address P O. Box 731063
Ph. (253) 770-0808, Fax (253) 770-0259
$4S
/r.
The court on June 21 reserved the right of first refusal issue for trial. It also reserved a permanent
decision on the child support issue, for the period starting August 1, until trial (see below).
3
4
Respondent, on July 18, filed for the first time, a proposed parenting plan making him the
primary residential parent, and a financial declaration.
III. ISSUES
7
8
The parties have different proposals for parenting plan, child support, and division of property
and liabilities.
10
Child support: Petitioner filed a modified financial declaration with sealed financial documents,
11
which reflects her slightly lower income at present, on June 15. This document was not filed in
12
time for the June 21 hearing, and, according to the proposed child support worksheets which
13
were served on respondent at the settlement conference, the correct child support should be
14
$ 546.29, due to a slight reduction in hours, rather than the $ 460.96 that respondent is presently
15
paying.
16
17
Petitioner also wants reimbursement for daycare expenses that the respondent has not paid for the
18
months of September 2010, part of February 2011, March 2011, April 2011, May 2011, and
19
June, 2011. Daycare is $ 200/month and respondent was ordered in the child support orders to
20
pay an amount proportional to his income.
21
22

Street Address. 4115 S Meridian, Ste. B
Mailing Address' P.O. Box 731063
Ph (253) 770-0808, Fax (253) 770-0259
J .3 S 7 5
Sb
1
2
3
Respondent also has not paid any contribution for extraordinary health care expenses,
extracurricular activity expenses, and court costs (for Tyler) for the boys, despite the petitioners
request. (It is true that the August 24, 2010 temporary order states that respondent is only to pay
for extracurricular activities that he agrees to in writing; petitioner, however, wants this provision
changed, for reasons that will be stated in testimony).
8
9
Petitioner will propose, as an alternative to the respondent paying any expenses, besides basic
10
daycare and his unions health insurance, that petitioner pay 100% of daycare, extracurricular
11
activity expenses, and extraordinary health expenses, provided that she is awarded the sole
12
income tax exemption for the boys as dependents.
13
14
Petitioner is opposed to the right of first refusal provision for several reasons, which in
15
summary are: concern about respondents girlfriend, who has a recent domestic violence burglary
16
on her record, from supervising Hunter every day; the complications in daily visitation
17
exchanges, morning and afternoon, for the limited amount of daily time Hunter is in daycare;
18
and the fact that Hunter would not need daycare if he is allowed to attend the neighborhood
19
school he is assigned to, rather than the school he was ordered to attend in the contempt motion.
20
21
22

Street Address 4115 S Meridian, Ste. B
Mailing Address - P O. Box 731063
Ph: (253) 770-0808, Fax (253) 770-0259
13' 1 ^ 2 8 1,1
19575
1
2
Parenting plan: Petitioner wishes to make only slight modifications in the August 24 temporary
parenting plan, which makes her the primary residential parent and gives respondent visitation
every other weekend through Monday morning, every Wednesday evening, and extra time on
school breaks, selected holidays and special occasions, and five weeks every summer (petitioner
also has the children five weeks every summer).
7
8
Petitioner notes that respondent is moving for a change in primary residential parent, five days
before trial without asserting limiting factors and without having had a guardian ad litem
10
appointed, and she strenuously opposes such a change.
11
12
13
Petitioner is suggesting, as modification, the following:

(i)
That respondent provide full disclosure regarding his girlfriends domestic violence
14
burglary conviction, including a copy of the police report; that his girlfriend attend an
15
anger management course, and that respondent keep petitioner informed on how he
16
and Melissa are dealing with the truancy issues and other issues of her teenage boy,
17
who has issues similar to the parties older boy Tyler.
18
19
(ii)
That respondent disclose the make, model, and serial number of all guns in his
20
possession, and proof that he is storing them at his mothers home. That
21
respondent enroll Hunter in a gun safety course, since respondent had bought Hunter
22
a gun.

Street Address 4115 S, Meridian, Ste. B
Mailing Address P.O. Box 731063
Ph (253) 770-0808, Fax (253) 770-0259
S ' t-'Z B lk
*' 7S
55 8250
(iii)
That a location for visitation exchanges be specified in the parenting plan, and
that the location be a restaurant in an accessible location, so that the boys dont have
to wait outside.
(iv)
That visitation on holidays start at 6:30 a.m., rather than the present 8:00 a.m., since
petitioner, as a nurse, often works holidays and has to be at work at 7:00 a.m.
(Respondent would be given the option to start visitation at 8:00 a.m. on holidays
on which petitioner is not working, and a schedule of petitioners working holidays
will be given to respondent).
10
11
(v)
That 4th of July visitation be extended until midnight, so that the boys can
enjoy the fireworks without interruption.
12
13
14
Property division:
Personal propertyrespondent took most of the expensive big ticket items, and
15
petitioner is aware that some of these items were sold. Proceeds from sold items
16
should be divided 50/50.
17
18
VehiclesRespondent sold two of the communitys vehicles after separation
19
for $ 5,100. Petitioner wants the proceeds divided 50/50.
20
21
22
2009 tax returnrespondent gave petitioner only $ 790.45 from the $ 12,281 in
tax refund, and petitioner wants the proceeds or a judgment for $ 5350.
This demand may be modified if respondent can satisfactorily demonstrate

Street Address 4115 S. Meridian, Ste B
Mailing Address: P.O Box 731063
Ph (253) 770-0808, Fax (253) 770-0259
\
i
y 1 4 5 ?5
amounts that he paid for the communitys benefit.
2
3
RetirementThe parties had both cashed out their retirement once, and spent
the funds for community needs. Petitioner now has only $ 2,000 in retirement
and respondent has $ 21,000 in retirement. Petitioner proposes a 50/50 split
or, specifically, a Qualified Domestic Relations Order giving her $ 9,500
of respondents retirement at maturity.
8
9
10
11
Debt division: There are some debt division issues still not resolved.
12
13
Frenchys loanRespondent borrowed $ 2,000 from a friend and
14
repaid in full for a 10 foot enclosed trailer that was purchased by
15
respondent at the time of, or shortly before, separation, and taken
16
by respondent, never to be used by the community. Petitioner is
17
requesting a $ 1,000 reimbursement.
18
19
IRS refund deduction for community debtThe IRS took $ 2,376.40
20
out of petitioners tax refund this year for mistakes in the communitys
21
2008 tax return. Respondent owes the petitioner half of the money for
22
that deduction, or $ 1,188.20.

Street Address: 4115 S Meridian, Ste B
Mailing Address. P.O. Box 731063
Ph- (253) 770-0808, Fax (253) 770-0259
Sallie Mae student loan repayment: $ 5, 159 now owing. This loan paid
for schooling which allowed petitioner to contribute 10 years of nursing
salary to the community. Petitioner is requesting that respondent pay
back 50 % of what is currently owed, or $ 2,579.
5
6
7
8
9
10
Unpaid bills that respondent left petitioner with
11
When respondent left the house, he left behind bills for cell phone (Verizon), cable, water,
12
garbage, home phone, and auto insurance that petitioner paid. Respondent should
13
reimburse petitioner 50/50 for these bills.
14
15
Respectfully submitted this 25th day of July, 2011
16
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20
21
22
10 of 10

Street Address 4115 S Meridian, Ste. B
Mailing Address P.O. Box 731063
Ph (253) 770-0808, Fax (253) 770-0259
145?
10-3-00961-1
368554/4
WTRC
0 7 -2 9 -1 1
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3
4
IN THE SUPERIOR COURT OF W A ITM C TO N , COUNTY OF PIERCE
7
8

Petitioner(s) ,
Case No 10-3-00961-1
WITNESS RECORD
vs
____________ Respondent(s)
10
11
12
13
NAME
JENNIFER K. SHIPMAN
Petitioner
JASON W. SHIPMAN
Respondent
RELATIONSHIP TO CASE
DATE
PETITIONER WITNESS
07/27/11
RESPONDENT WITNESS
07/27/11
14
15
16
17
18
19
20
21
22
23
24
25
WITNESS RECORD -1 of 1
10-3-00961-1
7/27/2011
1
2
3
4
5
6
IN THE SUPERIOR COURT OF WASHINGTON, COUNTY OF PIERCE
7
8

Petitioner(s) ,
9
10
11
Cause No 10-3-00961-1
EXHIBIT RECORD
vs
Respondent(s)
T-L
14
P
Description
No.
D
15
16
17
18
19
Petitioners Composite Exhibit Lens Crafter's

Customer Receipt, IRS refund document, Sallie
Mae.com student loan document, Statement of
Earnings Details re Jennifer K
Shipman/Catholic Health Initiatives
Unopened envelope addressed to Jason
Shipman w/ certified mail receipt attached,
Opened envelope addressed to Jason Shipman
w/ certified mail receipt attached
20
Off
V AH
*).&. I)
12
13
'
Obj
Admitted
Agreed
Denied
Illustrative
Published
Redacted
Reserved
Withdrawn
Date
Admitted
07/27/11
Admitted
07/27/11
Recd
by
Clerks
Office
V[/
21
22
23
24
25
EXHIBIT RECORD
10-3'00961-1
-1 of 2
7/27/2011
Cause No 10-3-00961-1

Petitioner(s) ,
vs
____________ Respondent(s)
STIPULATION AND ORDER FOR

RETURN OF EXHIBITS
It is hereby stipulated that at such time as the Judgment in the above entitled action shall
become final, or upon Judgment becoming final after Appeal, or upon the filing of a Dismissal, or upon
filing a Satisfaction of Judgment, the County Clerk may return all exhibits offered and received in
evidepdejin the above entitled action to the party introducing said exhibits
Judgment Entered,
Appeal Filed
Remittitur Filed
Dismissal Filed
Satisfaction Filed
RECEIPT FOR EXHIBITS
Received from the PIERCE COUNTY CLERK the following exhibits

s Exhlblt(s) No
____________________________
Petitioner(s)
D a te ____________
Attorney for Petitioner(s)
Respondent(s) s Exhibit(s)
No
___________________
___________________
D a te____________
Attorney for
Respondent(s)

Cause Number. 10-3-00961-1

Petitioners)
vs
Page 1 of 2

Respondent(s)
ROBERT D LLOYD
TIMOTHY M GREENE
SHIPMAN, TYLER
SHIPMAN, HUNTER
Proceeding Set Decision/Ruling

Proceeding Outcome Motion Held
Resolution Closed by Court Order Post-Hrg
Outcome Date 07/28/2011 11 51
Proceeding Outcome code MTHRG

Resolution Outcome cod^-CLCO"*
Ixcalcivtl pbl d_civiUoumaI_report_cover
Us 1 ^ 2 0 1 3 .
bSt?2f-


MEMORANDUM OF
JOURNAL ENTRY
vs
Page 2 of 2
Judge/Commissioner
RONALD E CULPEPPER
Atty Tim Greene present on behalf of petitioner (petitioner not

present today for court decision); Respondent present pro se.
July 28. 2011 11:29 AM
Court renders decision (s): No equity in home remaining

Debts addressed. No
reimbursement to petitioner in re tax return. Resp to reimburse Pet in re children's glasses.
Reimbursement of $500 to pet from respondent in re daycare expenses.
11:35 AM School loan - not requiring resp to reimburse pet (Sallie Mae loan).
11:36 AM Personal property1all property in parties' possession remains with that person;
not requiring reimbursement for sold vehicles.
Box of pictures: resp and pet to cooperate in making copies and divide. Original photos to
go to parties who are in pics Guns: Safety courses for minors required, guns to be secured
and not readily available to minors Support1 exemptions for tax purposes to pet, but after
August, 2011 pet will need to provide insurance coverage for kids Pet responsible for extra
curricular activities. 11 40 AM Retirement accounts: all of pet to her, $4k of his to him.
Total reimbursement to petitioner = $1,643 75, can be entered as judgment or added to
QDRO Respondent requests to have his pool table returned. - After argument, court orders
pool table returned to respondent, over petitioner obj. Respondent requests to have his
soda machine returned. Court awards the soda machine to respondent, over petitioner obj
If petitioner does not have, she'll need to advise of the whereabouts if she has knowledge.
Petitioner's pay rate to be re-calculated w/o overtime. 11:50 AM Final documents will be
presented on 8/4/11 at 9am after review by parties.
14S69
B/ S 2 3 1 1
23SS4

Cause Number: 1 0 -3 -0 0 9 6 1 -1
Petitioner(s)
vs.
page 1 of 2

Respondent(s)
Judge/Commissioner: RONALD E. CULPEPPER
Court Reporter: KARLA JOHNSON
Judicial Assistant/Clerk: ANGELA EDWARDS
SHIPMAN. JENNIFER KAY
ROBERT D. LLOYD
Daniel N Cook
SHIPMAN, TYLER
SHIPMAN. HUNTER
Proceeding Set: Presentation/Trial

Proceeding Outcome: Motion Held
Outcome Date: 08/04/2011 9:15
Resolution:

Proceeding Outcome code:MTHRG
Ixcalcivil.pbl.ctjcivilJoumal_report_cover


MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner:
RONALD E. CULPEPPER
Court ReportenKARLA JOHNSON
Judicial Assistant/Clerk: ANGELA EDWARDS
Atty Greene present on behalf of petitioner. Respondent

present pro se. Final documents reviewed. Argument re pool table and visitation; rulings
August 04. 2011 09:02 AM
stand. 09:09 AM Further argument re child support. Parenting Plan; FOF/COL; Decree of
Disso signed.
09:14 AM Order of Child Support not entered today. Matter reset to allow Mr. Shipman to
present an alternative. This issue reset to Tuesday, 8/9 at 9am.
JUDGE/COMMISSIONER: RONALD E. CULPEPPER Year 2011

County of Pierce
No. 10-3-00961-1

Petitioner,
and
Parenting Plan:
Final Order (PP)

Respondent.
the final parenting plan signed by the court pursuant to a decree of dissolution, legal
separation, or declaration concerning validity signed by the court on this date.

Name
Parenting Plan
Final Order (PP)
Age
Tyler Shipman
16
Hunter Shipman
10

Ph: (253) 770-0808, Fax (253) 770-0259
1 4 5 6 .9
? ^ p t)q ?

Under certain circumstances, as outlined below; the court may limit or prohibit a parents
contact with the child(ren) and the right to make decisions for the child(ren).
2.1

Does not apply.
2.2
Does not apply.

The residential schedule must set forth where the child(ren) shall reside each day of the year;
including provisions for holidays, birthdays of family members, vacations, and other special
occasions, and what contact the child(ren) shall have with each parent. Parents are encouraged
to create a residential schedule that meets the developmental needs of the child(ren) and
individual needs of their family. Paragraphs 3.1 through 3.9 are one way to write your
residential schedule. If you do not use these paragraphs, write in your own schedule in
Paragraph 3.13.
3.1

3.2
School Schedule
Upon enrollment in school, the child(ren) shall reside with the petitioner,
except for the following days and times when the child(ren) will reside with or be with the other
parent:
from 5:00 p.m. Friday to Monday mornings at the beginning of the school day every other week
every Wednesday from 5 p.m. to 8 p.m.
Parenting Plan
Final Order (PP)
Law Offices o f Greene & Lloyd, PLLC

Street; 4115 S. M eridian, Ste. B
Ph: (253) 770-0808, Fax (253) 770-0259
2 3 BB 9 3
3.3
The winter vacation shall be split evenly between the parents, with the father having the first
half of the vacation in even-numbered years and the mother having the first half in odd numbered
years.
3.4
Same as 3.3
3.5
Summer Schedule
Upon completion of the school year, the children shall reside with the mother, except for the
following days and times when the children shall reside with or be with the other parent:
Father shall have the first five weeks residential time during the summer break.
3.6
Does not apply.

3.7
The residential schedule for the child(ren) for the holidays listed below is as follows:
New Years Day

Presidents Day
Memorial Day
July 4th
Labor Day
Veterans Day
Thanksgiving Day
Christinas Eve
Christmas Day
New Years Eve
Easter
[x ]
Parenting Plan
Final Order (PP)
With Petitioner
(Specify Year
Odd/Even/Everv)
With Respondent
(Specify Year
Odd/Even/Everv)
odd
even
odd
even
odd
even
odd
odd
odd
even
even
odd
even
odd
even
odd
even
odd
even
even
even
odd
odd
even
For purposes of this parenting plan, a holiday shall begin and end as follows (set forth
times):A holiday begins at 8:00 a.m. and ends at 10:00 p.m. unless it is fathers
holiday and mothers workday, on which day the holiday begins at 6:30 a.m. and ends at
10 p.m. The 10 p.m. end to the holiday does not apply to the Fourth of July.
Street: 4115 S. M eridian, Ste. B
Ph: (253) 770-0808, Fax (253) 770-0259
146 b
3 ^ 5 /2 8 1 1
,'2 3 0 9 9 q
The Fourth of July holiday ends at midnight.
3.8
The residential schedule for the children) for the following special occasions (for example,
With Petitioner
With Respondent
(Specify Year
(Specify Year
Odd/Even/Every)
Odd/Even/Everv)
every
Mothers Day____
Fathers Day_____
every_________________
____
Mothers birthday
every.
Fathers birthday
Childrens birthdays
even__________________
odd
5
6
7
8
9
For purposes of this parenting plan, a special occasion shall begin at 8:00 a.m. and end at
10:00 p.m., unless it is fathers special occasion and mothers workday, on which days
the special occasion begins at 6:30 a.m.
10
11
12
3.9
13
If the residential schedule, Paragraphs 3.1-3.8, result in a conflict where the children are
scheduled to be with both parents at the same time, the conflict shall be resolved with priority
given as follows, with 1 being the highest priority.
14
15
6.
5.
4
3.
2.
1.
16
17
school schedule
winter vacation
.school breaks
summer schedule
holidays
special occasions
18
19
20
3.10
Restrictions
21
22
23
Parenting Plan
Final Order (PP)

Ph: (253) 770-0808, Fax (253) 770-0259
146S?
3.11
S .'S ^ S S i
2 3 0 ig ig
Transportation costs are included in the Child Support Worksheets and/or the Order of Child
Support and should not be included here.
Transportation arrangements for the child(ren), between parents shall be as follows:
The exchange point is the paternal grandparents home, unless the parties mutually agree
to a different exchange point.
3.12
The children named in this parenting plan are scheduled to reside the majority of the time with
the [ ] petitioner [ ] respondent. This parent is designated the custodian of the child(ren) solely
for purposes of all other state and federal statutes which require a designation or determination of
custody. This designation shall not affect either parents rights and responsibilities under this
parenting plan.
3.13
Other
a. It is the responsibility of the parent scheduled to have the children to arrange suitable
alternative care if necessary and to pay for the needed care.
b. Each parent shall notify the other at least forty-eight (48) hours in advance if he or she is
unable to comply with the regular schedule.
c. Each parent shall keep the other apprised of his or her current residence address and residence
telephone number.
d. Both parents shall have unlimited access to the childrens school, daycare, and medical
records. Neither parent may revoke this provision by telling the providers to disobey this
court order.
e. Telephone Access
The children shall have reasonable telephone privileges with the parent with whom the
children are not then residing, without interference of the residential parent.
Parenting Plan
Final Order (PP)

Ph: (253) 770-0808, Fax (253) 770-0259
I4fcfe9
3 /5 /2 8 1 1
2 3 ^ i^ i
f. Participation in Childrens Events

1. The children shall be accompanied by the parent with whom the children are residing
at the time of a given social event. The other parent shall not be limited from
attendance at that event, providing said attendance by the non-residential parent is
not disruptive to the other participants.
2. Each parent shall be responsible for keeping themselves advised of the school,
athletic, and social events in which the children participate. Both parents may
participate in school activities for the children, such as open house, attendance at
an athletic event, etc.
g. Gun Safety
1. Both parents shall keep household guns locked up in a location not accessible to the
children.
2. The father shall enroll Hunter in a gun safety course and provide proof to the mother
of Hunters successful completion of the course within 45 days of entry of this order.
3.14
This is a summary only. For the full text, please see RCW 26.09.430 through 26.09.480,
If the person with whom the child resides a majority of the time plans to move, that person shall
If the move is outside the childs school district, the relocating person must give notice by
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).
may ask for modification under RCW 26.09.260.
Parenting Plan
Final Order (PP)
Law Offices o f Greene & Lloyd, PLLC

Ph: (253) 770-0808, Fax (253) 770-0259
14669
8y r2 S il
238182
and safety of a person or a child at risk.
If no objection is filed w ithin 30 days after service of the notice of intended

relocation, the relocation w ill be permitted and the proposed revised residential
schedule may be confirmed.
5
6
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.
objection, the relocating person shall not move the child before the hearing unless there is a
10
11
IV. Decision Making
12
13
4.1
Each parent shall make decisions regarding the day-to-day care and control of each child while
the child is residing with that parent. Regardless of the allocation of decision making in this
parenting plan, either parent may make emergency decisions affecting the health or safety of the
children.
14
15
16
17
18
19
4.2
Major Decisions

Education decisions
joint
joint
joint
20
21
22
23
Parenting Plan
Final Order (PP)

Ph: (253) 770-0808, Fax (253) 770-0259
4.3

Does not apply because there are no limiting factors in paragraphs 2.1 and 2.2 above.
The purpose of this dispute resolution process is to resolve disagreements about carrying out
this parenting plan. This dispute resolution process may, and under some local court rules or
the provisions of this plan must be used before filing a petition to modify the plan or a motion for
contempt for failing to follow the plan.
Disputes between the parties, other than child support disputes, shall be submitted to (list person
or agency):
mediation by Pierce County Center for Dispute Resolution,
based on each partys proportional share of income from line 6 of the child support
worksheets.
The dispute resolution process shall be commenced by notifying the other party by
certified mail/retum receipt.
(a)
(b)
(c)
(d)
(e)

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

Parenting Plan
Final Order (PP)

Ph: (253) 770-0808, Fax (253) 770-0259
3.4SS 9
g y 5-^2 ?'i t
'2339184
4
5
Does not apply.

6
7
8
9
10
11
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
If a parent fails to comply with a provision of this plan, the other parents obligations under the plan are
not affected.
12
Dated: _
13
RONALD E. CULPEPPER
Approved for entry:
14
15
16
or Lawyer/WSBA No.
Print Name
Signature of Party or Lawyer/WSBA No.

Print Name
riL E U
DEPT. 17
IN OPF*, r *'"R T
17
18
AH P
19
PIERCE IcbuNTY, Clerk
20
21
22
23
Parenting Plan
Final Order (PP)

Ph: (253) 770-0808, Fax (253) 770-0259
2/4.SS5?
10-3-00961-1
36896565
FNFCL
5 ^ 2 3 1 i
2 3 0 * fas;
s*
06-05-11
]
2
3
4
5
6
7
8

County of Pierce
No. 10-3-00961-1
Petitioner,
10
and
Respondent.
Findings of Fact and

Conclusions of Law
(Marriage)
(FNFCL) __________
11
I. Basis for Findings
12
13
The findings are based on:

[x ]
trial. The following people attended:
14
Petitioner.
Petitioners Lawyer.
Respondent pro se.
15
16
II. Findings of Fact
17
18
19
20
Upon the basis of the court records, the court Finds:

2.1
Residency of Petitioner
The Petitioner
is a resident of the state of Washington.
21
22
23
Findings of Fact and Conclusions of Law
(Marriage) (FNFCL)
Law Offices of Gree ne & Lloyd, PLLC

Mailing: P.O, Box 731063
Ph: (253) 770-0808, Fax (253) 770-0259
2.2
Notice to the Respondent
The respondent
appeared, responded or joined in the petition.
2.3
Basis of Personal Jurisdiction Over the Respondent
The facts below establish personal jurisdiction over the respondent.

The respondent is currently residing in Washington.
2.4
Date and Place of Marriage
The parties were married on April 24, 1994 at North Bend, Washington.
2.5
Status of the Parties
Husband and wife separated on February 27, 2010..

2.6
Status of Marriage
The marriage is irretrievably broken and at least 90 days have elapsed since
the date the petition was filed and since the date the summons was served or
the respondent joined.
2.7
Separation Contract or Prenuptial Agreement
There is no written separation contract or prenuptial agreement.
Findings o f Fact and Conclusions of Law

(Marriage) (FNFCL)

Ph: (253) 770-0808, Fax (253) 770-0259
g /2 0
l i
2^ 0
1
2.8
Community Property
2
The parties have the following real or personal community property:
3
1. Each party is vested in a retirement fund.
2. Each party possesses motor vehicles registered in the party's name.,
3. Each party has miscellaneous personal property in the partys possession.
4. The husband has a ten foot trailer in his possession.
5. The husband has the communitys photographs in his possession.
Other: The wife either possesses a Pepsi machine or pool table or

is to provide the court with an explanation as to the whereabouts
of these items.
The community home that had been located at 9306 116th St. E.
had been foreclosed upon in April, 2011, and is no longer property
of the marital community.
10
11
12
13
14
15
2.9
Separate Property
The husband has the following real or personal separate property:

Miscellaneous property in his possession.
The wife has the following real or personal separate property:
Miscellaneous property in her possession.
16
17
18
19
20
21
22
23
Findings of Fact and Conclusions o f Law
(Marriage) (FNFCL)

S tr e e t 4115S. M eridian, Ste. B
Ph: (253) 770*0808, Fax (253) 770-0259
1
2.10
Community Liabilities
2
The parties have incurred com m unity liabilities and the parties
have divided these liabilities by agreement.:
3
4
5
6
7
O ther: The husband owes the wife equitable reimbursement for the following:
a) $ 1,000 for the purchase of the ten foot trailer that the husband has in his
possession.
b) $ 500 for daycare expenses for Hunter.
c) $ 143.75 reimbursement for Tylers lost eyeglasses.
8
9
2.11
The husband has incurred separate liabilities, for which he will be solely
responsible.
10
11
The wife has incurred the following separate liabilities, for which she will
be solely responsible.
12
13
Separate Liabilities
2.12
14
Maintenance
Maintenance was not requested.
15
16
2.13
Does not apply.
17
2.14
Protection Order
18
Does not apply.
19
2.15
Fees and Costs
20
There is no award of fees or costs.
21
2.16
22
Pregnancy
The wife is not pregnant.
23
Findings or Fact and Conclusions of Law
(Marriage) (FNFCL)

S treet; 4115 S. M eridian, Ste. B
Ph: (253) 770-0808, Fax (253) 770-0259
2.17
Dependent Children
The children listed below are dependent upon either or both spouses.
Name of
Child
2.18
Mothers
Name
Age
Fathers
Name
Tyler
16
Hunter
10
Jennifer Shipman
Jason Shipman
This court has jurisdiction over the children for the reasons set forth below.
The children lived in Washington with a parent or a person
acting as a parent for at least six consecutive months
immediately preceding the commencement of this proceeding.
2.19
Parenting Plan
The parenting plan signed by the court on this date is approved and
incorporated as part of these findings.
Other: The basic structure of the parenting plan was ordered by
a court commissioners temporary order after hearing on August 24, 2010,
and this plan has been slightly modified on specific issues raised by the
parties in the July 27, 2011 trial on this matter.

(Marriage) (FNFCL)

Ph: (253) 770-0808, Fax (253) 770-0259
6 9 3 'r; .-' 3 i i 23$
s*
1
2.20
Child Support
2
There are children in need of support and child support should be set pursuan;
to the Washington State Child Support Schedule. The Order of Child Support
signed by the court on this date and the child support worksheet, which has
been approved by the court, are incorporated by reference in these findings.
3
4
5
6
7
2.21
Other
The wife is the sole recipient of the IRS tax exemption for the children.
This condition is in consideration of the wife being solely responsible for
health insurance, uncovered health expenses, and extracurricular expenses
for the children as discussed in the Order of Child Support and the Final
Parenting Plan. The wife is still entitled to credits for these expenses in
Calculating her child support on the Child Support Worksheets.
9
10
11
12
III.
13
14
15
The court makes the following conclusions of law from the foregoing findings of fact:
3.1
3.2
18
19
20
Jurisdiction
The court has jurisdiction to enter a decree in this matter.
16
17
Conclusions of Law
Granting a Decree
The parties should be granted a decree.

3.3
Pregnancy
Does not apply.
21
22
23
(Marriage) (FNFCL)
Law Offices of G reene &Lloyd, PLLC

Ph: (253) 770-0808, Fax (253) 770-0259
14669
3.4
7 ^ 0 ^ ^^
Disposition
The court should determine the marital status of the parties, make provision for a
parenting plan for any minor children of the marriage, make provision for the
support of any minor child of the marriage entitled to support, consider or approve
provision for maintenance of either spouse, make provision for the disposition of
property and liabilities of the parties, make provision for the allocation of the
children as federal tax exemptions, make provision for any necessary continuing
restraining orders, and make provision for the change of name of any party. The
distribution of property and liabilities as set forth in the decree is fair and
equitable.
2
3
4
5
6
7
S /5 /'2 0 i i
3.5
Does not apply.

8
3.6
Protection Order
9
Does not apply.
10
3.7
11
Does not apply.
12
13
14
3.8
Other
Dated;
15
Approved for entry:
Notice'ljf p/esentation waived:
16
17
18
Signature of Party or Lawyer/WSBA No

/
gnarure of/Party or Lawyer/WSBA No.
19
20
Print or Type Name
/P S " & S ?
/
Dat
Date
S" 3^7/
Print or Typ e Name
21
22
23
Findings of Fact and Conclusions o f Law
(Marriage) (FNFCL)

Ph; (253) 770-0808, Fax (253) 770-0259
10-3-00961-1
3689B569
DCD
08-05-11
3
4
5
6

County of Pierce

8
No. 10-3-00961-1
Decree of Dissolution (DCD)
Petitioner,
10
11
and
Respondent.
12
13
I. Judgment/Order Summaries
1.1 Restraining Order Summary:
Does not apply.

14
15
16
17
18
19
20
21
1.2 Real Property Judgment Summary:
Does not apply.

1.3 Money Judgment Summary:
Judgment Summary is set forth below.

Jennifer Kav Shipman
A. Judgment creditor
B. Judgment debtor
$ 1.643.75
C. Principal judgment amount
$4):
D. Interest to date ofjudgment
E. Attorney fees
$rQz
$-0F. Costs
$z0:
G. Other recovery amount
H. Principal judgment shall bear interest at 12 % pa* annum
I. .Attorney fees, costs and other recovery amounts shall bear interest at -0- % per annum
J. Attorney forjudgment creditor
Timothy M. Greene
K. Attorney forjudgment debtor
Pro se
L. Other
22
End o f Summaries
23
Decree of Dissolution
(DCD)
Law Offices.of G reene & Lloyd, PLLC

Street: 4115 S. M eridian , Ste. B
Ph: (253) 770-0808, Fax (253) 770-0259
II. Basis
Findings of Fact and Conclusions of Law have been entered in this case.
III. Decree
It Is Decreed that;
3.1
Status of the Marriage
The marriage of the parties is dissolved.

3.2
Property to be Awarded the Husband
The husband is awarded as his separate property the following property (list real estate*
furniture, vehicles, pensions, insurance, bank accounts, etc.):
All property currently in his possession, with the exception of specific items listed under
property to be awarded the wife.
Pepsi machine
Pool table
Other: The community home that had been located at 9306 116thSt. E. had been foreclosed
upon in April, 2011 and is no longer the property of the marital community.
If the wife does not have possession of the Pepsi machine or the pool table, she is to
disclose the whereabouts of these items and she is ordered to return these items,
whether or not they are in the possession of third parties. However, if the wife
does not have possession of the Pepsi machine or pool table and does not know
of their whereabouts, she is to provide an explanation.
3.3
Property to be Awarded to the Wife
The wife is awarded as her separate property the following property (list real estate,
furniture, vehicles, pensions, insurance, bank accounts, etc.):
All property currently in her possession, with the exception of specific items listed under
property to be awarded the husband
Wedding ring of wife
Heirloom pocket watch once owned by wifes grandfather
Originals of photographs in which wife or her family (excluding the children) are in picture and
husband not in picture and copies of all other photographs, except photographs of husband or his
family not including children (husband possesses photographs at time decree entered).
(PCD)

S treet: 4115 S. M eridian , Ste. B
Ph: (253) 770*0808, Fax (253) 770-0259
1
Other; The husband represents that he does not have the wedding ring and the heirloom pocket watch.
He is to return these items to the wife if he finds them.
2
3
4
3.4
Liabilities to be Paid by the Husband
The husband shall pay the following community or separate liabilities:
All community liabilities that he has been paying since the separation of the parties.
7
Other; He is obligated to reimburse the wife for the following items;
8
S 1,000 for the ten foot trailer currently in his possession.
$ 143.75 for replacement of Tylers eyeglasses
10
$ 500.00 for daycare reimbursement for Hunter
(see Paragraph 1.3, Money Judgment Summary above).

Unless otherwise provided herein, the husband shall pay all liabilities incurred by him since the date
of separation.
12
13
3.5
Liabilities to be Paid by the Wife
14
The wife shall pay the following community or separate liabilities;
15
AH community liabilities that he has been paying since the separation of the parties.
16
Unless otherwise provided herein, the wife shall pay all liabilities incurred by her since the date of
separation.
17
3.6
Hold Harmless Provision
18
19
20
[]
Each party shall hold the other party harmless from any collection action relating to
separate or community liabilities set forth above, including reasonable attorney's fees and
costs incurred in defending against any attempts to collect an obligation of the other party.
Other:
21
22
23

Street* 4115 S. M eridian , Ste, B
Ph: (253) 770-0808, Fax (253) 770-0259
14-669
3.7
2 6 9 ^ 1 1; ..r
Maintenance
Does not apply.
3.8
Does not apply.
3.9
Protection Order
Does not apply.

3.10
The court has jurisdiction over the children as set forth

in the Findings of Fact and Conclusions of Law.
3.11
Parenting Plan
The parties shall comply with the Parenting Plan signed by the court on this date.
The Parenting Plan signed by the court is approved and incorporated as part of this decree.
3.12
Child Support:
Child support shall be paid in accordance with the Order of Child Support signed by the
court on this date. This order is incorporated as part of this decree.
3.13
Attorney Fees, Other Professional Fees and Costs
Does not apply.

3.14
Name Changes
The wife's name shall be changed to

Jennifer Kay Lund.
3.15
Other: The wife is the sole recipient of the IRS tax exemption for the children. This
condition is in consideration of the wife being solely responsible for health insurance,
uncovered health expenses and extracurricular expenses for the children as discussed
in the Order of Child Support and the Final Parenting Plan. The wife is still entitled
to credits for these expenses in calculating her child support on the Child Support
Worksheets.
(DCD)

Street: 4115 S. M eridian , Ste. B
Ph: (253) 770-0808, Fax (253) 770-0259
1
2
3
4
5
6
Dated:
uoner
7
8
9
Respondent or respondents lawyer:

[ ] Presented by:
[ ] Approved for entry:
[ ] Notice for presentation waived:
Petitioner or petitioners lawyer:

[] Presented by:
[ ] ApnrOved^for j
[]
prpsedb tion waived:
/7 V ^
loner or Lawyer/WSBA No.
10
II
12
'RONALD E. CULPEPPER
n
Print or Type Name
Signature of Respondent or Lawyer/WSBA No.
G rd M , A 3 - / 4
~ ~ S <X'> <en')
Print or Type Name
Date
ja
Date
13
14
15
16
17
18
19
20
21
22
23
(DCD)

S treet; 4115 S. M eridian , Ste, B
M ailing; P.O. Box 731063
Ph: (253) 770-0808, Fax (253) 770-0259
P / 1 1 / ? Q i 4
M "! o r


Petitioners)
vs.
Page 1 of 2

Respondent(s)
Court Reporter. KARLA JOHNSON
Judicial Assistant/Clerk' ANGELA EDWARDS
ROBERT D LLOYD
Daniel N Cook
SHIPMAN, TYLER
SHIPMAN, HUNTER
Proceeding Set. Presentation/Trial

Proceeding Outcome1Motion Held
Resolution:
Outcome Date 08/09/2011 9 24

Resolution Outcome code*
Ixcalcivtlpbl d_civiljoumal_report_cover


MEMORANDUM OF
JOURNAL ENTRY
vs
Page 2 of 2
Judge/Commtssioner
RONALD E CULPEPPER
August 09. 2011 09:15 AM

present pro se.
Atty Greene present on behalf of petitioner.
Child Support worksheet figures argued
Respondent
Court adopts current rates on
support until Mr. Shipman returns to work. Mr. Shipman asserts he's overpaid approx $638.
No action on the overpayment today.
KEVIN STOCK
10-3-00961-1
38328505
Clerkofthe Superior Court and

DirectorofArbitration
04-12-1
LTDEX
FILED
rirc :
IN COUNTY CLERK'S OrFICE
DATE: April 11,2012
APR 1 2 2012
p.m.
TO WHOM IT MAY CONCERN:

RE: Pierce County Cause Number:
10-3-00961-1
Case Title: JENNIFER KAY SHIPMAN VS. JASON WILLIAM
SHIPMAN
Appeal No.:
Appeal Status:
Please come in and withdraw the exhibits or authorize the County Clerk to
destroy them. Return this letter with an "X" in the appropriate square
signifying your intentions.
E x h ib its W ili B e D e s t r o y e d On M A Y 18. 2 0 1 2
If Y o u D o N o t R e s p o n d
Sincerely,
Kevin Stock, Clerk
Michael Kapfhammer
Deputy Clerk, Evidence Section
798-7717
**************************************************************************************
I will pick up the exhibits DPetitioners DDefendants on

(Date)
____ I hereby authorize the Pierce County Clerk to destroy the
Petitioners Defendants exhibits in Pierce County Cause Number
ROBERT D. LLOYD
4115 S. MERIDIAN, SUITE B
PUYALLUP, WA 98373
N \WORDDOCS\ltnx formsWauItVdestroy exhibits civil 2 att
Uv? 1 8 3 7 5
4^ i8/*2812
538288
IN COUNTYF CLERK'S OFFICE
APR 1 8 2012 P.M.

0-3-00961-1
38367143
04-18-12
NTDE
PIERCE COUNTY,WASHINGTON
ffIVtN STOCK. Countyffwk
PIERCE COUNTY SUPERIOR COURT, STATE OF WASHINGTON
JE N N IF E R K A Y SH IPM AN ,
Plaintiff,
vs.
JA S O N WILLIAM SHIPMAN,
Defendant.
)
>
)
)
)
>
)
)
>
>
>
i
Case No.: 10-3-00961-1

Notice of Destruction of
Exhibits
(NTDE)
Receipt of Exhibits
(EXRECT)
B ' a n o tice w a s filed a n d s e n t r e g a r d in g d e s tru c tio n o f e x h ib its o n
If- I t .
N o re s p o n s e w as re c e iv e d fro m e ith e r p a rty

EH N o re s p o n s e w as re c e iv e d fro m P la in tifl/P e titio n e r
DN
re s p o n s e w as re c e iv e d fro m D e fe n d a n t/R e s p o n d e n t
T h e e x h ib its in th e ab o v e re fe re n c e d case w h e re d e s tro y e d on
C l E x h ib its in th e ab o v e re fe re n c e d c a se w h e re p ic k e d u p on _______________________ by:

EH P la in tiff/P e titio n e r________________________________ .______________
CHD e fe n d a n t/R e s p o n d e n t___________________________________________
18^7t? 4 '' i 8 z''28 4 2 S 18288
fierce County______________________ ________________________ __

Office of the County Clerk
KEVIN STOCK
930 Tacoma Avenue South, Room 110

Tacoma, Washington 98402-2177
(253) 798-7455 FAX (253) 798-3428
Clerk of the Superior Court and

Director of Arbitration
DATE: April 11,2012

TO WHOM IT MAY CONCERN:
RE:
Pierce County Cause Number:

10-3-00961-1
Case Title: JENNIFER KAY SHIPMAN VS. JASON W ILLIAM
SHIPMAN
Appeal No.:
Appeal Status:
Please come in and withdraw the exhibits or authorize the County Clerk to
destroy them. Return this letter with an "X" in the appropriate square
signifying your intentions.
E x h ib its W iii B e D e s t r o y e d On M A Y 18, 2 0 1 2
If Y o u D o N o t R e s p o n d .
Sincerely,
Kevin Stock, Clerk
Bf
Michael Kapfhammer
Deputy Clerk, Evidence Section
798-7717
*************,#c*****,**'*,**'*****"*,*************'*******,*,****'*,**********,********************
____ I will pick up the exhibits nPetitioners DDefendants o n __

(Date)
_ l hereby authorize the Pierce County Clerk to destroy the
Petitioners Defendants exhibits in Pierce County Cause Number
ROBERT D. LLOYD
4115 S. MERIDIAN, SUITE B
PUYALLUP, WA 98373
'y.^êc
N:\WORDDOCS\linx forms\vaul1\destroy exhibits civil 2 attorneyÔtfc
12/2002
.. recycledjiH:n3r
E-FILED
May 10 2012 2:27 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1

Petitioner(s),
vs.
NO. 10-3-00961-1
NOTICE OF INTENT TO WITHDRAW

_______________ Respondent(s)
AND TO: Daniel N Cook, attorney for Respondent, TIMOTHY M. GREENE, attorney for
Respondent
NOTICE IS HERBY GIVEN that ROBERT D. LLOYD intends to withdraw as attorney for
Petitioner/Plaintiff(s) JENNIFER KAY SHIPMAN, in the above-entitled action on May 10, 2012.
This notice is given pursuant to Civil Rule 71(c) of the Rules for Superior Court.
Withdrawal shall be effective without court order and without the service and filing of any
additional papers unless an objection to the withdrawal is served upon the withdrawing attorney
prior to the date set forth above.
There is no trial date scheduled for this case.
PAGE 1 OF 2
ntiwdsup-0002.pdf
LAW OFFICE OF GREENE AND LLOYD

P.O. BOX 731063
PUYALLUP, WA 98373
(253) 770-0808
10-3-00961-1
The last known name and address of the parties I have been representing are listed below:
2323 7TH STREET SE #B203
PUYALLUP, WA 98374
CERTIFICATE OF SERVICE
I certify under penalty of perjury under the laws of the State of Washington that the foregoing is
true and correct: That on May 10, 2012, I mailed a copy of this document to the attorney(s) of
record and/or parties at their respective addresses of record.
DATED: May 10, 2012
PAGE 2 OF 2
ntiwdsup-0002.pdf
/s/ ROBERT D. LLOYD

ROBERrDTEDYD712896U
Attorney for Petitioner/Plaintiff(s)
LAW OFFICE OF GREENE AND LLOYD

P.O. BOX 731063
PUYALLUP, WA 98373
(253) 770-0808
E-FILED

June 28 2012 8:51 AM

KEVIN STOCK
No. 10-3-00961-1
COUNTY CLERK
ORDER SETTING CASE SCHEDULE

Type of case:
DIC
Petitioner(s)
Vs.
Track Assignment:
Assignment Department:
Docket Code:

Respondent(s)
Modification of Custody
ORLA
ORSCS
7/5/2012
Notice of Adequate Cause & Note for Comm Cal filed w/Petition or no later than
7/19/2012
Certificate of Parenting Class - Petitioner's (Must be filed on or before)
8/30/2012
Certificate of Parenting Class - Respondent's (Must be filed on or before)
8/30/2012
Adequate Cause Hearing on Commissioner Calendar to be held. (If this hearing is not held by this date,
petition will be dismissed)
Set Settlement Conference Date with Judge/Commissioner RONALD E. CULPEPPER
8/30/2012
PlaintifFs/Petitioner's Disclosure of Primary Witnesses
11/1/2012
8/30/2012
11/22/2012
Defendant's/Respondent's Disclosure of Primary Witnesses
12/6/2012
Disclosure of Rebuttal Witnesses
12/20/2012
Week of 1/31/2013
2/7/2013
Discovery Cutoff
Exchange of Witness and Exhibit Lists and Documentary Exhibits
2/21/2013
3/7/2013 9:00
Trial
U n le s s o t h e r w i s e i n s t r u c t e d , A L L A t t o r n e y s / P a r t i e s s h a ll r e p o r t to t h e t r i a l c o u r t a t 9 :0 0 A M o n
th e d a te o f tria l.
If the case has been filed, the plaintiff shall serve a copy of the Case Schedule on the defendant(s) with the summons and complaint/
petition: Provided that in those cases where service is by publication the plaintiff shall serve the Case Schedule within five (5) court days
of service of the defendant's first response/appearance. If the case has not been filed, but an initial pleading is served, the Case Schedule
shall be served within five (5) court days of filing. See PCLR 3.
All attorneys and parties shall make themselves familiar with the Pierce County Local Rules, particularly those relating to case
scheduling. Compliance with the scheduling rules is mandatory and failure to comply shall result in sanctions appropriate to the
violation. If a statement of arbitrability is filed, PCLR 3 does not apply while the case is in arbitration.
Dated: June 28, 2012
Judge FAMILY COURT - 2

Department ORLA
FIERCE CGOHTi SUPERIOR COURT

kEUIK STOCK
CLERKOF TRE SUPERIOR COUP'
TaCQHA'#
10-3-00961'!
IN COUNTY TURK'S OFFICE
a .m .

County of Pierce
rJUN 28 2012
p .m
R.-pt. Fate
06/2ET9I2
Aect. Date
06/28/2012
'ftecei;t/Itss; tt Iran-Code RocketCode

$FFR
^Gl2-05-0L96t/01 UQ4
Cashier: JT-f
Paid By: lend. Jennifer
Urnsaction j*iount:
No. 10-3-00961-1
JENNIFER KAY LUND
(fka Jennifer Shipman)
Petitioner,
and
Summons(Modification/
Adjustment of Custody
Decree/Parenting Plan/
Residential Schedule)
(SM)
Respondent.
To:
JASON W. SHIPMAN
1.
An action has been started in the above court requesting that a custody decree/parenting
plan/residential schedule be modified/adjusted. Additional requests, if any, are stated in the
petition, a copy of which is attached to this notice.
2.
You must respond to this notice and petition by serving a copy o f your written response on the
person signing this summons and by filing the original with the clerk o f the court. If you do not
serve your written response within 20 days (or 60 days if you are served outside o f the state of
Washington) after the date this summons was served on you, exclusive o f the day o f service, the
court may enter an order o f default against you, and the court may, without further notice to you,
enter an order regarding adequate cause and a decree to modify/adjust the custody
decree/parenting plan/residential schedule and providing for other relief requested in the petition
If you serve a notice of appearance on the undersigned person, you are entitled to notice before
an order o f default or a decree may be entered.
The court shall deny the petition unless it finds that adequate cause for hearing the petition is
established, in which case it shall set a date for hearing on an order to show cause why the
requested order or modification should not be granted.
Temporary residential placement or custody is not being sought
Summons Mod/Adj Parenting Plan (SM) - Page 1 of 2

WPF DRPSCU 07 0120 Mandatory (7/2007) - C R 4 1, RCW 26 09 270, 26 10 020
u&e
08:53 AH
$56.00
6^29/*
12 17 9 2 2 6
You may file an opposing declaration to show that there is not adequate cause to hold a full
hearing If you do not file an opposing declaration or respond and the court finds that adequate
cause exists, the court may enter an adequate cause order and an order modifying/adjusting the
custody decree/parenting plan/residential schedule without notice to you pursuant to RCW
26.09.270.
Your written response to the summons and petition must be on form WPF DRPSCU 07.0200,
Response to Petition for Modification/Adjustment o f Custody Decree/Parenting Plan/Residential
Schedule. This form may be obtained by contacting the clerk o f the court at the address below,
by contacting the Administrative Office o f the Courts at (360) 705-5328, or from the Internet at
the Washington State Courts homepage:
http://www.courts.wa.gov/forms
6.
If this action has not been filed with the court, you may demand that the petitioner file this action
with the court. If you do so, the demand must be in writing and must be served upon the person
signing this notice. Within 14 days after you serve the demand, the petitioner must file this
action with the court, or the service on you o f this notice and motion will be void
If you wish to seek the advice of an attorney in this matter, you should do so promptly so that
your written response, if any, may be served on time.
8.
One method of serving a copy of your response on the petitioner is to send it by certified mail
with return receipt requested.
This summons is issued pursuant to Superior Court Civil Rule 4.1 o f the state of Washington.
Dated June 27, 2012
t-J s /w J /M
k.
Jeijjwfer K. Lund
Petitioner
File original of your response with

the clerk of the court at:
Serve a copy of your response on:

930 Tacoma Ave. S
Tacoma, WA
Jennifer K. Lund
2323 - 7th Street SE, Apt. B-203
Puyallup, WA 98374
Summons Mod/Adj Parenting Plan (SM) - Page 2 o f 2

WPF DRPSCU 07 0120 Mandatory (7/2007) -C R 4 1, R C W 26 09 270, 26 10 020
10-3-00961-1
38773269
06-28-12
SPTMDC
INCOUNTYFd
an.
i c s OFFICE
8 8 2012 m

KEVIN STOCK, County Cle*
DStnY
BY.

County of Pierce
No. 10-3-00961-1
JENNIFER KAY LUND

Petition for Modification/

Adjustment of Custody Decree/
Parenting Plan/Residential
Schedule
(PTMD)
Petitioner,
and
Respondent.
1.1
Para. 2.14: check box if petition is

attached for:
[ ] Order for protection DV (PTORPRT)
[] Order for protection UH (PTORAH)
Identification of Requesting Party/Parties
JENNIFER K. LUND,
Birth date: Feb. 16, 1974
Last known residence Pierce County
1.2
Identification of Other Party/Parties
JASON W. SHIPMAN
Last known residence
1.3
Birth date Aug 20,1972

Pierce County
Dependent Children
Tyler Shipman, age 17
Hunter Shipman, age 11
Pet for Mod/Adj Parenting Pin (PTMD) - Page 1 o f 6

WPF DRPSCU 07 0100 Mandatory (07/2011)
CR 4 1, R C W 26 09 181, 260, 270, RCW 26 26 130(7)(b)
Jennifer K. Lund
2323 - 7th Street SE, Apt B-203
Puyallup, WA 98374
(253) 256-4255
II. Basis
2.1
Petition for an Order Modifying Custody Decree/Parenting Plan/Residential

Schedule
This is a petition for an order modifying the prior custody decree/parenting plan/residential
schedule/judgm ent establishing parentage and approving my proposed parenting plan/residential
schedule, which is filed with this petition.
2.2
Adequate Cause
There is adequate cause for hearing the petition for modification.
2.3
Child Support
Child support should be modified or established if the court grants the petition to modify the
parenting plan or residential schedule A child support worksheet and financial declaration must be
filed with this action RCW 26.09.170.
2.4
Jurisdiction and Venue

The court has proper jurisdiction and venue.
The requesting party, the children and the other party all reside in Pierce County, Washington.
2.5
Jurisdiction Over Proceeding

This court has jurisdiction over this proceeding for the reasons below:
This court has exclusive continuing jurisdiction. The court has previously m ade a child
custody, parenting plan, residential schedule or visitation determination in this m atter and
retains jurisdiction under RCW 26.27.211.
This state is the home state o f the children because
the children lived in Washington with a parent or a person acting as a parent for at
least six consecutive months immediately preceding the commencement o f this
proceeding.
The children and the parents or the children and at least one parent or a person acting as a
parent have significant connection with the state other than mere physical presence, and
substantial evidence is available in this state concerning the childrens care, protection,
training and personal relationships, and.
The children have no home state elsewhere.
No other state has jurisdiction.
Pet for Mod/Adj Parenting Pin (PTMD) - Page 2 of 6

CR4 1 , RC W 26 09 181, 260, 270, RC W 26 26 130(7)(b)
Jennifer K. Lund
2323 - 7thStreet SE, Apt B-203
Puyallup, WA 98374
(253)256-4255
2.6
Uniform Child Custody Jurisdiction and Enforcement Act Information

N am e o f Child
Tyler Shipman, age 17
Hunter Shipman, age 11
Parents Name
Jason W Shipman, Father
Jason W. Shipman, Father
Parents Name
Jennifer K. Lund, M other
Jennifer K. Lund, M other
During the last five years, the children have lived in no place other than the state o f W ashington and
with no person other than the requesting party or the other party
Claims to custody or visitation'
The requesting party does not know o f any person other than the other party who has
physical custody of, or claims to have custody or visitation rights to, the children
The requesting party has not been involved in any other proceeding regarding the children.
Other legal proceedings concerning the children
The requesting party does not know of, any other legal proceedings concerning the
children.
2.7
Custody Decree or Parenting Plan/Residential Schedule

The Custody Decree/Parenting Plan/Residential Schedule was entered on August 04, 2011 at Pierce
County, Washington.
2.8
Modification Under RCW 26.09.260(1), (2)

Does not apply
2.9
Modification or Adjustment Under RCW 26.09.260(4) or (8)

Does not apply
2.10
Adjustments to Residential Provisions Under RCW 26.09.260(5)(a) and (b)

Does not apply.
The custody decree/parenting plan/residential schedule should be adjusted because a
substantia] change in circumstances o f either parent or o f the child has occurred and the
proposed modification to the custody decree/parenting plan/residential schedule is in the
best interest o f the children and is a minor modification in the residential schedule that does

CR 4 1, R C W 26 09 181, 260, 270, RCW 26 26 130(7)(b)
Jennifer K. Lund
2323 - 7thStreet SE, Apt. B-203
Puyallup, WA 98374
(253) 256-4255
-b-'2 9 / e i 2
1.7*7.2.
not change the residence the children are scheduled to reside in the majority o f the time
and'
is based on a change o f residence o f the parent with whom the child does not reside
a majority o f the time or an involuntary change in work schedule by a party which
makes the residential schedule in the parenting plan impractical to follow.
2.11
Adjustments to Residential Provisions Under RCW 26.09.260(5}(c), (7), (9)

Does not apply.
2.12
Adjustments to Nonresidential Provisions Under RCW 26.09.260(10)

The following nonresidential provisions o f the parenting plan should be adjusted because
there is a substantial change o f circum stances o f either party or o f the children and the
adjustment is in the best interest o f the children:
[X]
[X]
[X]
[X]
Dispute resolution
Decision making.
Transportation arrangements.
Other:
There should be a specific provision restricting the 11-year-old child from
traveling out o f state alone.
2.13
Substantial Change in Circumstance

(You must complete this part if you request a modification or adjustment in
paragraphs 2.8, 2.10, 2.11.1, 2.11.3 or 2.12.)
The requested modification or adjustment o f the custody decree/parenting plan/residential schedule
is based upon the following substantial change in circumstance:
The father has relocated and/or is in the process o f relocating to Yelm He has visitation through
M onday a.m. when the children go to school. He must awake the children at 4:00 a.m. to make the
extra l hour to l X
A hours extra travel time to drop the children o ff at school.
This makes the plan impractical to follow.
Also, the father plans on sending our 11 -year-old son to Florida, alone, via airplane to visit the
paternal grandfather who has a history o f domestic violence, alcoholism and other issues
It is unreasonable for a parent to not travel and/or supervise this time.
Joint decision making should be modified because o f the new distance o f the parents and the father
has failed to perform the parenting function o f exercising appropriate judgm ent with the children
(given this latest traveling scenario).

CR 4 1, R C W 26.09 181, 260, 270, R C W 26 26 130(7)(b)
Jennifer K. Lund
2323 - 7lhStreet SE, Apt B-203
Puyallup, WA 98374
(253)256-4255
6^29^2312
2.14
17922 fese
Protection Order
Does not apply.
2.15
Servicemembers Civil Relief Act Statement

2.15.1
Service m em ber status. Jason W. Shipm an is not a service member;
B. Factual basis:
O ther factual basis: my own personal knowledge
2.15
Dependent o f a service m em ber status -- Jason W. Shipman is not a dependent o f a

resident o f W ashington who is on active duty and is a N ational Guard m em ber or a
Reservist
B Factual basis
O ther factual basis: my own personal knowledge.
III. Relief Requested

The moving party requests that the court find that there is adequate cause for hearing this petition and enter
an order modifying the custody decree/parenting plan/residential schedule in this m atter and approving the
proposed parenting plan/residential schedule, which is filed with this petition.
The m oving party also requests that the court:
Enter an order establishing child support in conjunction with the proposed parenting
plan/residential schedule. The child support worksheet and financial declaration are filed
with this petition.
I declare under penalty o f perjury under the laws o f the state o f W ashington that the foregoing is true and
correct.
Signed at Puyallup, W ashington on June 27, 2012.

CR 4 1, R C W 26 09 181, 260, 270, R C W 26 26 130(7)(b)
Jennifer K. Lund
2323 - 7thStreet SE. Apt B-203
Puyallup, WA 98374
(253) 256-4255
6 /2 9 A 2 B I2 17922 &SS
*
9
[]
Joinder
[]
I , _____________________________ J o i n in the petition. 1 understand that by joining in the petition,

a decree or judgm ent and order may be entered in accordance with the relief requested in the
petition unless, prior to the entiy o f the decree or judgm ent and order, a response is filed and
served.
[]
I waive notice o f entry o f the decree
[]
I dem and notice o f all further proceedings in this m atter. Further notice should be sent to
the following address (you m ay list an address that is not your residential address where
you agree to accept legal docum ents).
Any time this address changes while this action is pending, you m ust notify the opposing parties
in w riting and file an updated Confidential Inform ation Form (W PF DRPSCU 09 0200) with the
court clerk.
Date
Signature

C R 4 1, R C W 2 6 09 181, 260, .270, R C W 2 6 2 6 130(7)(b)
Print Name
Jennifer K. Lund
2323 - 7lhStreetSE, Apt B-203
Puyallup. WA 98374
(253) 256-4255
317'^- 2 6 B B 1
e i2
IN c o u n ty ^ H R ics o ffic e
am
JUN 2 8 2012
pm .

K E V III S T O C K , County Clerk
BY___ ^
DEPUTY
Washington State Child Support Schedule Worksheets

SZTProposed by E l (name)<J f .A .A I
Or, Q
State of W A
O th e r__________________ . (C S W P )
Signed by the Judicial/Reviewing Officer. (C S W )
M oth er Lund, Jennifer____________________________ Fath er Shipman, Jason___________________________

C ounty PIER C E_________________________________ Case No. 10-3-00961-1___________________________
Child(ren) and Age(s): Tyler/17, Hunter/11

Part 1: Income (See Instructions, Page 6)
c. Business Income
e. Other Income
f. Imputed Income
g. Total Gross Monthly Income (add lines 1a through 1f)
b. FICA (Soc.Sec.+Medicare)/Self-Employment Taxes
g. Maintenance Paid
3. Monthly Net Income (line 1g minus 2i)
(add father's and mother's monthly net incomes from line 3)
5. Basic Child Support Obligation (enter total amount in box >)
Child #1 $875
Child #3
Child #5
Child #2 $709
Child #4
Father
$ 3400
$0
$ 0
$0
$0
$0
$ 3400
Mother
$ 3000
$0
$0
$0
$0
$0
$ 3000
$ 0
$
$
$
$
$
o
o
o
0
0
$
$
$
$
$
0
0
0
0
3000
$ o
$ 0
$
$
$
$
$
$
$
o
0
0
0
0
0
3400
$ 6400
$ 1584
0.531
0.469
6 / 2 9 / 2 9 J. 2
1 7 S'
Part II: Basic Child Support Obligation (See Instructions, Page 7)

7. Each Parent's Basic Child Support Obligation without consideration
of low income limitations. (Multiply each number on line 6 by line 5)
8. Calculating low-income limitations: Fill in only those that apply.
a. Is combined Net Income Less Than $1.000? If ves. for each
b. Is monthlv Net Income Less Than Self-suDDort Reserve? If yes.
for that parent enter the presumptive $50 per child.
7- Is monthlv Net Income Greater "I han Self-suDDort Reserve? If ves.
for each parent subtract the self-support reserve from line 3. If that
amount is less than line 7, then enter that amount or the
presumptive $50 per child, whichever is greater.
$ 0
$0
$ 0
$ 0
$ 0
$0
9. Each parent's basic child support obligation after calculating

applicable limitations. For each parent, enter the lowest amount
from line 7, 8a - 8c, but not less than the presumptive $50 per child.
$ 841
$ 743
$ 743
$ 841
$ 1164
Part III: Health Care, Day Care, and Special Child Rearing Expenses (See Instructions, Page 8)
Father
Mother
$ 293
$0
$ 0
$ 0
c. Total Monthly Health Care Expenses (line 10a plus line 10b)
$ 293
$ 0
$ 293
(add father's and mother's totals from line 10c)
11. Day Care and Special Expenses
$0
$ 0
$ 0
$0
$ 0
$0
$
0
$0
$0
$ 0
$ 0
$ 0
$ 0
$0
e. Total Day Care and Special Expenses
$ 0
$0
(add lines 11a through 11 d)
12. Combined Monthly Total Day Care and Special Expenses (add
$ 0
father's and mother's day care and special expenses from line 11e)
13. Total Health Care, Day Care, and Special Expenses (line 10d plus .
$ 293
line 12)
14. Each Parent's Obligation for Health Care, Day Care, and Special
$ 156
$ 137
Expenses (multiply each number on line 6 by line 13)
Part IV: Gross Child Support Obligation
$ 997
$ 880
Part V: Child Support Credits (See Instructions, Page 9)
$ 0
$ 293
$ 0
$0
8 tl i 7 8

$0
$0

$0
$ 293
Part VI: Standard Calculation/Presumptive Transfer Payment (See Instructions, Page 9)
17. Standard Calculation (line 15 minus line 16d or $50 per child
$ 587
$ 997
whichever is greater)
Part VII; Additional Informational Calculations
18. 45% of each parent's net income from line 3 (.45 x amount from
$ 1530
$ 1350
line 3 for each parent)
19. 25% of each parent's basic support obligation from line 9 (.25 x
$ 186
$ 210
amount from line 9 for each parent)
Part VIII: Additional Factors for Consideration (See Instructions, Page 9)
20. Household Assets
Mother's
Father's
(List the estimated present value of all major household assets.)
Household
Household
$ 0
$0
a. Real Estate
$ 0
$0
b. Investments
$ 0
$ 0
$0
$0
$0
$0
$
0
$o
f. Other (describe)
$0
$0
21. Household Debt
(List liens against household assets, extraordinary debt.)
$ 0
$0
$ 0
$ 0
$ 0
$0
$ 0
$0
a. Income Of Current Spouse or Domestic Partner
(if not the other parent of this action)
$ 0
Name
$ o
Name
$ 0
$ o
b. Income Of Other Adults In Household
Name
Name
c. Gross income from overtime or from second jobs the party is
asking the court to exclude per Instruction, Page 8
d. Income Of Child(ren) (if considered extraordinary)
Name
Name
$ 0
$ 0
$ 0
$ 0
$0
$0
$0
$0
$0
$0
fe

Name
Name
f- Income From Assistance Programs
Program
Program
Ct /'
f& eise
$ 0
$ 0
$ 0
$ 0
$0
$0
$0
$0
$0
$ 0
$0

$0

$0
$ 0
Father's
24. Child Support Owed, Monthly, for Biological or Legal Children
Household
Name/age:
Paid Yes (X] No $ o
Name/age:
Paid Yes lx ] No $ 0
Name/age:
Paid | | Yes E
No $ 0
$ 0
$ 0
Mother's
Household
$ 0
$ o
$ 0
25. Other Child(ren) Livinq In Each Household

(First name(s) and age(s))
X
X
X
X
X
26. Other Factors For Consideration
Judicial/Reviewing Officer
Date
fc-
10-3-00961-1
38773301
PPP
06-28-12
S^-<.26'12 IV H2. 2 7 B iS 2
IN COUNTY S H r ICS OFFICE

a .m .
O T282012
pm.

K E V IN STO C K , County Clerk
ov
- _________ DEPUTY

County of Pierce
In re the M arriage o f
No. 10-3-00961-1
JENNIFER KAY LUND
Petitioner,
and
Proposed Parenting Plan

(PPP)

R espondent.
This parenting plan is proposed by Jennifer K. Lund.
It is OrderedAdjudged and Decreed:

TYLER SHIPMAN, age 17

HUNTER SHIPMAN, age 11

U n d e r ce rta in c irc u m s ta n c e s , as o u tlin e d below, th e c o u rt m a y lim it o r p ro h ib it a p a re n ts
co n ta c t w ith th e c h ild (re n ) a n d the rig h t to m ake d e c is io n s fo r the child(ren)
2.1

Does not apply.
Parenting Plan (PPP, PPT, PP)

WPF DR 01.0400 Mandatory (6/2008)
RCW 26.26.375, 26.09.016, .181; .187; .194
Page 1 of 8
Jennifer K. Lund
Puyallup, WA 98374
(253) 256-4255
2.2 Other Factors (RCW 26.09.191(3))

N eglect or substantial nonperform ance o f parenting functions
T he abusive use o f conflict by the parent which creates the danger o f serious damage
to the childs psychological development.
A long-term im pairm ent resulting from drug, alcohol, or other substance abuse that
interferes with the perform ance o f parenting functions.

The re s id e n tia l s c h e d u le m u s t se t fo rth w here th e ch ild (re n ) s h a ll re sid e e a ch d a y o f th e year,
in clu d in g p ro v is io n s fo r holidays, b irth d a ys o f fa m ily m em b ers, vacations, a n d o th e r s p e c ia l
occasions, a n d w h a t c o n ta c t the c h ild (ren) s h a ll h a v e w ith each p a re n t P a re n ts are e n c o u ra g e d
to create a re s id e n tia l s c h e d u le th a t m e e ts th e d e v e lo p m e n ta l n e e d s o f the ch ild(ren) a n d
in d iv id u a l n e e d s o f th e ir fa m ily P a ra g ra p h s 3 1 th ro u g h 3 9 are one w a y to w rite y o u r
re s id e n tia l s c h e d u le I f y o u do n o t u se these p a ra g ra p h s, w rite in y o u r ow n s ch e d u le in
P a ra g ra p h 3 .1 3
3.1
Schedule for Children Under School age.

T here are no children under school age.
3.2
School Schedule
A fter enrollm ent in school, the child shall reside w ith the m other except for the follow ing times
the children reside with the father:
The children shall reside with the father from Friday at 5:00 p.m through Sunday at 5:00 p m.
every other weekend.
The father also shall have residential time from 5:00 p.m. through 8 00 p.m. every W ednesday.
3.3

T he w inter vacation shall be split evenly between the parents, with the father having the first
h a lf o f the vacation in even-numbered years and the m other having the first h alf in odd
num bered years.
3.4 Schedule for Other School Breaks

Same as 3 3

RCW 26.26.375, 26.09.016, .181; .187; .194
Page 2 of 8
Jennifer K. Lund
Puyallup, WA 98374
(253) 256-4255
> '2 9 > 2 8 1 2
3.5
7"
?S @ iS 4
Summer Schedule
Upon the com pletion o f the school year, the children shall reside with the mother, except for the
follow ing days and times when the children shall reside with the other parent:
The father shall have the first five weeks o f residential tim e during the sum m er break
3.6

Does not apply.
3.7

The residential schedule for the children for the holidays listed below is as follows
With M other
(Specify Year
O dd/Even/Everv)
New Y e ar's Day
M artin L uther King Day
Presidents Day
M em orial Day
July 4 th
Labor Day
V eterans Day
T hanksgiving Day
C hristm as Eve
C hristm as Day
N ew Y ears Eve
Easter Sunday
see 3.3
Even
Odd
Even
Odd
Even
Odd
Odd
Odd
Even
Even
Odd
With Father
(Specify Y ear
O dd/Even/Everv)
see 3 3
Odd
Even
Odd
Even
Odd
Even
Even
Even
Odd
Odd
Even
A holiday shall begin at 8:00 a m. and ends at 10:00 p.m., unless it is the fathers holiday and
m others workday, on which day the holiday begins at 6:30 a.m , and ends at 10.00 p.m. the
10:00 p.m. end to the holiday does not apply to the Fourth o f July, which ends at m idnight
H olidays which fall on Friday or Monday shall include Saturday and Sunday.
3.8

The residential schedule for the children for the follow ing special occasions (for example,
W ith M other
With Father
(Specify Year
(Specify Year
O dd/Even/Everv)
O dd/Even/Everv)
M others Day
Every

RCW 26.26.375, 26.09.016, .181; .187; .194
Page 3 Of 8
Jennifer K. Lund
2323 - 7thStreet SE. Apt. B-203
Puyallup. WA 98374
(253)256-4255
S . '2 9 - ' 2 B 1 2
37922
7 8 B IB S
F ath er's Day

C hildrens Birthday
M others Birthday
Fathers B irthday
Even
Every
Every
Odd
Every
Special occasions shall begin at 8:00 a.m. and end at 10 00 p.m., unless it is father's special
occasion and m others workday, on which days the special occasion beings at 6:30 a.m.
3.9

Rank the order o f priority, with 1 being given the highest priority:
1 -special occasions (3.8)
2 -h o lid a y s (3.7)
3 - winter vacation (3 3)
4 - school breaks (3 4)
5 - summer schedule (3.5)
6 - school schedule (3 1,3.2)
3.10
Restrictions
Does not apply because there are no limiting factors in paragraphs 2.1 or 2 2.
3.11
Transportation costs are included in the children Support W orksheets and/or the O rder for
children Support and should not be included here.
Transportation arrangements for the children betw een parents shall be as follows:
The delivering parent shall provide transportation to the paternal grandparents home, unless the
parties agree to a different exchange point.
3.12
The children nam ed in this parenting plan are scheduled to reside a m ajority o f time w ith the
mother. This parent is designated the custodian o f the child(ren) solely for purposes o f all other
state and federal statutes which require a designation or determ ination o f custody This
designation shall not affect either parents rights and responsibilities under this parenting plan.
3.13
Other
a.
It is the responsibility o f the parent scheduled to have the children to arrange suitable
alternative care if necessary andto pay for the needed care
b.
Each parent shall notify the other at least 48 hours in advance if he o r she is unable to
com ply with the regular schedule.

RCW 26.26.375, 26.09.016, .181; .187; .194
Page 4 Of 8
Jennifer K. Lund
Puyallup. WA 98374
(253)256-4255
-y2 9 Z 2 B 12
i ? 9 2 '2
Each parent shall keep the other apprised of his or her current residence address and
residence telephone number.
d.
Bothe parents shall have unlimited access to the childrens school, daycare, and medical
records. Neither parent may revoke this provision by telling the providers to disobey
this court order
Telephone Access. The children shall have reasonable telephone privileges with the
parent with whom the children are not then residing, without interference of the
residential parent.
f.

1. The children shall be accompanied by the parent with whom the
children are residing at the time of a given social event The other
parent shall not be limited from attendance at that event, providing said
participants
2. Each parent shall be responsible for keeping themselves advised of the
school, athletic, and social events in which the children participate.
Both parents may participate in school activities for the children, such
as open house, attendance at an athletic event, etc.
g.
Gun Safety
1 Both parents shall keep household guns locked up in a location not
accessible to the children.
2. The father shall enroll Hunter in a gun safety course within 14 days and
provide proof to the mother of Hunters successful completion of the
course within 3 days of completion. If he does not do so a finding of
contempt of this provision will result in a monetary sanction of $500.
h.
Travel alone
Neither parent shall have Hunter travel by airplane, train, bus, boat or vehicle without
adult accompaniment until Hunter is 16 years old.
3.14
Summary of RCW 26.09.430 - 480, Regarding Relocation of a Child
This is a summary only. For the full text, please see RCW 26.09.430 through 26 09.480.
If the person with whom the children reside a majority of the time plans to move, that person
shall give notice to every person entitled to court ordered time with the child
personal service or by mail requiring a return receipt This notice must be at least 60 days before
RCW 26.26.375, 26.09.016, .181; .187; .194
Page 5 of 8
Jennifer K . Lund
2323 - 7,hStreet SE, Apt B-203
Puyallup, WA 98374
(253)256-4255
6 2 2 9 ^ 2 ft 1 2
1732-2
7 &b i h ?
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).
any reasonable means. A person entitled to time with the children may not object to the move
but may ask for modification under RCW 26.09.260.
and safety of a person or children at risk.
If no objection is filed within 30 days after service of the notice of intended relocation, the
relocation will be permitted and the proposed revised residential schedule may be
confirmed.
A person entitled to time with a children under a court order can file an objection to the childs
The relocating person shall not move the children during the time for objection unless: (a) the
delayed notice provisions apply, or (b) a court order allows the move.
objection, the relocating person shall not move the children before the hearing unless there is a
IV. Decision Making
4.1
Day to Day Decisions
Each parent shall make decisions regarding the day-to-day care and control of each children
while the children are residing with that parent. Regardless of the allocation of decision making
in this parenting plan, either parent may make emergency decisions affecting the health or safety
of the children.
4.2
Major Decisions
Major decisions regarding each children shall be made as follows.

RCW 26.26.375, 26.09.016, .181; .187; .194
Paae 6 Of 8
Jennifer K. Lund
2323 - 7lhStreet SE. Apt. B-203
Puyallup, WA 98374
(253)256-4255
& -/2922B 1
Education decisions
Sports/cIub/Extra-curricular activities
4.3
-V
?B 8lSB
Mother
Mother
Mother
Mother
Sole decision making shall be ordered to the mother for the following reasons*
One parent is opposed to mutual decision making, and such opposition is
reasonably based on the following criteria:
(a)
(b)
(c)
(d)
The existence of a limitation under RCW 26 09.191;

The history of participation of each parent in decision making in each of
the areas in RCW 26 09.184(4)(a);
Whether the parents have demonstrated ability and desire to cooperate
with one another in decision making in each of the areas in
RCW 26.09.184(4)(a); and
The parents geographic proximity to one another, to the extent that it
affects their ability to make timely mutual decisions.
The purpose of this dispute resolution process is to resolve disagreements about carrying out
this parenting plan. This dispute resolution process may, and under some local court rules or
the provisions of this plan must, be used before filing a petition to modify the plan or a motion
for contempt for failing to follow the plan.
Mediation with Pierce County Center for Dispute Resolution. Costs shall be shared in the same
proportion as line 6 of the Child Support Worksheets.

I declare under penalty of perjury under the laws of the state of Washington that this plan has been
proposed in good faith and that the statements in Part II of this Plan are true and correct.
Signed at Puyallup, Washington on June 27, 2012.

RCW 26.26.375, 26.09.016, .181; .187; .194
Page 7 of 8
Jennifer K. Lund
Puyallup, WA 98374
(253) 256-4255

order o f this court.
Warning: V iolation o f residential provisions o f this order with actual know ledge o f its term s is
punishable by contem pt o f court and may be a crim inal offense under RCW 9A 40.060(2) or
RCW 9 A.40.070(2) Violation o f this order m ay subject a violator to arrest.
When mutual decision m aking is designated but cannot be achieved, the parties shall make a good faith
effort to resolve the issue through the dispute resolution process
If a parent fails to comply with a provision o f this plan, the other parents obligations under the plan are
not affected.
D a te d :______________________________________
_________________________
Judge/Commissioner
Presented by:
Approved for entry:
Jennifer K. Lund
Petitioner
Jason W. Shipman
R espondent

RCW 26.26.375, 26.09.016, .181; .187; .194
Page 8 of 8
Jennifer K. Lund
Puyallup, WA 98374
(253) 256-4255
h'2^/?A % rz 1 7 ^ 2
10-3-00961-1
38775246
CME
06-29-12

Cause
Petitioner(s)
Number 10-3-00961-1
vs
Page 1 of 2

Respondent(s)
Judge/Commissioner WENDY ELLEN ZICHT
Court Reporter, Smart Court
Judicial Assistant/Clerk Chelsea Glanz
SHIPMAN, JENN IFER KAY

SHIPMAN, JA SO N WILLIAM
Daniel N Cook
Attorney for R espondent
SHIPMAN, TYLER
SHIPMAN, HUNTER
Proceeding Set Exparte Action

Proceeding Outcome Held
Resolution
Outcome Date 06/28/2012 10 42

Proceeding Outcome code HELD
R eport run date/tim e 06/28/12 10 51 AM
Ixcalcivil pbl d_civiljoumat_report_cover
fj
2 9
? .B 1 2
i?9 2 r?


MEMORANDUM OF
JOURNAL ENTRY
vs
Page 2 of 2
Judge/Commissioner
WENDY ELLEN ZICHT
________________________________MINUTES OF PROCEEDING___________
Judicial Assistant/Clerk Chelsea Glanz
Court Reporter Smart Court
June 28, 2012 10.42 AM

Petitioner Jennifer Shipman NKA Lund comes before the court seeking a Temporary Order.
JIS reviewed. Respondent may seek to have this order reviewed with proper notice
provided to the Petitioner. Court signs order.
JUDGE/COMMISSIONER WENDY ELLEN ZICHT Year 2012
E^ 2 s ^ 2 n i 2
TPROTSC
06-29-12
COUNTY CLERK'S OFFICE
AM JUN 2 8 2012

County of King
PM
-DEPUTY
No. 10-3-00961-1
JENNIFER KAY LUND

Ex Parte Restraining
Order/Order To Show Cause
(Parentage)
(TPROTSC/ORTSC)
Petitioner,
and
[X] Clerks Action Required

[X] Law Enforcement Notification,
%4.1
Respondent.
Restraining Order Summary:
Restraining Order Summary is set forth below:
Name of person(s) restrained: JASON W. SHIPMAN
Name of person(s) protected: HUNTER SHIPMAN, age 11
______________________________________________________ See paragraph 4.1.

V io la tio n o f a R e s tr a in in g O r d e r in P a r a g r a p h 4 .1 b e lo w w ith a c tu a l k n o w le d g e o f its
t e r m s is a c r im in a l o ffe n s e u n d e r C h a p te r 2 6 .5 0 R C W a n d w ill s u b je c t th e v io la to r to
a r r e s t R C W 2 6 .2 6 .5 9 0 .
I. Show Cause Order
It is ordered that JASON W, SHIPMAN appear and show cause, if any, why the restraints below should
not be continued in full force and effect pending final determination of this action and why the other
relief, if any, requested in the motion should not be granted. A hearing has been set for the following
date, time and place:
Date: July *h I____ ,2012
Place. Pierce County Superior Court
401 - Fourth Ave. N.
Kent, WA 98032
Time: 9:00 AM
Room/Department: M> f t o f a l OK (U v tft m
Ex Parte Restraining Order (TPROTSC/ORTSC) - Page 1 o f 3

WPF PS 04 0170 Mandatory (6/2008) - CR 65(b), RC W 26 26 590
6 / 2 9 / 28 i 2
i 7-928
If you disagree with any part of the motion, you must respond to the motion in writing before the
hearing and by the deadline for your county. At the hearing, the court will consider W ritte n sworn
affidavits or declarations. Oral testimony may N o t be allowed. To respond you must: (1) file your
documents with the court; (2) provide a copy of those documents to the judge or commissioners
staff; (3) serve the other partys attorney with copies of your documents (or have the other party
served if that party does not have an attorney); and (4) complete your filing and service of documents
within the time period required by the local court rules in effect in your county. If you need more
information, you are advised to consult an attorney or a courthouse facilitator.
F a ilu r e to a p p e a r m a y r e s u lt in a T e m p o r a r y O r d e r b e in g e n te r e d b y th e c o u r t w h ic h
g r a n ts th e r e lie f r e q u e s t e d in th e m o tio n w ith o u t fu r th e r n o tic e .
II. Basis
A motion for a temporary restraining order without written or oral notice to Carmen S. Jackson or that
party's lawyer has been made to this court.
III. Findings
The court adopts paragraphs 2.1, 2.2, and 2.4 of the Motion/Declaration for an Ex Parte Restraining
Order and for an Order to Show Cause (Form WPF PS 04.0150) as its findings, except as follows:
[]
Further, the court finds that the nonrequesting party is absent and a) is on active duty as a National
Guard member or Reservist residing in Washington, or b) is a dependent of a National Guard
member or Reservist residing in Washington on active duty. Despite the service members or
dependents absence, failure to enter the temporary orders below would result in manifest injustice
to the other interested parties.
IV. Order
I t is O r d e r e d :
4.1
Restraining Order
V io la tio n o f a R e s tr a in in g O r d e r in P a r a g r a p h 4 .1 w ith a c t u a l n o tic e o f its te rm s is
a c r im in a l o ffe n s e u n d e r C h a p t e r 2 6 .5 0 R C W a n d w ill s u b je c t th e v io la to r to a rre s t.
R C W 2 6 .2 6 .5 9 0 .
[]
Does not apply
Jason W. Shipman is restrained from taking 11-year-old Hunter Shipman, or arranging for Hunter
Shipman, to go outside of the State W^hingFri |i i ifi illj tfimli i in nnttn h"
rn an
ffifpfiSnpwithout adult supervision.
The clerk of the court shall forward a copy of this order, on or before
the next judicial day, to Pierce County Sheriff which shall enter this order into any
computer-based criminal intelligence system available in this state used by law
______enforcement agencies to list outstanding warrants. (A law enforcement information
[ ]
C le r k s A c t io n .

WPF PS 04.0170 Mandatory (6/2008) - CR 65(b), R C W 26 26 590
6 7 2 9 -'2 8 i 2
1 7 9 2 8
i < * V 8 8# s 3
sheet must be completed by the party or the partys attorney and provided with this
order before this order will be entered into the law enforcement computer system.)
Service
The requesting party must arrange for service of this order on the restrained party File the original
Return of Service with the clerk and provide a copy to the law enforcement agency listed above.
F u ll F a ith a n d C re d it
Pursuant to 18 U.S.C. 2265, a court in any of the 50 states, the District of Columbia, Puerto Rico,
any United States territory, and any tribal land within the United States shall accord full faith and
credit to the order.
4.2
Other Restraining Order
BOTH PARTIES are restrained and enjoined from removing any of the children from the state of
Washington
4.3
Surrender of Deadly Weapons
Does not apply.

4.4
4.5
Expiration Date
ju J L C b 'fe ^ c li'l /o - F*.

This order shall expire on the hearing date set forth above , unlcs3 otherwise extended-by thecourt-.
Waiver of Bond
Does not apply.

4.6
Other
nnp chaii
thp rS ^ '
out a Valid d rive n
license, insurance jc v . appropriate child safely
restraints----------------------------------------------------------Parties shall comply wiu ^ ^stm g court orders and

treatment requirements, ii
. - *'e, from any Ursai,
ppijr-1i<-'irir>l
gnnannr nr
o r I ij t_________
Dated June
Fetitioner/l|6sponde^Plainiiff/Defenaant
may seek-review of this order in the
Ex Parte Department, Room 105, prior to
the scheduled hearing, after giving at
least 24 hours notice to the opposing
DQrty or his/her attorney ANDupon
Presented by.
Q m a iI u
Jennifer K&und
Petitioner
FILED
IN COUNTYCLERK'S OFFICE
k .
5 w u l
fr /W /P -
Date

WPF PS 04 0170 Mandatory (6/2008) - CR 65(b), R C W 26 26 590
AM
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PIERCECOUNTYSUPERIORCOURT S38TACOMAAWE8 TAC0MA>WASMMSTOKI
E-FILE
IN COUNTY CLEI
PIERCE COUNTY, '
June 29 2012
1
KEVIN ST
COUNTY C
NO: 10-3-0
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4
5
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7

COUNTY OF PIERCE
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In th e M a rria g e of:
J e n n ife r K a y S h ip m a n
P e titio n e r,
12
v.
13
Ja s o n W illia m S h ip m a n
14
15
R e sp o n d e n t.
)
)
)
)
C A S E N O .: 10 -3 -0 0 9 6 1 -1
)
)
N O T IC E O F A T T O R N E Y S
IN T E N T T O W IT H D R A W
)
)
)
)
16
17
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T O : C le rk o f th e co u rt
A N D T O : Ja so n S h ip m a n , P ro Se
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P L E A S E T A K E N O T IC E th a t T im o th y M . G re e n e in te n d s to w ith d ra w as a tto rn e y fo r
21
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th e P e titio n e r as o f J u n e 29, 2 0 1 2 . T h is w ith d ra w a l shall b e e ffe c tiv e w ith o u t C o u rt o rd e r u n le s s

an o b je c tio n is serv ed u p o n th e w ith d ra w in g a tto rn e y b e fo re Ju n e 29, 2012.
24
25
26
NOTICE OF INTENT
TO WITHDRAW
1 of 2

P.O. Box 731063 / 14705 Meridian East
(253) 770-0808, Fax (253) 770-0259
1
2
T h e la s t k n o w n ad d re ss o f th e p e titio n e r to w h ic h fu tu re p le a d in g s in th is m a tte r sh o u ld
b e d ire c te d is:
3
4
5
N am e
J e n n ife r K a y S h ip m a n
2 3 2 3 7th S tre e t S E # B 203
P u y a llu p W A 9 8 3 7 4
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7
D A T E D th is
2 9 th
d ay o f J u n e , 2012.
G R EEN E & LLOY D, PLLC
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BY:
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/S/ TIMOTHY M. GREENE

TIMOTHY M. GREENE, WSBA #17499
Attorney for Petitioner
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DECLARATION OF M AILING /DELIVERY THE

UNDERSIGNED CERTIFIES UNDER PENALTY OF
PERJURY UNDER THE LAWS OF THE STATE OF
WASHINGTON, THAT ON THE BELOW DATE I
CAUSED TO BE [x ] M AILED [ ] DELIVERED BY
LEGAL MESSENGER SERVICE, A TRUE COPY
OF THIS DOCUMENT TO:
Jennifer Shipman
2323 7th Street SE #B203
Puyallup W A 98374
Jason W. Shipman
11721 80th Avenue East
Puvallup W A 98373
DATED THIS 29th

DAY OF June , 2012
AT PUYALLUP, WASHINGTON
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/S/
BETTYANN WALTER *2
Bettyann Walter , LEGAL ASSISTANT
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NOTICE OF INTENT
TO WITHDRAW
2 of 2

P.O. Box 731063 / 14705 Meridian East
(253) 770-0808, Fax (253) 770-0259
FILED
' B B S S *
j^ o iW S 1 0 -3 -0 0 9 6 1 -1
38797589
CME
07-03-12
PIERCE COUHTY, Clerk

y
DEWY

Cause Number: 10-3-00961 -1
Petitioner(s)
vs.
Page 1 of 2

Respondent(s)
Judge/Commissioner: DIANA LYNN KIESEL
Court Reporter Smart Court
Judicial Assistant/Clerk Jennifer Allyn

Daniel N Cook
Attorney for R esp o n d en t
SHIPMAN. TYLER
SHIPMAN, HUNTER
Proceeding Set: Ex Parte Action-Return Hearing

Resolution:
Outcome Date: 07/02/2012 13:46
Clerk's Scomis Code.MTHRG

Report run date/time 07/02/12 2.11 PM

tx c a ld v il.p b l.d _ c iv iljo u m a ljr e p o r t_ c o v e r


MEMORANDUM OF
JOURNAL ENTRY
vs.
Page 2 of 2
Judge/Commissioner:
DIANA LYNN KIESEL
________________________________ MINUTES OF PROCEEDING___________

Court ReportenSmart Court
July 02, 2012 01:47 PM

Respondent Jason Shipman comes before the court with a request to amend previously
signed exparte restraining order. Also present is petitioner Jennifer Shipman.
JIS reviewed. Parties are to follow current exparte order. Child may not leave the state of
Washington pending further hearing.
JUDGE/COMMISSIONER DIANA LYNN KIESEL Year 2012
E-FILED
IN COUNTY CLERK'S OFF
PIERCE COUNTY, WASHINC
July 05 2012 11:40 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
5
6
7

10
11

NO. 10-3-00961-1
Petitioner,
12
v.
13
NOTICE OF INTENT TO WITHDRAW

AS ATTORNEY
____________________ Respondent.
14
TO:
CLERK OF THE COURT
15
16
17
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NOTICE IS HEREBY GIVEN that pursuant to CR 71(c) Daniel N. Cook of

Faubion, Reeder, Fraley & Cook, P.S. intends to withdraw as counsel of record for the
above Respondent, Jason William Shipman, on the 17th day of July 2012. The
withdrawal as counsel of record shall be effective immediately, without order of the
Court unless an objection to said withdrawal is served upon Daniel N. Cook within 10
days.
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20
21
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For purposes of further process of service, the last known address for
Respondent, which is known to be the true and correct address, is 11721 80th Ave E,
Sumner, WA 98390. Trial is currently scheduled in this case for March 7, 2013.
DATED July 5 , 2 0 1 2 .
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24
EtyDaniel N.Cook, WSBA348S6'~~------Of Attorneys for Respondent
25

S :\C A S E S 1 \1 P le a d in g s \N o tic e o f I n te n t to W itM r a w .d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
DECLARATION OF MAILING
2
3
4
I, Amber Johnson, am over the age of 18, and competent to testify in the abovecaptioned case.
5
6
On July 5, 2012, I mailed true and correct copies of the above Notice of Intent to
Withdraw. The documents were mailed via first class mail, via regular mail, postage
pre-paid, to:
8
9
10
11
Jason Shipman
11721 80th Avenue ESumner, WA 98390
STATE OF WASHINGTON, THAT THE FOREGOING IS TRUE AND CORRECT.
12
Signed on Wednesday, July 05, 2012, at Lakewood, Washington.
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/ tlllU C I
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J U I II IO U I I
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S : \ C A S E S 1 \ 1 P le a d in g s W o tic e o f I n te n t to W ith d r a w .d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, \
July 31 2012 1
1
KEVIN ST
COUNTY C
2
3
4
5
6
7
8
Petitioner(s),
10
Cause No.
10-3-00961-1
Order Continuing
Adequate Cause Hearing
vs.
11

12
Respondent(s)
Clerks Filing code: ORACONT
13
14
15
16
THIS MATTER having come on regularly for hearing to determine if there is adequate cause to
proceed to trial with regard to a Petition which has been filed,
17
Now, therefore, it is hereby
18
ORDERED the Show Cause hearing determining Adequate Cause is continued.
19
20
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22
Dated this
31 day of July, 2012
23
24
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/S/ROBYN LINDSAY
ROBYN LINDSAY
Judge/Commissioner
E-FILED
July 31 2012 10:04 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)

Address: 11721 80TH AVE E PUYALLUP, WA 98373
Phone: (253) 686-3971

Respondent
Pierce County Superior Court, County-City Building - 930 Tacom a Ave S - Tacoma, W A 98402
Show Cause
Nature of Hearing:
Child Support, Parenting Plans, Restraining Orders
CALENDAR DATE: Wednesday, September 19, 2012 9:30 AM

W O RKING COPIES SHALL BE SUBMITTED TO COMMISSIONERS SERVICES ROOM 140,
BEFORE 12:00 NOON TW O COURT DAYS PRIOR TO HEARING
DATED:
July 31, 2012.
Signed:
/s/ JENNIFER KAY SHIPMAN
NAME:
Phone:
(253) 256-4255
ADDRESS: 2323 7TH STREET SE #B203

PUYALLUP, WA 98374
WSBA#:
For:
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For Petitioner
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Clerk:
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Jxcrtrpt pbl dJouma!_en try_ sbowca use_ report
'1
10-3-00961-1
38947676
RTS
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20 i 2
08-0 M !

County of Pierce
No. 10-3-00961-1
JENNIFER KAY LUND

Petitioner,
and
Return of Service
(Optional Use)
(RTS)

Respondent.
/ Declare:
1,
lam over the age o f 18 years, and I am not a party to this action.
2,
1 served the following documents to JASON WILLIAM SHIPMAN:
3,
[x]
[x]
[x]
[x]
summons, a copy o f which is attached

petition in this action
proposed parenting plan or residential schedule
proposed child support worksheets
other: Ex p o r { ^ resfaximwomar
9
a
ovtW
S&ttvag c a s e S cKiAu3 ^
n o k - f a - Q oranU fistofiers C A M M o r ___________________________
motion for and ex parte order
The date, time and place o f service were (if by mail refer to Paragraph 4 below):
Date:
______________________________ Time: ________________ *_________ a.m./p.m.
Address:
__________
Return of Service (RTS) - Page 1 of 2

WPF DRPSCU 01.0250 (6/2010) - CR 4(g), R C W 4.28.080(15)
4.
5.
Servi ce wa s made:
VC
[]
by delivery to (name)____________________________________, a person of

suitable age and discretion residing at the respondents usual abode.
Other:
correct.
Signed at (city)
/<\rr\______________, Washington on \ A\\j
Amy M. Edwards V)oDCK~aA^ R.
Return o f Service (RTS) - Page 2 of 2

WPF DRPSCU 01.0250 (6/2010) - CR 4(g), RCW 4.28.080(15)
__________ , 2012.
3 O f t i "? ;

County of Pierce
No. 10-3-00961 1
JENNIFER KAY LUND

Petitioner,
and
$um m ons(M odification/

A djustm ent o f Custody
O ecree/Parenting Plan/
R esidential Schedule)
(SM )
Respondent.
To:
JASON W. SHIPMAN
1.
2.
You must respond to this notice and petition by serving a copy of your written response on the
person signing this summons and by filing the original with the clerk of the court. If you do not
serve your written response within 20 days (or 60 days if you are served outside of the state of
Washington) after the date this summons was served on you, exclusive of the day of service, the
court may enter an order of default against you, and the court may, without further notice to >ou.
enter an order regarding adequate cause and a decree to modify/adjust the custody
decree/parenting plan/residential schedule and providing for other relief requested in the petition
If you serve a notice of appearance on the undersigned person, you are entitled to notice before
an order of default or a decree may be entered.
3.
Temporary residential placement or custody is not being sought.

WPF DRPSCU 07.0120 Mandatory (7/2007) - CR 4.1: R C W 26.09.270: 26.10.020
Opposing Party I
rfli5 6 9
3Ssi?6
<s-;+
&
hearing. If you do not file an opposing declaration or respond and the court finds that adequate
cause exists, the court may enter an adequate cause order and an order moditying-/adj Listing the
26.09.270.
5.
Your written response to the summons and petition must be on form WPF DRPSCU 07.0200.
Response to Petition for Modification/Adjustment of Custody Decree/Parenting Plan/Residential
Schedule. This form may be obtained by contacting the clerk of the court at the address below,
by contacting the Administrative Office of the Courts at (360) 705-5328, or from the Internet at
the Washington State Courts homepage:
http ://ww w.cou rts.wa.gov/forms
6.
signing this notice. Within 14 days after you serve the demand, the petitioner must file this
action with the court, or the service on you of this notice and motion will be void.
7.
If you wish to seek the advice of an attorney in this matter, you should do so promptly so that
your written response, if any, may be served on time.
8.
One method of serving a copy of your response on the petitioner is to send it by certified mail
with return receipt requested.
Dated June 27, 2012
'e h
k .
lu
td
inifer K^Lund
Petitioner
File original of your response with
the clerk o f the court a t
Serve a copy of your response on:

930 Tacoma Ave. S.
Tacoma, WA
Jennifer K. Lund
2323 - 7thStreet SE, Apt. B-203
Puyallup, WA 98374

WPF DRPSCU 07.0120 Mandatory (7/2007) - CR 4.1; R C W 26.09.270:26.10.020
1 (j.f.Q
0 'j/
320 i 7 7

Jennifer Lund and I drove from Puyallup WA to Yelm WA on Thursday 6/28/12
at 6:20 PM to serve Jason Shipman the restraining order and court documents. We did not
have an address for his fiancee Kasey Riggs, but his son, Hunter Shipman, had said that
she lives by Safeway in Yelm. So I looked for his work van in a neighborhood near
Safeway. Luckily 1 found his work van. I was not sure which house was Kaseys so I
knocked on three different home doors. The third house was where his fiancee Kasey
lives. A girl about 10-11 years of age answered the door and I smelled a dirty, musty
stench coming from the home. I asked the girl if Jason Shipman was there? She told me
that he was not home and did not know what time he would be back. Then I noticed that
Jasons youngest son Hunter was playing video games in the living room. 1 asked Hunter
where his dad was at or if he knew when his dad would be home. Hunter told me that his
dad and Kasey were at a motorcycle meeting. Hunter did not know when his dad would
be home.
I then left the property, got into my car and drove to Safeway parking lot to sit and wait
for Jason to return home. We sat there for an hour waiting then decided to get a bite to
eat. While eating dinner I received a phone call from my husband that Jason had left him
a voicemail saying Hey Greg, call me back, we need to have a serious conversation.
We then decided to go back to Kaseys house to see if Jason had returned home from his
meeting. When I knocked on the door the same girl answered. She said that Jason was not
home and they were going to bed. We decided to go back to Safeway parking lot and wait
for Jason again. We waited until 11:30pm for him to show up, but he never did. I thought
it was strange that a parent would not be home by 11:30pm on a work night and leave
four children under the age of 12 home alone without any adult supervision.
Amy Edwards
1022-13* Street SW
Puyallup, WA 98371
(253)228-2263
196 9
6.^1.^2612
300178
To whom it may concern:

On the evening of July 1st 2012,1, Deborah R. Bergman, accompanied Jennifer Lund to the home of Jason
Shipman and his parents, Pete and Becky Rambow, residing at 1172180thAve E in Puyallup, Washington
98373. We arrived around 6:45pm. As I was rounding the back of the house, where I heard children and
adults playing baseball, I made eye contact with Jason Shipman. His sister, Staci, said, "Sorry, Jason, they
caught up to you ." I looked down to keep from tripping on loose gravel. When I looked up, Jason had
disappeared around to the front of the house. Jennifer saw him enter the residence through the front
door. Jason's sister, Sierra, told me, "Sorry Jason's not here." I asked, "Oh...that wasn't just Jason I saw?"
Sierra replied, "Uh, well this is private property, so you need to get off and leave " Their niece,
Samantha, then added, "Yeah, you are trespassing on private property, so get the hell off!" Staci then
jumped in and said, "Sorry, you need to leave now! This is private property and you are trespassing and
you need to leave." I said, "Thank you, have a nice day," and l returned to Jennifer's vehicle.
As I was relaying what was said to Jennifer, Jason's fiancee drove away in a white minivan. Jason
followed soon after in his mother's vehicle. Jennifer called the Puyallup Police Department's nonemergent number to see if they could provide us with the civil restraining order and other documents or
serve him a civil stand-by. The dispatcher informed Jennifer that Puyallup P.D. does not service that area
and that she would need to call the Pierce County Sheriff's Department. While she was on the phone,
Jason's brother, Theodore Shipman approached the driver's side window and said to Jennifer, "Sorry, it's
not going to happen today. You need to get off our property." Theodore pointed to 117th St and said,
"Go park over there. You can't park here." Jennifer replied, "I am on the phone with the Sheriff's
Department," while rolling up her window. Jennifer was parked on the easement of 80th Ave the entire
time. She technically was never on Pete and Becky's property. Jennifer did move to appease Theodore.
Kasey came back while Jennifer and I were waiting for an officer from the Pierce County Sherriff's
Department to arrive. Deputy Christian (Badge#477) and Deputy Burke (546) arrived just before 7:15pm.
The Deputies informed Jennifer and I that they no longer get involved with serving civil restraining
orders, but would be happy to talk with Kasey to get this matter resolved. After talking with Kasey for a
bit, the deputies returned to Jennifer's vehicle and informed us that Kasey did not want to, and did not
have to accept the court papers containing the restraining order and other documents on Jason's behalf.
Deputy Christian then went to his vehicle and returned to us with a number for the Pierce County Civil
Department. He told us that the Pierce County Civil Department may be able to help with the serving of
papers.
We left Pete and Becky Rambow's residence at about 7;45pm and drove to the Handi Corner on 112th.
We sat there waiting for Jason to drive by until about 8:10pm. While driving down 112th on our way back
to my vehicle, we passed Jason and he flipped his middle finger at us as he drove by. We traded vehicles
and arrived back at the Rambow's residence around 8:25pm. The minivan was gone. We drove to the
gas station and filled up. We left Puyallup at approximately 8:52pm.
We arrived in Yelm at Jason and Kase/s house at around 9:15pm. When we drove by, the white minivan
was not there, so Jennifer drove us to Jack-In-The-Box for some dinner. We returned approximately 30
minutes later. Jason and Kasey's garage was open and the white minivan was parked across the road
next to Jason's work truck. Kasey was standing outside of the garage, smoking. Jennifer and I circled the
block one time to see if Jason would join her. When we came back around, the garage was closed and
Kasey was no longer in sight.
Jennifer parked at the top of the cul-de-sac in hopes of seeing Jason come out. As we were waiting,
Kasey came out to smoke but Jason did not join her. Soon after, a Yelm Police Officer pulled up behind
us. The neighbors had called them because Jennifer and I were parked by mail boxes and they were
concerned. He asked what we were doing there and Jennifer informed him that we were trying to serve
her ex-husband with a Civil Restraining Order and other Documents. Kasey was still outside and the
officer offered to talk with her to find out if Jason was home. Kasey told the officer that he was not
there and she did not know when he would return.
The officer asked us to park somewhere else, so Jennifer and I parked in the Safeway Parking Lot. This
still provided a line of sight to the cul-de-sac where Jason's residence was and continued waiting for his
return. At 11:10pm, Jason drove his Harley Davidson into the Safeway Parking Lot and parked two rows
behind our vehicle. He glared at us while he spoke on his cell phone to someone. A few moments later,
his fiancee Kasey pulled into a stall by him and they began talking. Then Jason drove up and parked by
the passenger window, where 1was sitting. As we were trying to roll the passenger window down, Jason
said, "Well come oni Roll down the window; Roll down the fucking window!" Once I got the window
down, Jason said, "Three Stars!" I handed him the paperwork and said, "Jason Shipman, you've been
served." Jason Shipman was served at 11:19pm.
Jennifer was so upset by Jason's anger and harsh words that it took her a half of an hour to be able to
drive us back to Puyallup.
If there are any questions or concerns, I can be reached at 253-486-6309.
Thank you,
(Name Printed)
(Signature)
I9fef9
S / 1 72 y ! 2
3S*^'8
IN OPEN C O U R T
08-01-1:
V
38947677
*H
10' 5-00961
ML
3I
2012
.PIERCE COUNTY, Clerk

v
deputy

County of
No- JO dfflfrl /
In re:
Jw m fa S fo ip W I
O rder re Adequate Cause

(M odification/A djustm ent of
C ustody Decree/Parenting
Plan/R esidential Schedule)
Denied (ORRACD)
Petitioner,
and
^ if At(/
^
Respondent.
_ Hearing se t (ORH)
r- erks Action Required
I. Basis
1.1
A petition requesting the modification/adjustment of the custody decree/parenting

plan/residential schedule in this matter has been presented to the court.
12
A hearing was held on
vi/ty j
31
2 0
Y?~
[Date].
II. Findings
The Court Finds:

2.1
Jurisdiction
This court has jurisdiction over the proceeding and the parties.
2.2
Service on Nonm oving Party
The nonmoving party was served with a copy of the petition for modification/adjustment of
custody decree/parenting plan/residential schedule, summons, a proposed parenting plan, and
child support worksheet, if any, on____
|j
____[âte]-
Ord re Adequate Cause (ORRACD, ORRACG, ORH) - Page 1 of 3

WPF DRPSCU 07.0300 Mandatory (7/2007) - RCW 26.09.260; .270; 26.10.200
2.3
9(-1. q
B ' 1 y 2** 1 2
3S01S1
Tim e Elapsed S ince Service on the Nonm oving Party
The nonmoving party was served within the state of Washington and more than 20 days
have elapsed since the date of service.
The nonmoving party was served outside the state of Washington and more than 60 days
have elapsed since the date of service.
The nonmoving party was served by mail and more than 90 days have elapsed since date
of mailing.
2.4
Response
The nonmoving party has responded.

The nonmoving party has not responded and is in default.
2.5
Adequate C ause Finding
[]
2.6
adequate cause for hearing the petition has not been established,
/adequate cause for hearing the petition has been established.
ThVparties stipulate that there is adequate cause for hearing the petition.
Servicem enjbers Civil R elief A ct S tatem ent
2.6.1
Service nVember status It appears the nonmoving party:

[ ] is not a sfervice member;
[ ] is on activVduty in the U.S. armed forces (excluding National Guard and reserves);
[ ] is on active qîty and is a National Guard member or a Reservist residing in
Washington;
[ ] is not on activeûty in the U.S. armed forces (excluding National Guard and
reserves);
[ ] is not on active dutând is a National Guard member or a Reservist residing in
Washington,
2.6.2
Dependent of a service member status It appears the nonmoving party:

[ ] is not a dependent of a resident of Washington who is on active duty and is a
National Guard member or a Reservist;
[ ] is a dependent of a resident of Washington who is on active duty and is a National
Guard member or a Reservist;
[ ] is presumed not a dependent of a res'Ment of Washington who is on active duty and is
a National Guard member or a Reservist.
III. O rder
ft is Ordered:
[]
[]
The petition is denied.

The matter is set for hearing or trial at the date or time established or to be established.

WPF DRPSCU 07.0300 Mandatory (7/2007) - R C W 26.09.260; .270; 26.10.200
1Q ttQ fi i ^ a* -v QQH 1 Q?
[]
The matter is set for hearing <w*triafat: ^7

Date:
\MHI iScjof
M ___________
Time: _______________ ^
<
P>
[]
The nonmoving party is in default.
V ^ iA m
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in
iv w e o u i^ l
Dated:
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Robyn A. Lindsav
COIjKT c o m m is s i o n e r
F jlU ? A ^
__________
.Signature ?f Party or Lawyer/WSBA No.
O w n r /e r
s
Print Name
Print Name
# "* * * * < ,
Presented by:
J d fU U p A
a.m./prmT"
Lund
Date
Wy<y
>
S N A
Date
Print Name
Print Name
Date

WPF DRPSCU 07.0300 Mandatory (7/2007) - RCW 26.09.260; .270; 26.10.200
Date
E-FILE
IN COUNTY CLEF
PIERCE COUNTY, 1
September 19 2)
1
KEVIN ST
COUNTY C
2
3
4
5
6
7
8
Petitioner(s),
10
Cause No.
10-3-00961-1
Order Continuing
Adequate Cause Hearing
vs.
11

12
Respondent(s)
Clerks Filing code: ORACONT
13
14
15
16
THIS MATTER having come on regularly for hearing to determine if there is adequate cause to
proceed to trial with regard to a Petition which has been filed,
17
Now, therefore, it is hereby
18
ORDERED the Show Cause hearing determining Adequate Cause is continued.
19
20
21
22
Dated this
19 day of September, 2012
23
24
25
/S/ROBYN LINDSAY
ROBYN LINDSAY
Judge/Commissioner
E-FILED
September 19 2012 10:56 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)

Address: 11721 80TH AVE E PUYALLUP, WA 98373
Phone:
Respondent
Show Cause
Nature of Hearing: Child Support, Parenting Plans, Restraining Orders
CALENDAR DATE: Tuesday, November 06, 2012 9:00 AM

DATED:
September 19, 2012.
Signed:
NAME:
Phone:
ADDRESS: 2323 7TH STREET SE #B203

PUYALLUP, WA 98374
/s/ JENNIFER KAY SHIPMAN
WSBA#:
For:
1 of
Bl'Z
I S S 'J b
0 9 -2 0
1 0 -3 -0 0 9 6 1 -1
39221368
1:
SEP 1 9 2012
No. 1 0 - 3 - 0 0 9 6 1 - 1 \
DEPUTY
Memorandum of Journal Entry

[
] Show Cause
(ADM02)
Respondent(s)
'Sg,___________________
_________P r o
For Petitioner
_____________
For Respondent
C x u A .s e
re
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pierce c o u n t y .
Petitioner(s),
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Septem ber 19, 2012 9:00 AM
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Show Cause
ROBYN LINDSAY

Calendar C3 - SHOW CAUSE/FAMILY LAW
Ixcrtrpt pbl d jouma/_enfry_s/TOtvcat/se_reporf
//
rv v______________________________________________
_<RusXa*jL*>^.----
/ IN OPEN COURT
)URT OF THE STATE OF W ASHINGTON
D FOR PIERCE CO UNTY
{
______ 9 c o
FILED
CM E
6 8 1 7 8
Clerk
^ ^ " 2 1 ^ 2 0 1 .i
ih3A
e e l?
S u p e rio r C o u rt o f W a s h in g to n
C o u n ty o f
D dfflfr/ I
In re:
-ktintfff stiip/h?
Petitioner,
and
Respondent.
Order re Adequate Cause

(Modification/Adjustment of
Custody Decree/Parenting
Plan/Residential Schedule)
[ ] Denied (ORRACD)
I s s s s s s ? 0m*L
u l e r k 's A c tio n R e q u ire d _____________
I. Basis
1.1
A petition requesting the modification/adjustment o f the custody decree/parenting
This court has jurisdiction over the proceeding and the parties.
2.2
Service on Nonmoving Party

The nonmoving party was served with a copy o f the petition for modification/adjustment of
custody decree/parenting plan/residential schedule, summons, a proposed parenting plan, and
child support worksheet, if any, o n _____ 1j
___________[Pate],

WPF DRPSCU 07 0300 Mandatory (7/2007) - RCW 26 09 260, .270, 26.10 200
21 --'2 8 i Z
2.3
1 9 6*J t s j
Time Elapsed Since Service on the Nonmoving Party

The nonmoving party was served within the state o f Washington and more than 20 days
have elapsed since the date o f service.
The nonmoving party was served outside the state o f Washington and more than 60 days
have elapsed since the date o f service.
The nonmoving party was served by mail and more than 90 days have elapsed since date
of mailing.
2.4
Response
The nonmoving party has responded.
The nonmoving party has not responded and is in default.
2.5
Adequate Cause Finding
[]
2.6
adequate cause for hearing the petition has not been established.
Adequate cause for hearing the petition has been established.
ThVparties stipulate that there is adequate cause for hearing the petition.
Servicemenjbers Civil Relief Act Statement

2.6.1
Service nfember status It appears the nonmoving party:

[ ] is not a sfervice member;
[ ] is on actiw iduty in the U.S. armed forces (excluding National Guard and reserves),
[ ] is on active flirty and is a National Guard member or a Reservist residing in
Washington;
[ ] is not on activeûty in the U.S. armed forces (excluding National Guard and
reserves);
[ ] is not on active dutând is a National Guard member or a Reservist residing in
Washington,
2.6.2
Dependent o f a service member status It appears the nonmoving party:

[ ] is not a dependent o f a resident o f Washington who is on active duty and is a
National Guard member or a Reservist,
[ ] is a dependent o f a resident o f Washington who is on active duty and is a National
Guard member or a Reservist;
[ ] is presumed not a dependent o f a resident o f Washington who is on active duty and is
a National Guard member or a Reservl
III. Order
It is Ordered:
[]
[]
The petition is denied.

The matter is set for hearing or trial at the date or time established or to be established.

WPF DRPSCU 07.0300 Mandatory (7/2007) - RCW 26 09.260, .270, 26.10.200
1883b
a d j f i M tT
The matter is set^for hearing o^triaf at :
[]
Date:
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Place:
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Room/Department:
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lonmovine party is in default.
The nonmoving
[]
y
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Other:
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s &
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itiY
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/( /^ t^ \W
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.................. .
ated1
Robyn A. Lindsav
COURT COMMISSIONER
\A i J ' pfc^senled ^y*

Cjr| |||^^)gnature $ Party or Lawyer/WSBA No.
\t
' K )& in t& r
Signature o f Party or Lawyer/WSBA No.
Lund
Print Name
Date
Print Name
lin
Date
$ -0 S i^ itu re o f Party or Lawyer/WSBA No.
arty or Lawyer/WSBA No.
Print Name
Date
i t f .
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Signatui o f Party or Lawyer/WSBA No.
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Print Name
l/l/u tfr M b i M J ' i ,
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IN OPEN COURT
SEP 19 2012
lh
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WPF DRPSCU 07,0300 Mandatory (7/2007) - RCW 26 09,260, .270; 26 10 200
VklERCE COUNTY, Clerk,
28533
18^322812
158092

Petitioners)
No. 10-3-00961-1
vs.
NO TICE OF NONCOM PLIANCE

AND O RDER SETTING
NO NCOM PLIANCE HEARING
Respondent(s)
regard to the following items:
Certificate of Parenting Class - Petitioner's - Not Filed
Certificate of Parenting Class - Respondent's - Not Filed
TO:
Deadline:
Deadline:
08/30/12

(Court File Copy)
PAGE 1 OF 2
18^3-^2812
150093

IN AND FOR PIERCE C O U N TY
Petitioners)
No. 10-3-00961-1
vs.
N O TICE OF NONCOM PLIANCE

AND O R D ER SETTING
NO NCOM PLIANCE HEARING
Respondent(s)
regard to the following items:
Settlement Conference not confirmed by deadline - (See PCLR 16 & PCLSPR 94.04)
Deadline:
08/30/12
You are hereby ORDERED to appear for a hearing at 1:30 pm on Friday, 10/26/12 to comply with the Case
Schedule, or deliver a report of the same no later than the time set for the hearing.
The court may impose sanctions or terms for failure to comply with the Case Schedule. If the court finds that an
attorney or party has failed to comply with the Case Schedule and has no reasonable excuse, the court may order
the attorney or party to pay monetary sanctions to the court, or terms to any other party who has incurred expense
as a result of the failure to comply, or both; in addition, the court may impose such other sanctions as justice
requires. See PCLR 3 ( j ).
DATED: 10/01/12
Judge Family Court - 2

Department ORLA
Phone #: 253-798-3654
Copies mailed to:

Shipman, Jennifer Kay
Shipman, Jason William
TO:
(Court File Copy)
PAGE 2 OF 2
E-FILED
October 09 2012 3:32 PM
KEVIN STOCK
COUNTY CLERK
Case No. 10-3-00961-1
Petitioner(s),
vs.
Notice of Address Change for Litigant

(NTCA)
Respondent(s) .
Please take notice that my address for service of court records is:
11721 80TH AVE E
PUYALLUP, WA 98373
Dated October 9, 2012

Address provided to the clerk in open court.
qy-yC'H
0
10- 3-00961-1
39388631
PCOPC
4 fi / "fy / rJ-iS^ 7
^0-^ 7 f
10-22-12

A.M.
OCT 19 2012
P.M.
P1 1 W ^ |S 0N
BY
I & - 3 -
Q Q
'
< ?* / -
~~D5Pury
Cause Number
3 e -\v u v e .r
Case names:
^ \ i y w
Petitioner
3 as6 Y \
S h ip m a n
Respondent
T o A ll T h o s e T o W h o m T h i s L e t t e r M a y C o m e
T h e
In s titu te
fo r
C h ild r e n s A d v o c a c y
Is p l e a s e d to a n n o u n c e th a t:
Je n n ife r Shopman
H a s s u c c e s s fu lly c o m p le te d a F o u r H o u r w o rk s h o p
D o n t
F o r g e t
th e
K id s
A n d , h a v i n g s u c h d i s t i n c t i o n a n d p e r s p i c a c i t y in r e g a r d
to th e c o u r s e , is h e r e b y g r a n te d th is
C e r t if ic a t e o f C o m p le t io n
D a te d th is 1 6 th d a y o f M a rc h , 2 0 1 0
In the City of Tacoma, State of Washington
Instructors: S u s a n (D eG tom e, M .T .d ,
J o h n A G e n H in e s , !M .S .
T o A ll T h o s e T o W h o m T h is L e tte r M a y C o m e
F a m i l y E d u c a t i o n a s a d S r a p p o ir t S e r v i c e s
is P l e a s e d t o A n n o u n c e t h a t
1NCOUNTY^K'S OFFICE
pM .
PIERP.P a im n WASHINGTON
PIES K , County Cte^K
am
l l @
DEPJTV
Has s u c c e s sfu lly C om pleted Participation in the
M R T P a r e n tin g
a n d F a m ily V a lu e s C la s s
A n d H aving Show n Such Distinction in Regard to The Course Is H ereby Granted This
CIITDFICAT
IP H 1 T DO N
A w a r d e d this T w e n t y S ix th Day o f J u n e in the y e a r Two T h o u s a n d Twelv e
F a m ily
&
E d u c a tio n
S u p p o r t
S e rv ic e s
Supporting Fam ilies...Strengthening Communities
F a m ilylS d u ca tlo n A n d lS u p iiio ri.o rg
IQ- 3-00961-1
39394246
NTCA
A-OV?
10-22-12
u u u N T Y CLERKS OFFICE
a.m.
OCT 1 9 2012
P.M.
3 IBPC COUNTV, WASHINGTON

J?eviN STOCK, C o ^ y C lerk
d
- 4 ^ - Z - _ DEPUTY
SUPERIOR COURT OF W ASHINGTON COUNTY OF FIERCE

in re
Janm-fer l/- o m Uind

(sK^wari)
NO. | 0 - 3 - 0 0 3 k I -
Patitlonar,
NOTICE OF CHANGE OF
ADDRESS
and
v j a s o i lA'llwum ^ u p im a A ,
Respondent.
NOTICE IS HEREBY GIVEN that the address for the attorney and / or party
identified below is changed to the following:
NAME:
c fe n A f^ r
\L,
L -U n d _________________________
NEW ADDRESS:
3 3 3 -? ^ 6 t
SE, ftfir U 101_________________
P U J jd J I/J ft iV A
EFFECTIVE:
m TH IS
[ /]
[ ]
[ ]
CASE, I
9 0 3 ? 4 ________________________
lo fo (/,3 ________________________________________
THE: (solocS om)
Patraonsr
Respondent
Attorney fo r __________________________________ WSBA#
Dated this /3
day of O O fobdT"
NOTICE OF CHANGE OF ADDRESS
. 20
288 3 8
10-3-00961 -1
39428083
RSP
1 8 ^2 9 ^2 8 1 2
/A/
10-29-12
A/&L
188182
COt
o
'CA *
0 0/>,
%

County of
No. 10-3-00961-1
In re:
Jennifer K. Lund
Petitioner,
and
Jason W. Shipman
Respondent.
R esponse to P etition for

M odification/Adjustm ent o f
C ustody D ecree/Parenting
Plan/R esidential Schedule
(RSP)
C h e c k b o x if p e t i t io n is a t t a c h e d fo r:
[ ] O r d e r f o r p r o t e c t io n D V (PTO R PRT)
[ ] O r d e r f o r p r o t e c t i o n UH (PTORAH)
To:
I. Response
1.1
Adm issions and Denials

The allegations o f the petition in this matter are adm itted or denied as follow s (check only one for
each paragraph):
Paragraph o f the Petition
1.1
1.2
1.3
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
[]
[]
[]
[]
[]
[]
[]
[3
U
[]
[]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
[x ]
[x ]
[x ]
[X]
[X]
[X]
[X]
[X]
[X]
[X]
[X]
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
Resp to Pet for Mod/Adj (RSP) - Page 1 of 3

Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
2M 3i
2.9
2.10
2.ll
2.31.1
2.11.2
2.11.3
2.12
2.13
2.14
2.15
2.16
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
Admitted
[x]
[x]
[X]
[X]
[X]
[X]
[X]
[X]
[X]
[X]
[X]
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
Denied
[]
[]
[]
[}
[]
[]
[]
[]
[]
[]
[]
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Lacks Information
Each allegation of the petition that is denied is denied for the following reasons (list separately):
Jennifer (the Petitioner) has a history of this type of behavior. Lying to the court and in fact accusing me of
things that she is doing. I have never had a problem or history of alcohol abuse or gun violence. Yet
she continues to make these accusations. She claims she didnt know 1 was working. I will include
testimony that she did. Including my son asking when I moved in with Kasey my now wife. I
inquired as to why he would ask that he stated mom says your work van is at her house every day.
She claims that pawn the kids off at my parents. This is also a lie. She claims that she didnt know
that Hunter was going with his cousin to Florida also untrue. She lied about my father, our
relationship is strong and I have been to Florida. He is a deacon in his church, in fact she was aware
that my father was coming here to take Hunter to Great Wolf Lodge and spending a few days alone
and she did not try to stop that. She spent several hours on the phone with his, stating what a bad
father I am. She tried to get him to change the date of the trip, so she could be the one to send
Hunter. She states that I should not be able to drop the kids off early on Sunday night, then she
states that I should have to drop them off on Sunday, because 1moved to Yelm. She does not want
me to drop them off early; she wants the court to make me drop him off early. I have sent her
numerous emails since she has filed this paperwork, asking if she would like me to drop Hunter off
on Sunday and she ignores my phone calls and blocks my texts. In regards to Hunter and Andy
flying alone she put Hunter and Tyler on a plane alone to visit me in San Diego. She claims these
things are not ok, yet she has done them herself. The only thing I kept from Jennifer is my wedding
date. This was at the request of the children. When I talked to them about marring Kasey the first
thing Hunter said was Does mom have to know? 1 told him yes she does. He and Tyler both
begged me not to tell her until they came to my house for the summer. I honored their request and
she still hurt them. 1have made numerous attempts to work things out with Jennifer. I have had her
found in contempt of court for thee types of things in the past. Since then I have pointed out
multiple things she is in contempt for, making medical and school decisions without me, again. 1
dont want her found in contempt of court again, as it is not in the best interest of our children. But
her trying to remove my decision making is pushing the issue. The bottom line is Jennifer is angry
and vindictive. Based on lies alone she stopped Hunter form visiting his grandfather and going to
Disney World. 1 am including Tylers school history so you can see the troubles in her home and
how he excels at mine. Tyler earned more credits in the past two years while with me for just five
weeks, than he has the entire year while with Jennifer. On the transcript, where it says CR is a
credit earned during the summer with me. The Petitioner continues to intentionally drag out court. I
sent several emails trying to schedule mediation; she waits until the last minute knowing it would
not be in time. At the last mediation we went to, the mediator apologized to me, saying Jennifer was
unreasonable and wouldnt even listen to the advice of her own attorney. I believe the only chance
mediation has is if you dismiss this case so she is motivated to work on these issues.
2S83S
1.2
1 8 /2 9 /2 0 1 2
288184
Notice of Further Proceedings

Notice o f all further proceedings in this matter should be sent to the address below
1.3
Other
II. Requests
2.1
Request for Dismissal
[]
[x ]
2.2
Does not apply.

The non-requesting party requests that the petition be dismissed.
Request for Modification or Adjustm ent
[]
[]
Does not apply.

The no-nrequesting party requests that the court enter an order modifying or adjusting the
custody decree/parenting plan/residential schedule in this matter and approving the
proposed parenting plan/residential schedule, which is filed with or attached to this
response. The non-requesting party also requests that the court:
[]
[]
[]
Find there is adequate cause for hearing this matter.

Enter an order establishing child support in accordance with the proposed
parenting plan/residential schedule. The child support worksheet and financial
declaration are filed with this response.
Other:

W PF DRPSCU 07.0200 Mandatory (6/2008) - R C W 26.09.260; .270; 26.10.200
20838
13^29^2012
28S185
2.3
Protection O rder
[]
There is a protection order between the parties filed in case number _______________
court________________________, which expires on (date)________________ _
The court should grant the [ ] domestic violence [ ] antiharassment petition for order for
protection:
[ ] attached to this response.
[ ] filed separately under [ ] this case number [ ] case number___________________
[]
Dated:
Notice to party: you may list an address

that is not your residential address where
you agree to accept legal documents.
Anv 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.
gnature of Non-requesti
or Lawyer/WSBA No.
Jason W. Shipman
Print or Type Name
16221 Curry Ct SE, Yelm, Wa 98597
(Address)

Gmarl - Sunday night
n :
SZSSZglZ
2B91B6
Page 1 o f 1
jason shipman< ouUaw0015@gmail.com>
Sunday night
1 message
jason shipman < outlaw0015@gmail.com>
To: Jennifer lund <mjen15@hotmail.com>
Fri, Sep 14, 2012 at 3:44 PM
I have left a few messages with no reply. We need to go to mediation, or maybe even just talk. We could
probably resolve a lot by simply talking. Either w ay I have made several attempts to increase the child
support. They will not let me and send back any extra that I pay. I agree that it makes more sense to drop
hunter off on Sunday nights until we move closer. The judge said dropping him off early was ok, apparently
your attorney didnt fill you in to that point. You missed alot of things by not being in court. Most of the
things you have brought to court have already been ruled on. Please read the divorce decree. Ill just drop
him at the gate to your apartment complex like w e have done so many times in the past. I hope we can
work together in the future instead of continuing to hurt poor Hunter. Please let me know how I can help
you.
https://majJ,googie.com/majT/?ui=2&ik=8bfaI 3ada4& view =pt& search-sent& th-l 39c6f3...
10/25/2012
Gmail - Mediation
G e ia il
28338
1 8 '3 8 - '2 8 12
2B013V
Page 1 o f 1
jason shipman< outlaw0015@gmail.com>
M e d ia tio n
1 message
To: rnjen15@hotmail.com
Fri, Sep 21, 2012 at 2:06 PM
I left you another message did you get it? You need to schedule mediation. I have surgery the 12th so it
has to be before that I stated that in court just want to remind you. Looking forward to working out things in
mediation
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search=all&th=139eaa73...
10/19/2012
Gmail - Mediation 2
a t?_* jj
1 9 ^ 2 5 /2 8 1 2
z e s i a e page 1 o f 1
jason shipman< outiawOOl5@gmail.com>
byCooglc
M e d ia tio n 2
1 message
To: Jennifer lund <mjen15@hotmail.com>
Mon, Sep 24, 2012 at 10:09 PM
I still haven't herd from you regarding mediation. Please try to get this scheduled. I would like to discuss
several topics with you while we are there. The medical decisions you made without me, Hunter possibly
spending more time with me when I move back to Puyallup-Then there is the issue of child support
that needs to be corrected and accommodations need to be made so the state can change it when I get
laid or when I go back to work. There is also the issue with you not allowing Tyler to have his belongings
and you keeping his senior project preventing him from graduating. I am sure there are issues you want to
discuss also. As you know, I am always willing to talk if you change your mind. I look forward to mediation
please schedule it soon as I'm sure it takes time to get an appointment and we only have three weeks until
my surgery. Have you started your 12 week parenting class yet? I found it to be wonderful. Please let me
know if I can help you get the ball rolling on this.
https://mail.google.com/mail/?ui=2&ik=8bfal 3ada4&view=pt&search-all&th=l 39fbd4c...
10/19/2012
Page 1 of 1
Student Interval Totals

J
ID: 485858
/ ('Z '
j l f
Name: Shipman, Tyler Jason
C-
Building: Rogers High School
Grade: 12
Day View: * DIST

Display: * Code
Interval Values
S e m i Sem 2 YTD IP R 1 IP R 2 IP R 3 IP R 4 IP R 5 IP R 6
M em bership
90
90
180
30
20
20
31
20
20
Absence Excused
5.5
5.5
0.5
Absence Unexcused
23.5
38.5
62
7.5
5.5
13.5
8.5
7.5
Detailed Day View Criteria

Sem i
S em 2
YTD
IP R 1
IP R 2
IP R 3
IP R 4
IP R 5
IP R 6
C riteria
Total Day
Periods
40
176
24
296
24
40
472
48
40
56
40
40
104
S tu d e n t
Scheduled
Periods
31
137
18
225
15
31
362
33
31
44
31
32
80
0 49
S tu d e n t
Unscheduled
Periods
39
71
110
15
12
24
0 15
P resent
Periods
_
3
. .
15
24
39
15
0 0 5
Absent
Periods
31
122
201
31
323
18
31
40
29
25
73
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iS T UDENTlNFORMATIONTj
LEGALNAME(LAST, FIRSTMIDDLE)[andothw/formalnamesused)
SHIPMAN, TYLER JASON
WASHINGTON STATE HIGH SCHOOL

T R A N S C R IPT
REPORTDATE
GRADUATIONDATE
10/16/2012
Grade Point4T0able
DISTRICT IDENTIFICATIONNUMBER
BIRTHDATE
485858
08/15/1994
PARENT(S)ZGUARDIAN(S)
LUND , JENNIFER
SHIPMAN, JASON
A
AB+
B
BC+
c
cD+
D
EOfF =
37
33
30
27
23
20
17
13
10
00
NOTUSEDING.PA______
P/N Pass/Nopass
CR/NC Credrt/NoCredit
SAJ Satisfactoiy/Unsatisfactofy
w
withdraw
SSID
7201639153
SCH O O L OF RECORD
SCHOOLNAME,ADDRESS, PHONENUMBER^
ROGERS HIGH SCHOOL
12801 86TH AVE E
PUYALLUP, WA 98373
253-841-8717
SCHOOLDISTRICTNAME
PUYALLUP SCHOOL DISTRICT
*** SCHOOLS ATTENDED ***

City, State
Entry
School
Exit
PUYALLUP, WA
09/2008 06/2009
BALLOU JUNIOR HIGH
PUYALLUP, WA
09/2009 10/2010
ROGERS HIGH SCHOOL
PUYALLUP, WA
EMERALD RIDGE HIGH SCHOOL
10/2010 02/2011
PUYALLUP, WA
02/2011 06/2011
ROGERS HIGH SCHOOL
PUYALLUP, WA
07/2011 07/2011
SUMMER SCHOOL
PUYALLUP, WA
09/2011 06/2012
ROGERS HIGH SCHOOL
* *** COURSE DESIGNATION KEY **************
Course
Ltr Cred Cred Crs
I a Inti Baccalaureate a = Advanced Placement
Code
Description
Grd Earn Attp Dsg
C = College in the HS
R = Running Start
MO/YR: 06/2011 GRD LEV: 11
T = T e c h Prep
B = CADR/HECB Core
50 B
085412 ALGEBRA I
B 0
50
H = Honors Option
K = Cambridge Program
00 B
087212 AMERICAN STUDIES II
F
0 00
************* ACADEMIC RECORD ******************
50
468150 FITNESS WALKING
F
0 00
Course
Ltr
Cred CredCrs 134431 GUITAR TECHNIQUES
50 B
D
0 50
Code
Description
Grd Earn Attp Dsg
00 B
080512 JUNIOR ENGLISH
F
0 00
50 T
136322 VIDEO PRODUCTION II
CR
0 50
MO/YR: 01/2009 GRD LEV: 09
MO/YR: 07/2011 GRD LEV: 11
08534 1 ALGEBRA I
' F
00 B
0.00
00 B
0754 01 ENG9 WLDSTY
F
57413V BIOLOGY A/B
CR
1 00 1.00
0.00
1503 01 PHYSICAL SCI
F
50 B
0.00
08051V JUNIOR ENGLISH A / B p i CR
1, 00 1.00
57410 0 SCI BY (BBS IGN
50
08721V US H I S T O R Y r A / 1 00 1.00
0.50
50 B
163501 SS9 WLD)- S T D Y ^ p D 4 j = l .50
MO/YR : 02/2*612 GRD^LEV
143200 STRNGTHy CND>9^' ^ ->. ;WcT ;0T50
50
692131 ATTEND^SERvfGE>\
50
,,r~ M t F p
o
50 B
08 5421 GEOMETRY^S
0.50 B
50 B
1
085342 ALGEBR/^*T~""lRr'<'~b"NC-^6roo* 0.50 B
080711 SENIORÊNGLI
Ô^ffO 0.00 B
242102 DIGITOOi&VAi i1ip S( HU< CR OiSofjBOt 0.50 T
087360 SR SOCTAL^ STUDIES^<X U F ^ W o b 0.50 B
075402 ENG9 WLDSTY
F
0.00 0.00 B
354711 WELDING I
F
0.00 0.50 T
462130 LIFE ISSUES
D- 0.50 0.50
MO/YR: 06/2012 GRD LEV: 12
150302 PHYSICAL SCI
D
0.50 0.50 B
138510 CERAMICS 1
C
0.50 0.50 B
163502 SS9 WLD STDY
D
0.50 0.50 B
085422 GEOMETRY
D
0.50 0.50 B
MO/YR: 01/2010 GRD LEV: 10
08535V GEOMETRY
CR
0.50 0.50
134432 GUITAR TECHNIQUES
139311 FRENCH I
D+ 0.50 0.50 B
D
0.50 0.50 B
085351 GEOMETRY
D
0.50 0.50 B
085522 MATH LAB II
CR
0.50 0.50
C+ 0.50 0.50
080712 SENIOR ENGLISH
572111 SCIENCE INVESTIGATN
F
0.00 0.00 B
080111 SOPHOMORE ENGLISH
D
0.50 0.50 B
08071V SENIOR ENGLISH A
CR
0.50 0.50
468410 SWIMMING SKILLS AA 1 A- 0.50 0.50
087360 SR SOCIAL STUDIES
F
0.00 0.00 B
A- 0.50 0.50 T
136311 VIDEO PRODUCTION I
MO/YR: 07/2012 GRD LEV: 12
MO/YR: 06/2010 GRD LEV: 10
24221V BUS COMP INFO A
CR
0.50 0.50
F
139312 FRENCH I
0.00 0.50 B
24221V BUS COMP INFO B
CR
0.50 0.50
085352 GEOMETRY
F
0.00 0.50 B
08071V ENGLISH 12 B
CR
0.50 0.50
F
572112 SCIENCE INVESTIGATN
0.00 0.50
57211V GENERAL SCIENCE A
CR
0.50 0.50
080142 SOPHOMORE ENG DRAMA
A
0.50 0.50 B
57211V GENERAL SCIENCE B
CR
0.50 0.50
0.50 0.50 T
136312 VIDEO PRODUCTION I
D
24434V PERSONAL FINANCIAL L CR
0.50 0.50
B
0.50 0.50
468220 WEIGHT TRAINING
08981V PSYCHOLOGY
CR
0.50 0.50
08736V SR SOCIAL STUDIES
CR
0.50 0.50
MO/YR: 02/2011 GRD LEV: 11
0.00 0.50 B
085361 ALGEBRA II
F
087211 AMERICAN STUDIES II
F
0.00 0.00 B
576031 CHEMISTRY I
F
0.00 0.50 B
69230V CREDIT RTRV ENGLISH CR
0.50 0.50
69230V CREDIT RTRV ENGLISH CR
0.50 0.50
080511 JUNIOR ENGLISH
F
0.00 0.00 B
136231 PHOTO I DIGITAL
F
0.00 0.50 TB
136321 VIDEO PRODUCTION II
F
0.00 0.50 T
For inform ation about the State of Washington High School

Transcript please visit the OSPI website at www.k! 2 wa.us.
AUTHORIZEDSIGNATURE
TITLE
Page
DATE
1 of 2
WASHINGTON STATE HIGH SCHOOL

TRANSCRIPT
STUpEN T IN FQ RMATI ON j
REPORT DATE
LEGAL NAME (LAST, FIRST MIDDLE) (arid other/formal names used]
SHIPMAN, TYLER JASON
BIRTHDATE
485858
08/15/1994
A
AB+
s
B
BC+
C
CE>
D
E or F =
PARENT(S)/GUARDIAN(S)
4.0
37
33
30
2.7
23
20
1.7
13
10
0.0
LUND, JENNIFER
SHIPMAN, JASON
* * * * * REPORT PERIOD AND CUMULATIVE SUMMARY * * * * *
GPA
GPA
Cred Cred GPA
Grd
Earn A ttp Earn Attp
Lev Mo/Yr
PtS GPA
03.15 1.575
09 01/2009 1.50 2.00 1.50 2.00
09 06/2009 2.50 3.00 1.50 1.50
O l . 50 1,000
06.50 2.167
10 01/2010 3.00 3.00 3.00 3.00
04.00 1.333
10 06/2010 1.50 3.00 1.50 3.00
00.00 0.000
11 02/2011 1.00 3.00 0.00 2.00
02.00 1.333
11 06/2011 1.50 2.00 1.00 1.50
OO . 00 0.000
11 07/2011 3.00 3.00 0.00 0.00
00.50 0.250
12 02/2012 1.00 2.50 0.50 2.00
02.00 1.333
12 06/2012 3.00 3.00 1.50 1.50
OO . 00 0.000
12 07/2012 4.00 4.00 0.00 0.00
Cum ulative:;22.00 28.50 10.50 16.50
1 9 .65 1.191
* * * * * * * * ADDITIONAL STATE REQUIREMENTS * * * * * * * * *
Reading Standard
MET
MET
W ritin g Standard
Mathematics Standard
NOT MET
Science Standard
NOT MET
NOT MET
High School & Beyond _Plan ps
Culminating Project.C
NOT MET
*
* * * *
-k ieiTk
Hr +
k k
Ht* *
k k k k
iSCHOOL OF RECORD!
SCHOOL NAME7ADDRESS, PHONE NUMBER
ROGERS HIGH SCHOOL
10/16/2012
Grade Point Table
DISTRICT IDENTIFICATION NUMBER
* * * * * * * * * * * * *
GRADUATION DATE
NOT USED IN G P A____________
P/N
CR/NC
SAJ
W
Pasa/No Pass
Credlt/No Credit
Satlstactory/Unsati sfactory
Wthdrw
SSID:
7201639153
12801 86TH AVE E

PUYALLUP, WA 98373
253-841-8717
SCHOOL DISTRICT NAME
PUYALLUP SCHOOL DISTRICT
* *+ ******
C e r t i f i c a t e o f Academi c A c h i eyement J L
EARNED
* * * * * * * * * * * ENbÔF^TRANSCRIPTi-RECORD^S** * * * * * * * * *
P L Y A U t jP S C H O O L U I S I R 1 C I
For information about the State of Washington High S c h o o l

Transcript please visit the OSPI website at www k1 2 .w a .u s.
AUTHORIZEDSIGNATURE
Page
TiTH
daTE
2 of 2
10-3-00961-1
39428097
DCLR
10-29-12
1KI^
f il e d
a m.

County of
BY_
OCT 26 2012
rm.
YWASi
H,NClerk
5TON
(,^Cmnty
DEPUTY
In re:
Jennifer K. Lund
No. 10-3-00961-1
Petitioners),
and
Jason W. Shipman
Respondent(s)-
Decla ration of
__Stacilynn Rambow.
(Optional Use)
(DCLR)_____________

Name:
___Stacilynn Rambow________________________
Age:
____25____________________________________
Relationship to the parties in this action: ___sister to Jason Shipman
/ D e c la r e :
I am writing this statement for my brother Jason Shipman. Jason is a good dad.
He is interested in his kids hobbies and enjoys spending time with them,
teaching them new things. I live with my parents and Jasons kids get dropped
off here on Wednesday and every other Friday. Jason is always early to pick
them up and has them back here before Jenifer gets here, in case she shows up
early. He never just leaves them here. Jason is a very active father. Jason does
not drink when he has his kids, and even in the time his kids are not with him,
his drinking is not excessive by any means.
Jenifer has always been difficult to deal with. She is never on time, If the kids
are with Jason and try to call her she will not answer their phone calls. She is
Declaration (DCLR) - Page 1 o f * 3
W P F D R P S C U 01.0100 (6/2006)
2SS3B
13^29^2812
288113
extremely upset that Jason has a new wife and is holding this against him. She
is trying to hurt Jason with her actions, but really she is just hurting the kids.
Her oldest son Tyler will not even talk to her because of her actions and her
lack of caring about what is best for the children. Really she just cares about
herself. She leaves Hunter home alone, letting Hunter cook on the stove and use
the oven when she is not there as well. Jenifer was part of this family but her
actions and making it impossible for even us to remain having a relationship
with her, more themjust for the kids. Jenifer used my face book page to stalk
Jason. She showed up at my welcome home BBQ to serve Jason papers. All the
nieces and nephews were here. When she realized Jason had left before she got
here, she called the police to come here. This was a traumatic experience for all
the children, all because she is upset that Jason is remarried. She made it so
Hunter could not go to Florida and spend time with his grandpa. She did this to
hurt Jason, which it did because he cares about Hunter and his feeling. And the
fact that he was not able to go with his cousin to Florida, hurt Hunter and
Andrew. She needs to stop thinking about herself when it comes to the children
and start thinking about what is best for them.
Hunter, as well as all children need a father in their life. Jason cares about his
children. He cares about spending time with them, and it is already hard for him
to only have Hunter every other weekend and one night a week. He deserves to
spend time with his children. He is an active parent and listens to them and
provides for their needs.
(Attach Additional Pages if Necessary and Number Them.)

1 declare under penalty o f perjury under the laws o f the state o f Washington that the foregoing is true and
correct.

Declaration (DCLR) - Page 2 of Ip
WPF DRPSCU 01.0100 (6/2006)
23338
1 3 /2 9 -/2 812
283114
1} Sealed Financial Source Documents (WPF DRPSCU 09.0220) for financial records
If Filed separately using a cover sheet, the records will be sealed to protect your
court personnel and certain state agencies and boards.) See GR 22(C)(2).
Declaration (DCLR) - Page 3 o f

W P F D R P S C U 01.0100 (6/2006)
2 8 G3 y 1 8 / 2 9 0 2 3 1
s. A
10-3-00961-1
39428131
288115
10-29-12
DCLR
IN C O UNTY CLERK'S OFFICE

County of
RM.
PIERCE COUNTY l/VASHIk
a I wCKXounty Clerk
HY----------- ----1J.------ DEPUTY
In re:
jt v s A x C t /
OCT 26 2012
A.M.
L u v \d
VL.
Petitioners),
No.
and
\ o - s
- Ooc\v - \
Declaration o f
V ) - ^ y )W V X V >
V \A 4 e .^
Respondents).
^ > V \\p w v o .i4
[Name]
(Optional Use)
(DCLR)

Name:
V l.
Age:
S V v\ p y v \< v n ___________
3 H _____________________________________
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I Declare:
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to HU,
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Declaration (DCLR) - Page 1 of *2.

WPF DRPSCU 01.0100 (6/2006)
W u u * A e ^
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yg
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I declare under penalty o f perjury under the laws o f the state o f Washington that the foregoing is true and
correct.
Signed at _
__________, [C ity]
Signature o f Declarant
U ) ft
[State] on \ P . \ g
TjQ\T_
[Date],
__ f t . t W < p w t< v m _______

Print or Type Name

court personnel and certain state agencies and boards.) See GR 22(C)(2) .
Declaration (DCLR) - Page 2 o f ____
W P F D R P S C U 01.010 0 (6/2006)
10-3-00961-1
39428166
DCLR
10-29-12
am .
OCT 2 6 2012

County of
RM
deputy
In re:
No. l o - ' i - O O ^ V > - \
Petitioners),
and
J (MkCM
Declaration of
" ^ U r
^
[Name]
(Optional Use)
(DCLR)
pW VXh
Respondents).

Name:
T s jle f
Age:
^ .
S V u f i v W A w ______________
______________________________________
J (X s <m
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Declare:
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W P F D R P S C U 01.010 0 (6/2006)
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(Attach Additional Pages i f Necessary and Number Them.)

f declare under penalty o f perjury under the laws o f the state o f Washington that the foregoing is true and
correct.
Signed at
YtllY) ________________ , [C ity] V

a/
/j-
[State] on
( 0 / f# ! IX
[Date],

Declaration (DCLR) - Page 2 of X
W P F D R P S C U 01.0100 (6/2006)
28838
10-3-00961-1
39428167
1 S /Z 9 S 2 B 1 2
238119
10-29-12
DCLR
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A.M.

County o f
OCT 2 6 2012
WASH/Mg
GsuntwQ,
l / [ / EPUTY
tare: Je n n ;-C v " K . L
ia h c I
no.
Petitioners),
and
; o - 3 - o o q 4 , / ~
D i
Declaration o f ^
<Xir\
[Name]
(Optional Use)
(DCLR)
Respondents).

Name:
H J t trC& .(^C( W ily o u J .
Age:
&0
I Declare:
4 5 (je tto n '*
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Declaration
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(DCLR)
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W P F D R P S C U 0 1.010 0 (6/2006)
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I declare under penalty o f peijury under the laws o f the state o f Washington that the foregoing is true and
correct.

1) Sealed Financial Source Documents (WPF DRPSCU 09,0220) for financial records
Declaration (D C LR ) - P age 2 o f Z
W P F D R P S C U 0 1 .0 1 0 0 (& 2 0 0 6 )
28838
1 0 -3 -0 0 9 6 1 -1
39428171
DCLR
18^28^2812
288121
1 0 -2 9 -1 2
FILED
am
OCT 26 2012

County of
.RM.
In re*
L tju v v d
Petitioner(s),
and
ÔsÔYV
V 0 - ^ V \X p X W o .K .
Respondents).
No. 10-3-00961-1
Declaration of
____ Justin Rambow
(Optional Use)
(DCLR)____________

Name:
Justin Rambow
Age:
25
Relationship to the parties in this a ctio n : Brother o f Jason, Uncle to Tyler and Hunter
Declare:
Jason Shipman to be a good father. H e does the best he can to provide, for both Tvler and Hunter, the
things that they need to be successful and live happy healthy lives. During his visitation he spends as
much time as he can w ith them. He is at the mutual meeting spot four parents house) on time for both
drop o ff and pick up o f the bovs. at the same time I cannot sav that about their mother Jennifer. There
have been a number o f occasions th a t she has been late for both pick up and drop o ff without a tim ely
warning. She seems unw illing to com prom ise in anv situation and tries to isolate her youngest son.
Hunter, from Jason s side o f the fa m ily and ignores her oldest Tvler on a regular basis____ ___________
Declaration (D C LR ) - P age 1 of 3
W P F D R P S C U 01.0100 (6/2006)
2BS38
18^29^2812
208122
I have personally witnessed numerous times the questionable parenting calls made bv Jennifer: some o f
these decisions being as simple as ignoring the bovs when they try to contact her for permission to do
something with their Dad. Grandparents, or other members o f our immediate fam ily. The one 1 feel to be
the most detrimental would be her lack o f commitment on helping Tvler. be successful in High School.
Throughout his time in High School Tvler struggled, as many teenagers do. getting to school. From mv
perspective, while Tvler needed to take more initiative, it was her responsibility to get her son to school.
As the primary guardian she needed to be more proactive in his schooling. Over the summer Tvler was
under the care o f Jason for an extended period o f time where Jason made sure that Tvler was in a position
to get to summer school and complete his course work. While he has still not fu lly completed all
requirements to get his high school diploma under Jason s care he was able to gain all credits need to do
so.______
_____________
____
__________________________________
From the outside looking in this tug-o-war o f power between Jason and Jennifer has gone on long
enough. The divorce has been final for over a year. Jason is re-married. Jennifer is dating: at this point
we need to focus on the kids. 1 do not see what goes on at Jennifer s house: all 1 can go on is what I hear
and see from the kids. Tvler has moved out, but had many issues while still living with Jennifer including
school issues, law enforcement contact and property damage. Hunter seems to be affected with the
situation differently gaining a significant amount o f weight and becoming stand offish. Jason does the
best he can with these issues when he has the bovs. keeping them active and involved in fam ily events
(when allow ed!______________________________________ _________________________________
I do not want to discredit either as a parent. This has been a d ifficu lt situation for all parties involved and
one in which there is no easy wav. I do want to make it clear though that Jason is a very capable,
competent, and loving father; bv no means should his rights as a parent be restricted, revised, or revoked.
Declaration (DCLR) - Page 2 o f "b

W P F D R P S C U 01.0100 (6/2006)
28S38
1 8 /2 9 /2 8 1 2
288123
(A tta ch Additional Pages if Necessary and Number Them.)

correct.
not attach financial records, personal health care records or confidential

fried with the court using one of these cover sheets:
I f filed separately using a cover sheet, the records will be sealed to protect your
Do
D e c la ra tio n (DCLR) - Page 3 o f 3

W R F D R P S C U 01.0100 (6/2006)
M m 3 9 * ? # i 2 2 ii?
1 0 -3 -0 0 9 6 1 -1
3942B 199
1 0 -2 9 -1 2
DCLR
'v
l.
y CLERK'S OFBCE
IN COUNTY
KU

County o f
OCT 26 2012 PM-
BY.------ -----------1 /
In re:
C ? e n n T -tc r ^
No. I O - ^ - O O ^ I o H
Petitioners),
and
dkscA
Declaration o f
>ecV_V >n a^PO\JL>
[Name]
(Optional Use)
(DCLR)
id
Respondents).
__ M <e. ^ ? g y y ib o u X
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Declaration (DCL'R)
DCt-R) - Page 1 o f "2W P F D R P S C U 01.010 0 (6/2006)
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1) Sealed Financial Source Documents (WPF DRPSCU 09,0220) for financial records
W P F D R P S C U 01.0100 (6/2006)
10-3-00961-1
39428201
10-29-12
DCLR

County o f
In re: Jennifer Lund
Petitioner's),
And Jason Shipman
Respondents).
No. 10-340961-1
Declaration of
Steven ShiDman
[Name]
(Optional Use)
(DCLR)__________________________

Name:
Age:
Steven P Shipman_________________________
6 0 ______ _______________________________

Father o f Jason Shipman and Grandfather o f Tvler and Hunter Shipman
Declare:
Your Honor:____________________________________ ____________ ________________________

1 would like to tell you a quick story about mv son which, 1 believe, demonstrates his fathering style. Mv
son gave up a tarpon fishing trip and used his Christmas airline g ift certificate so his son Hunter could
come to Florida with his cousin Andrew and visit us. the grandparents. We purchased the Disney World
tickets and all was set for a great visit for the bovs. Jennifer, Jason's ex-wife stopped the trip w ith false
accusations thus breaking two little bovs" hearts. M v son Jason then contributed his money. V2 o f the
airfare applying his contribution to our airfare so that we could come up to Washington and take the bovs
to Great W o lf Lodge and do our best to ease the disappointment in the bovs hearts. I work with youth
Declaration (DCLR) - Page 1 of "b

WPF DRPSCU 01.0100 (6/2006)
26838
10^28^2812
2501
down here in Florida w ith mv church and 1 would never sav anything that would jeopardize the safety or
mental health and happiness o f mv grandchildren. Jason and Jenifer tried hard and, perhaps, too lone to
make their marriage work. Jason has always been a loving father. His mother, mv ex-wife, has nurtured
and raised foster and step children and Jason s exposure to those relationships has made him a better Dad
than most. His ex-wife Jennifer has not told the truth and has been vengeful not always keeping the best
interest o f Tvler and Hunter 1g and foremost. Please, for the bovs" sake at least assign a mediator. Tvler
is an adult but Hunter needs his father and would be better o ff living with his father. I have never known
mv son to be a bad father. 1 am speaking w ith the best interest o f mv grandson in mv heart. Thank you
for vour time._________ _________ ______________________________________________________

1 declare under penalty o f peijuiy under the laws o f the state o f Washington that the foregoing is true and
correct.
Signed at
Declaration (D C LR ) - Page 2 of 3
W P F D R P S C U 01.010 0 (6/2006)
[C ity]
[Stale] on f r P X - I 0 - 3 0 1 {Date].
______ Steven P. Shipman

Print or Type Name
20838
10^2922012
2S012S

Declaration (D C LR ) - P ag e 3 o f 3
W P F D R P S C U 01.010 0 (6/2006)
2^838
10'3-00961-1
39428205
1 8 /2 9^28 1 2
2S8128
10-29-12
DCLR
AM OCT 26 2012
rm.

County of
In re:
YL.
viewrv v t e c
VPetitioner(s),
and
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Respondent(s).
No.
U 3 -'3 .-0 0 v \o V -\
Declaration o f
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[Name]
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This declaration is made bv:

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(Attach Additional Pages if Necessary' and Number Them.)


Declaration (D C LR ) - P ag e 2 o f
W P F D R P S C U 0 1.010 0 (6/2006)
20838
18^29^2812
2 S8 13 1
ff filed separately using a cover sheet, the records will be sealed to protect your
Declaration (DCLR) - Page 3 o f ~b

W P F D R P S C U 01.0100 (6/2006)
10-3-00961-1
10-29-12
DCLR
39428207

A.M.

County of
UCT 26 2012 RM.
..
KE
pi
BY
4 U
DEPUTY
In re:
_\evxv\.vC er
Y^.
1_\>jy \ cI
No.
\0 -3 -0 0 0 \U -l
Petitioners),
and
Ô cSO W
V) -
Declaration of
~ W > e o A n v e __ i
[Name]
(Optional Use)
(DCLR)
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Respondents).
v\
p /\ft & / \
Name:
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Print or Type Nam
Do not attach financial records, personaI health care records or confidential

1) Seated Financial Source Documents (WPF DRPSCU 09.0220) for financial records
If filed separately using a cover sheett the records will be sealed to protect your
Declaration (DCLR) - Page 2 of
W P F D R P S C U 01.0100 (6/2006)
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iC O u m V FC K 'S OFFICE
10-3-00961-1
3943B419
RTS
10-30-12

County of
In re:
'jL
luvÂ
No. / Q _ 3 Petitioner,
and
0 0 %
^ /
Return of Service
(Optional Use)
(RTS)
Respondent
Declare:
1.
Iam over the age o f 18 years, and I am not a party to this action.
2.
I served the following documents to (name)

[]
[]
[]
[]
[]
[]
[]
[]
{]
E3
[]
[]
t^
[]
n rt{
summons, a copy o f which is attached

proposed child support order
sealed financial source documents cover sheet and financial documents
Notice Re: Dependent o f a Person in M ilitary Service
notice o f hearing fo r_________________________________________
motion for temporary order
motion for and order to show cause re :____________________________
declarations o f
l i
temporary order
other:

WPF DRPSCU 01.0250 (6/2010) - CR 4(g), RCW4.28.080(15)
A___ -
/
4
t a / 3 0 / 7 g i ?
3.
The date, time and place o f service were ( if by mail refer to Paragraph 4 below):
Date:
/t
Address:
y/7-3.)
___________________ fa
4.
[]
[]
[]
\ ^ ~ ___Time:
- D o
'/o ilv f j
AV ~
tL _____________________
wA
_______________

by delivery to (name) _____________________________________ , a person o f
by publication as provided in RCW 4.28.100. (File A ffidavit o f Publication separately.)
(check this box only i f there is a court order authorizing service by m ail) by mailing two
copies postage prepaid to the person named in the order entered by the court on
(date)________________ _______ . One copy was mailed by ordinary first class mail,
the other copy was sent by certified mail return receipt requested. (Tape return receipt
below.) The copies were mailed on (date)_____________________________
(check this box only i f there is a statute authorizing service by m ail) by m ailing a copy
postage prepaid to the person requiring service by any form o f mail requiring return
receipt (Tape return receipt below.) The copy was mailed on (date)______________ .
Service o f Notice on Dependent o f a Person in M ilitary Service.

[]
[]
6.
Service was made:
[]
5.
5 1 6 1 6 5
The Notice to Dependent o f Person in M ilitary Service was [ ] served on f ] mailed by

first class mail on (date)_______________________________ Other
Other:
correct.
Total
___ _____________________
(Tape Return Receipt here, i f service was by mail.)

File the original Return o f Service with the clerk. Provide a copy to the law enforcement agency where
protected person resides i f the documents served include a restraining order signed by the court

WPF DRPSCU 01.0250 (m010) - CR 4(g), RCW4.28.080(15)
21Sa 0
10-3-00961 -1
39479411
M TDSM
1 1 -0 6 -1 2
*4
"*
FILED
a .m.
NOV 0 6 2012 PM
PIERCE COUNTY WASHINGTON

BY---------------------------------------------------- DEPUTY
F
County of
lnre: J e n n i e
NF
U vvxd
No.
Petitioners),
and^cxsov\
V ) . SK i p rncx^vv
\0 ~ 2 > -o o c \b \-l
Motion for Order

of Dismissal
(Optional use)
(MTDSM)
_____________________________ Respondent(s).
^
1 11.
S>V\ i p ^ y \ f t
[Name of moving party] moves (asks) the court for an
order dismissing this action because the moving party no longer wants the relief requested in the
TV\od.\Fi' axV>CM )VTcljasYr<rnn'V oC Cm iAAq TDecjree|

for these reasons: P e - h V i b n a r
^ c r r u jO jr A
W i s ______ v v q ____\ v d c r r t \ o n
[Name oFêtitk
to
P cM : b o v is x __ Ai*___ cxs.
V vK -V vX vS S W vft-tvh
Date: n . i o . i a
re o f Moving Party or Lawyer/WSBA No.
__^CXS>v>___ V j .__ q
Print or Type Name
Date: N I ck J- Vcv^ *2-Q V l,
Signature o f Nonmoving Party or Lawyer/WSBA No.
Mt fo r Ord Dismissal (MTDSM) - Page 1 o f 1

WPF DRPSCU 01.0550 (6/2006) CR 41(a)
Print or Type Name
21834
1 0 -3 -0 0 9 6 1 -1
39482564
ORDSM D
1 1 /7 /2 8 1 2
18885
1 1 -0 6 -1 2

County of
no.
Petitioners),
OcXSovy
\K) ^V \A ^)irvvcoi
i o - 3 - o o < a t o \ -1
Order of Dismissal
(Optional Use)
(ORDSM)
Respondent(s).
The court received (name o f moving party)
\AJ .
S>V\ i v^WVCA-W
s motion
for order of dismissal. Having reviewed the motion and the court file, it is hereby o r d e r e d that this
O f \ C y \ 11?
| ^3 \ /
action is dismissed.
fg T m o ^ l
J u u so if/
Dated: f ^ O V .
P t/A
b ie Q
l o , * 2_0\7_
----- -
ûdgc/Court^Tbrnm iss ioner

Presented by:
ignature of Moving Party or Lawyer/WSBA No.
Approved
Notice of l
to fort
ftion waived:
Signature of Nonmoving Party or Lawyer/WSBA No.
Print or Type Name
Print or type Name
Signature of Moving Party or Lawyer/WSBA No.
Signature of Nonmoving Party or Lawyer/WSBA No.
Print or Type Name
Print or type Name
Order o f Dismissal (ORDSM) - Page 1 o f 1

WPF DRPSCU 01.0560 (04/2012)
2 i B Bo - 11-^8^2012
8 8 8 r8

Petitioner(s)
vs.
Cause Number: 1 0 -3 -0 0 9 6 1 -1

Page 1 of 2

Respondent(s)
Judge/Commissioner: CRAIG S. ADAMS
Judicial Assistant/Clerk: Chelsea Glanz
SHIPMAN, JENN IFER KAY

SHIPMAN, JA SON WILLIAM
SHIPMAN, TYLER
SHIPMAN. HUNTER

Proceeding Outcome:Held
Resolution:
Outcome Date: 11/06/2012 9:49

Report run date/tim e: 11/06/12 9.56 AM
lxcalcivtl.pbl.d_civiljoumat_repori_cover
21959
1 1 ^8 /2 0 1 2
80071


MEMORANDUM OF
JOURNAL ENTRY
vs.
Judicial Assistant/Clerk: Chelsea Glanz

Start Datemme: 11/06/12 9:49 AM
Page: 2 of 2
Judge/Commissioner:
CRAIG S. ADAMS
Court ReporterSmart Court
November 06, 2012 09:49 AM
Respondent Jason Shipman comes before the court seeking an Order of Dismissal of the
Petition for Modification of Custody filed on June 27, 2012.
order.
JUDGE/COMMISSIONER. CRAIG S. ADAMS Year 2012
JIS reviewed.
Court signs
E-FILED
April 09 2013 11:26 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)
Name: JENNIFER KAY SHIPMAN

Address: 2323 7TH ST SE APT U101 PUYALLUP, WA 98374
Phone:
Petitioner
Show Cause
Nature of Hearing:
Contempt
CALENDAR DATE: Wednesday, May 01,2013 9:00 AM

DATED:
April 9, 2013.
Signed:
/s/ JASON WILLIAM SHIPMAN
NAME:
Phone:
(253) 686-3971
ADDRESS: 16221 CURRY CT SE

YELM, WA 98597
WSBA#:
For:
1 of
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1 0 -3 -0 0 9 6 1 * 1
40317302
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04-09-13
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KEVIN STOCK,
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BY_________
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County of
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No.
Petitioner(s),
and
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Declaration of
JovSQYN \K) ,__SW plW lw
[Name]
(Optional Use)
(DCLR)
S W fV v U L t^
Respondent(s)
This declaration is made by.

Name
S b W p m o m ____________
AO____________________________
Age*
Relationship to the parties in this action-
V\\n.vV\ni r \e \
I Declare:
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Declaration (DCLR) - Page f o f ' X

WPF DRPSCU 01.0100 (0/2006)
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I declare under penalty of peijury under the laws of the state of Washington that the foregoing is true and correct.
[State] on A p n i
,Y\-vnw
NO.
in v b
P ate].
^ k x p y v w jA
Print or Type Name

Do no t attach fin a n cia l records, personal health care records or confidential reports to this declaration. Such
records should be served on the other party a n d filed with the court using one o f these cover sheets:
1) Sealed Financial Source D ocum ents (W PF DRPSCU 09.0220) fo r fin a n cia l records
2) Sealed Personal H ealth Care R ecords (W PF DRPSCU 09.0260) fo r health records
3) Sealed C onfidential Report (W PF DRPSCU 09.270) fo r confidential reports. I f file d separately using a cover
sheet, the records w ill be sealed to p ro tect your privacy. Although they w ill be available to all parties in the
case, their attorneys, court personnel and certain state agencies and boards.) See GR 22(C)(2).
Declaration (DCLR) - Page 2 of *2

W PF D R P S C U 01.010 0 (& 2006)
2 2 9 6 6 4 ^ 9 /2 8 1 3 3 8 8 4 4
10-3-00961-1
40317303
MTSC
04-09-13
V. __ ________________
C0IWtVF,cilC8 OFFICE

County of
\
In re: VV\sl vw c\y v
e.v\v\\ * lc
1C.
No. \ 0 - 3 *
Lvxwd
. Motion/Declaration for an
Order to Show Cause re
Contempt
(MTSC)
Petitioner,
, and
f
^ Ca-v,OW
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rvvx^w
Respondent.
I. Motion
(Name of requesting party)

V ). A m p w \ov\
directing (name of other party)
VC., Liuw vl
court and show cause why an order should not be entered:
1.1
_moves die court for an order

to appear personally before the
Finding Contempt
Does not apply.

[]
[]
[]
[]
the order of child support

the order of maintenance
the parenting plan/custody order
the restraining order
other
Signed by the court on (date)

state)
1.2
U-'O O M
U J c k __________________
Establishing a Judgm ent
PK
Does not apply.
Mot/Dec Ord Show Cause re Contempt (MTSC) - Page 1 of 3

WPF DRPSCU 05.0100 Mandatory (10T2009) - R C W 26.09.160
___in (county and
22988
[]
[]
[]
Granting Sanctions
Does not apply.

Granting sanctions for contempt, including a forfeiture for each day die 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 make up residential time,
as may be appropriate under Chapter 721 RCW, Chapter 26.09 RCW, Chapter 26.10
RCW, Chapter 2626 RCW, and RCW26.18.040.
Imprisonment is sought as a sanction.
[]
'
[]
1.4
5 8 0 IS
Establishing ajudgment in the amount of $

plus $ ___
interest
for delinquent child support and $__________ ____ costs for die period from
(date)__________through (date)________________________
Establishing ajudgment in the amount of $ ___________plus $ ____________interest
for delinquent medical support and $ ___________ _ costs for the period from
(date)
_____________ through (date)_____ _____ _____________
Establishing ajudgment in the amount of $ ____________plus $____________interest
for delinquent child care, educational expenses, transportation expenses, or other special
expenses and $________________costs for die period from (date)______________
through (date)_________________.
Establishing ajudgment in the amount of $____ .
plus $ __________ interest
for delinquent maintenance and $______ ______ costs for the period from
(date)________________ ____ through (date)_______________________.
[]
1.3
4 ^ 9 /2 8 1 3
Other

Dated: J a p iiU __ g ?
ICTfS_______
_____________________________________
Signature of Requesting Party or Lawyer/WSBA No.
VAJ __ ^ V jip r w r \y i______
Print or Type Name

11. Declaration
(Name)
[]
gr
\L _
should be held in oontempt for die following reasons:
Failure to comply with the provision of the child support order which directed payment of.
[]
[]
current child support in the amount of $ _____________ per month.

medical support, including health insurance coverage and cash medical support as
described below:

W PF DRPSCU 05.0100 Mandatory (10X009) ~ R C W 26.09.160
" 2 2 0 8 ^ . 4 / 9 V 2 0 13
[]
6S316
[]
child care, educational expenses, transportation expenses, or other special expenses as

described below:
[]
Other.
Failure to comply with the maintenance order which directed payment of maintenance in the
amount of $ _____________ per month as described below:
Failure to comply with the parenting plan as follows:

Se e
[]
dii-cAov^drio*\
V\)- SVu ^ pyyvxw .
Failure to comply with the restraining order as which required:
This order was violated in the following manner
[]
Other:
correct
Signedat (chy)
NeW
(state)
_
gni
of Requesting Party
___ on (date)
Oasow___ VO- S V i ptwri^n______

' Print or Type Name

WPF DRPSCU 05.0100 Mandatory (10T2Q09) - R C W 26.09.160
23BS6
4 /-1 S ./2 0 1 .3
3 BZ^>
Superior Court of W ashington,

County of
In re:
J & A O J l/to z -
No.
Petitioner,
O rder to Show Cause re

Contem pt
(ORTSC)
Respondent.
and
<JP m
tfi/s
0 0
P f /r r f M f a /
It is Ordered:
(Name of nonrequesting party) Je-t'M.Y**./____ X

shall appear in
person before this court at the place and time below and show cause why the relief requested in the
motion should not be granted*
Date:
S T '? -
Place: P / t O W P f
/3
S c tf & rd K -G ! ti0 e r-
TimP.
Time:_________
Room/Department:
>.m.
V S 72p)
If you fail to appear in person and defend at these proceedings the court may grant all of the relief
requested and/or issue a bench warrant for your arrest without further notice to you.
If imprisonment is requested in the motion and you cannot afford an attorney, you may request the court
to appoint an attorney to represent you.
Other:
Dated:
Signature of Requesting Party or Lawyer/WSBA No.

Print or Type Name
Ord to Show Cause re Contempt (ORTSC) - Page 1 of 1

WPF DRPSCU 05 0150 Mandatory (6/2008) - R C W 26.09.160
4 * * 2 /2 0 3 .3 2 3 0 3 3 3 4 0 0 7 :3
INCOUNTY?tlf?K'S OFFICE
40332219
RTS
04-11-13
A.M.
APR 11 2013
P.M.
KISFm
VyASHINGTON
BY--------------- ^ ___ DEPUTY

County of
In re: *Wq_
No. 1 0 - 3 . - OCPi\o\-\
Petitioner,
and
VO* ^>V\\ipYYV0kj\
Return of Service
(Optional Use)
(RTS)
Respondent.
/ Declare:
1.
lam over the age of 18 years, and I am not a party to this action.
2.
I served the following documents to (name)_________________________

[]
[]
[]
[]
[]
[]
[]
[]
[]
[]
[sf
[Vr
[]
[]
summons, a copy of which is attached

proposed child support order
sealed financial source documents cover sheet and financial documents
Notice Re: Dependent of a Person in Military Service
notice of hearing for
______
motion for temporary order
motion for and order to show cause re: r n A ^ i v v
. ______
declarations of -ÔgJDw___ \AJ
temporary order
other:
Return of Service (RTS) - Page 1 o f 2

W PF D R P S C U 0 1.025 0 (6/2010) - CR 4(g), R C W 4.28.080(15)
4 3 1 2 3 2 3 1 3 /Z IS 1 9
3.
The date, time and place of service were (if by mail refer to Paragraph 4 below):
Date:
A p Y l\
Address:
4.
[]
[]
[]
____________ __ a.m./(ffi)
fWe. t UAO\
'P u Mo U u p

by delivery to (name)___________________________________ , a person of
by publication as provided in RCW 4.28.100. (File Affidavit of Publication separately.)
(check this box only if there is a court order authorizing service by mail) by mailing two
copies postage prepaid to the person named in the order entered by the court on
(date)__________ ____________ . One copy was mailed by ordinary first class mail,
the other copy was sent by certified mail return receipt requested. (Tape return receipt
below.) The copies were mailed on (date)________ _____________ .
(check this box only if there is a statute authorizing service by mail) by mailing a copy
postage prepaid to the person requiring service by any form of mail requiring return
receipt. (Tape return receipt below.) The copy was mailed on (date)__________
Service of Notice on Dependent of a Person in Military Service.

[]
[]
6.
Time:
Service was made; .

ra '
. []
5.
Z4.&B7S
The Notice to Dependent of Person in Military Service was [ ] served on [ ] mailed by

first class mail on (date)______________________________.
Other:
Other:
correct.
Signed at (city) SeXwv______________ , (state) LQTft
_____ ** ___________________________
Signature
_ on (date) ApvU
__ K . XL. S.V\j.pwvx v\
Print or Type Name
OOVI
______
Fees:
Service
________________________
Mileage
_______________________
Total
______ -________________
(Tape Return Receipt here, if service was by mail.)
File the original Return of Service with the clerk. Provide a copy to the law enforcement agency where
protected person resides if the documents served include a restraining order signed by the court.
Return of Service (RTS) - Page 2 o f 2
W P F D R PSC U 01.0250 (6/2010) - C R 4(g), R C W 4.28.080(15)
23133
422.2 2 2 S 1 3 5 E 8 A 3 3
INCOUNTYClI rK'SOFFICE
AM. APR 1 9 2013
BY_

C ounty of
In re: A\\^ TVACXXv\Ov^C
N^tv\wvsvc.r
ine=ur>Y
c fi
No. VO - 3 - 0 0 < A \o l ~r\
VL. L u n d
Petitioners),
and
^(XSOW
RM
V).
Respondents).
Declaration of
\\o&Qn__V J- ^>Vu/7ir\a.A
[Name]
(Optional Use)
(PCLR)
______________

Name:
AoSfrm __ \M
vy p t y x j i__________________
Age:
4 0 _____________________________________
W v -A y * * ^
dT
VlO Y^g-f
I Declare:
\1
V1 v x w
Y"O^XVA\t\g
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A e *v tv fe g
N/\oAAv\v\ .
<.W
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s>e>lgjr n \ ___t ^ v m A ls
tta u i_____
A og\___ woA__YgAiOftwA___ Ad __ A W m^___

p \\ oy\&__ n \W __ SoirwA\t\g^___&Va__ iii\W____
A W w__ V W V __ m V
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Vd v v\rsV__ Vsr W awa/i___Vvim
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A n r A ___UY^?
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vrvis^cd___ vxSvWWwi__ V*^r/vu*___2*W______
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AW srk w \t
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\V\cWAvrfV".__ g-YW>A Vs__ OLMvA
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-------------- :
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Declaration (DCLR) - Page f o f *2~
WPF DRPSCU 01.0100 (6/2006)
'pftW i
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Ap t ___ A W A ----------------------------------------------------------------------------------- --------- *123
(Attach Additional Pages if Neussaiy and Nnmber Them.)

I declare underpenalty of perjuryunder the laws of the state of Washington that the foregoing is true and correct
Signedat_
N eA w \
[City]
V xlcx
[State]on
Afl&tvy
NkK
Print or Type Name
[Date],
^Vx^vrwflîA
Do not attachfin an cial records, personal health care records or confidential reports to this declaration. Such
records should be served on the otherparty andfiled with the court using one o fthese cover sheets:
1) Sealed FinancialSource Documents (W PFDRPSCU09.0220)fo rfin an cial records
2) Sealed PersonalHealth Care Records (W PFDRPSCU09.0260)fo r health records
3) Sealed ConfidentialReport (W PFDRPSCU09.276)fo r confidentialreports. I f file d separately using a txrver
sheet, die records w ill be sealed to prated yourprivacy- Although they *uff he available to a llparties in the
case, their attorneys, courtpersonnel and certain state agencies and boards.) See GR 22(C)(2).
Declaration (DCLR) - Page 2 of 'T W P F D R P S C U 0 1 .0 1 0 0 (0 /2 0 0 6 )
2318B
Yes
Homeland Security:
IBR Disposition:
Forensics:
Case Report Status:
Resolved
None Required
Approved
5 8 8 1 VS
Page 1 of 4
In c id e n t N o. 1 0 0 0 9 6 3 4 .1
P u y a llu p P o lic e In c id e n t
R e p o rt
PDA: |
4 ^ 2 2 /2 8 1 3
subject }
Court Order / Service | DV
Case Management j
Disposition: :
Reporting By/Date: !
I
Reviewed By/Date: |
o o
2 51
<3
PPD226 - Brosseau. Rochelle 11/17/2010

08:00:00
PPD268 - KlefFman, Adam 11/18/2010 02:13:49
ii
Related Cases:
Case Report Number
1 Agency
1 Puyallup
10009511
Police
Non-Electronic Attachments
Attachment Type
ORP - Order for
Location Address:
City, State, Zip:
Contact Location:
Recovery Location:
CB/Grid/RD:
Occurred From:
Protection (copy)
Additional Distribution
PPD - DV Advocate
2323 7TH St Se #B203

Puyallup, WA 98374
9482 Puypd Grid

11/16/201019:26:00 Tuesday
1
l
Location Name: j
Cross Street j
City, State, Zip: j
>
City, State, Zip: j
!
I
Count
j
Bradley Parle Apts
Otstnct/Sector j p y _S1 Occurred To: j
Puyallup - South
1 1/17/2010 17:43:00 Wednesday
Notes:
Assisted By:- j PPD278 - Portmann, Ryan

|Field. . -r --- -- -- - - ^
1
--- - ..Notified: i
;No / " '
,r.r
-rr.r'
Entered By: \ PPD226 - Brosseau, Rochelle
j
Approved By: }PPD15075 -McNrven, Nichole
Entered On: : 11/17/201014:42:22
Exceptional
Clearanoe: j
....... - ApprovedOrt I11/18/2010 08:37:43
Exceptional Clearance Date: i
Adult/ Juvenile Clearance: !- - - --------...
- -- .
- - Other Distribution: *
Additional Distribution: j ppD -DV Advocate
Validation Processing ;'jDistribution Date:
County Pros. Atty-; *
Juvenfle f -j Other i ; -CPS > !Supervisor
City Pros. Atty- . s MffitaryM^ j DSHS 1 , PreTrial > ; --- ----..
- : jBy: : For Law Enforcement Use Only - No Secondary Dissem ination Allowed
Printed: November 3 0 ,2 0 1 0 -3:22 PM
Call Source:
PhoneReport
Insurance Letter
Records has the authority to ensure correct agency, CB/Grid/RD, and Distrid/Sector are incorporated
m the report.
Printed By. House, Natasha
2 3 ie
1^
P u y a llu p P o lic e I n c id e n t R e p o r t
4 /2 2 ^ 2 8 X 3
S 8 3 5 .9 6
Page 2 of 4
In c id e n t N o. 1 0 0 0 9 6 3 4 .1
t
t
Offense Details: 3810 - Protective Order - Service

Yes
j Chad Abuse:
Completed
Domestic Violence:
Completed:
CnminaJ Activity:
*
Location Type:
Total No. of Units
Entered:
Apartment
Gang Related: j
Crime Against j
No
!
Type of Security: j
| Evidence Collected: |
Juvenfle:
Hate/Bias:
No
None (No Bias)
Using:
Tools:
None
Entrance
Compromised:
Entry Method:
Suspect Description:
Suspect Actions:
Nates:
Other Entity Q 1 : Shipman, Jason William______________________________________ PDA: Yes

Aliases: j
DOS:
Height
Address:
City, State Tip:
Other Address:
Resident
1 fi^ e: \ 38
Se* j Male i
s 5*11" * Weight f 775
s Hair Color j
j 8811 133nrfStCtE
I County:
i Puyallup, WA 98373
P Country:
*_
j Nonresident
! OccupationfGrade:
s s N
Driver License No: i
Race:
White
i
;
) Unknown
|
Driver License ] Washington
State:
Attire: j
SMT: j
Entity Type: petitioner
(pap er/o rd er
|
|
| S^tement Obtained: j
! service only)
Ethnicity:
Eye Color
Phone:
Business Phone:
Other Phone:
EmptoyertSchoot
Place Of Birth:
Driver License
Country:
Complexion:
Facial Hair
Facial Shape:
1 Unknown
| Blue
; 253-686-3971
j
]
i Unknown
|
United States of
America
Entity Notes: |
Other Entity 02 : Shipman, Jennifer Kay
PDA:
Aliases:
For Law Enforcem ent Use O nly - No Secondary Dissem ination Allowed
Printed: Novem ber 30, 2010 - 3:22 PM

______________ Printed By: House, Natasha
231S3
I Age:
36
Height i 5 '6 "

i W eight j 180
Address > 2323 7TH St Se #B203
City, State Zip i Puyallup, WA 98374
Other Address iI
Resident ] Full - Time Resident
SSN I B
M
Driver License No
Attire
SMT
soc i Fem ! R **: \ White

I ale
!
HairColor j Brown
| Occupation/Gtade. j
Eye Color i
j
j
Phone: |
Business Phone, j
Other Phone: ;
Nurse
~ ~ T ....
Driver License ! Washington
State: j
Respondent
(p ap er/o rd er
service only)
Blue
253-606-3039
253-985-1711
Emptoyer/schooi: i
Place Of Both: }
s t Clair Hospital
Driver License j
Courtry: i
Complexion: j
Facial Hair. [
United States of
America
Entity Type
Page 3 of 4
B h**** i Non-Hispanic
! County: \
i Country: ;
;
|
BBBV97
I n c id e n t N o. 10009634.1
DOB:
4 ^ 2 2 / 2 S 13
Reporting j
Statement Obtained: j
Facial Shape: j
i
Entity Notes: j
Investigative Information
Means:
| Between 0600 and 1800 hours
I
|
\
Vehicle Activity: j
Motive: !
!
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| Direction Vehicle Traveling: j
Synopsis: {
On November 17,2010 Acting Sergeant J. Pihl #265 gave me the listed paperwork to serve on
Jennifer Shipman. I noted there was a case number assigned but there was no personnel number denoting
who had received the order initially. I checked RMS and observed that no general report had been
completed. I confirmed with records staff that a copy of the original had been created for the case file. I
attempted to contact Jennifer Shipman at her apartment located at 2323 7th St SE #B203 at approximately
0905hrs. There was no answer at the door. I called Jennifer and left a voice mail requesting a call.
Later this date Jennifer called and advised she was meeting her husband, Jason Shipman, for a child
exchange at 1700hrs at Best Buy. She stated that if I could not meet her there she would be available at her
apartment approximately 15 minutes later I advised her I needed to contact her in person but did not
describe the paperwork I had for her.
I later received a call from Jason Shipman asking why the paperwork had not been served last night
I advised him I did not know. I told him I had spoken to Jennifer earlier this date and would be attempting
service tonight shortly after the child exchange. Jason asked if it were possible to arrive at the exchange and
serve her. I stated it would depend on our availability at the time.
I arrived at the exchange site prior to 1700 hrs. Jennifer did not respond. She sent her brother,
Darren Lund, with the children*1instead. He said she was attempting to reach the Family Justice Center
before it dosed. I tried calling [Jennifer she did not answer her cell phone. I asked Mr. Lund to call and
Jennifer answered. I asked where she was currently located. I was hoping to gauge how long it would take
her to return to her home. Jennifer was vague and would not directly answer the question until I redirected
her specifically asking her "exact location at that moment* three times. She stated she was on Court C in
Tacoma but was returning to Puyallup. 1responded to Bradley Park Apartments and waited. When Jennifer
arrived f served her with the temporary order and notice of hearing. I advised City Comm. The record was
updated in WACIC. See attached note.
I would like to note the three prior contacts this department has had with this couple in as many days.
On November 10,2010 Officer Culp #304 took a report of DV Assault from Jason Shipman. The incident
occurred during a child exchange. Jennifer admitted she had hit Jason but stated it was only to get him to let
go of her window. He stated that she had reached out of the window to strike him.
F o r Law Enforcem ent Use Only - No Secondary Dissem ination A llow ed
Printed: Novem ber 30 ,2 0 1 0 - 3:22 PM

______________ Printed By: House, Natasha
2313e
!
4 /2 2 ^ 2 ^ 1 3
5BS13S
Page 4 of 4
In c id e n t N o . 100 0 9 6 3 4 .1
On November 11,2010 Officer Bourbon and I were requested by Jennifer to perform a civil standby
while she and her husband exchanged their two children at Best Buy. The children are aged 9 and 16 years
old. We maintained a visual on the couple from a distance. The exchange was completed without incident I
called Jennifer later and suggested she seek other options for their exchange. I explained there was
insufficient staffing for our police department to attend each of their exchanges. Jennifer stated that she had
wanted to drop the boys off at Jason's mother's home but that Jason would not let her. This required her to
take a day off from work. I suggested she contact her attorney to work on an option they could agree upon
without tiie need for law enforcement interaction. Jennifer stated her attorney was not very good. 1provided
her with information regarding the Judson Family Justice Center and suggested she check their website, call
them, or talk to them in person.
On November 12, 20101 responded to again perform a civil standby at the Best Buy for the couple at
Jennifers request Jason's mother responded for the exchange. She related that she would welcome the
children being brought to her home. Jennifer stated that this was not written in the Parenting Plan and she
felt she should follow it exactly or Jason would hold her accountable in some way. This did net make any
sense since she wanted the exchange through the grandmother on the prior day.
There is no further information at this time. This report will be forwarded to the DV Advocate for
information.
Reviewed By;
Reviewed Date: 1
l
i
F o r Law Enforcem ent Use Only - No Secondary Dissem ination A llow ed
Printed: W ovem ner30, 2010 - 3:22 PM

Printed By: House, Natastto
23133
4222^2813
S231SS
P ie r c e C o u n ty C e n te r f o r D is p u te R e s o lu tio n
738 Broadway, Suite 400
Tacoma, WA 98402
2 53 .57 2 .36 5 7
Fax: 2 5 3 .5 7 2 .3 5 7 9
S e ttle m e n t A g re e m e n t
W e , J e n n if e r L u n d
and
Ja s o n S h ip m a n , having participated in a m ediation
session on D ecem ber 8, 2 0 1 2 , and being satisfied th a t w e have reached a

fa ir and reasonable settle m e n t, hereby agree as follows:
3 .2 SCHO O L SCHEDULE. Upon en ro llm en t in the school, the ch ild (re n ) will
reside w ith th e p e titioner, except fo r th e following days and tim es w hen then
c h ild (re n ) will reside with or be with th e o th er parent: from 5 :0 0 pm Friday
to S un day night a t 8 :0 0 pm and ev ery W ednesday from 5 p.m . to 8 p .m .
Should th e fa th e r relocate into th e Puyallup School D istrict, th e schedule will
re v e rt to th e Parenting Plan dated A ugust 4 , 2 0 1 1 .
3 .7 SCHEDULE fo r HOLIDAYS
Th e 1 0 :0 0 pm end to the Holiday does not apply to th e Fourth o f July. The
Fourth o f July holiday ends on July 5th a t 8 p .m .
In th e e v e n t o f an em ergency, th e residential parent will notify th e o th er

p a re n t by voicem ail, or em ail as soon as possible.
Should th e ch ild (re n ) require a visit to a medical provider, th e residential

p a re n t will provide a 2 4 hour notification by voicem ail or em ail to th e o th e r
p a re n t. I f it is a sa m e day ap po intm en t, then notification will be given as
soon as a p p o in tm en t is m ade.
2 3 IB B
4 '/ 2 2 / 2 8 1 3
S20288
P ie r c e C o u n ty C e n te r f o r D is p u te R e s o lu tio n
738 Broadway, Suite 400
Tacoma, WA 98402
253 .57 2 .36 5 7
Fax: 253.57 2 .35 7 9
H u n te r will participate in a H un ter S a fe ty course a t the Paul Bunyon C en ter

in Puyallup in March 2 0 1 3 .
2 3 '8 3
4 S 2 2 S 2 & 13 5232B 1
Page 1 o f 2
jason shipman < outlaw0015@ gmail.com>
byCkX^lc
(n o s u b je c t)
2 messages
Jennifer Lund < mjent5@hotmail com>
To Jason Shipman <outlaw0015@gmail.com>
Mon, Apr 1,2013 at 3:07 PM
Mr Jason Shipman,
11721 -80th Ave E
Puyallup, WA 98373
(253)686-3971
Mr Shipman,
This is to inform you that Hunter has a dental appointment on Tuesday, April 9th, 2013 with his regular
dentist for his routine cleaning. I was also finally able to get Hunter an appointment with a pediatric
gastroenterologist He has an appointment with Dr Daniel Lustig on Tuesday, Apnl 16th, 2013 at 1 15pm.
(402 - 15th Ave SE, Puyallup). Back on Wednesday, February 13, 2013 you had told me that you would
send me a copy of your health insurance card for Hunter. I still have not received foe card. It would make
things easier dealing with Hunters medical appointments if I had a copy of the card, could you please send
it soon*?
Thank you,
Jennifer Lund
2 3 2 3 -7th Street SE, U101
Puyallup, WA 98374
(253)904-8608
jason shipman * outlaw0015@gmail com>

To. Jennifer Lund <mjen15@hotmail com>
Mon, Apr 1, 2013 at 5 14 PM
As per our divorce settlement you are responsible for all medical costs including medical insurance. I
provide it out of love for Hunter. I have ordered the cards they have not come yet l had a talk with Hunters
doctor He explained the stress of the lack of communication and general stress of being stuck in foe
middle is what makes him sick. There is nothing wrong with him physically Hunter and I talked about it He
explained how he gets upset because how mad you get about what he eats at my house I explained to
him foe doctor told me nothing he eats at my house will make him sick. If it was a food issue dinner Fnday
would make him sick before he went home. I also told him if it was not the food you would be mad at me for
something else. Once he understood you are always going to be mad at me regardless of what he eats all
the stomach problems were gone He has not had any issues since we found out foe truth. Look at the
stunt you pulled this weekend. You knew I was planning on picking him up this weekend. You also knew I
was wiling to let you keep him. I sent you a text. Everyone herd me say ill see you Fnday on Wednesday
night. Yet you didnt show up I think its funny all this started when you stopped him from going to Flonda
by lying about my father. He has not been sick for a long time. I have bent over backward to be nice to you.
I started going to Greg and Amy I started meeting you at Fred Meyers all in hopes you would act like a
mature adult that cares about whafs best for her son rather than how to being vindictive and just plain
mean. Your lies and actions are physically making your son sick. Due to the fact that you blocked my
phone and refuse to communicate we are going to have to revert to the parenting plan and the written
https://mail.google.com/mail/?ui=2&ik=8bfal 3ada4&view=pt&search==inbox&th^l3dc7a...
4/18/2013
2 3 IB S
4^22^2913
5 2 6 2 .9 2
Page 2 o f 2
agreement of mediation. I will no longer meet you at Fred Meyer or Greg and Amy's. Hopefully some day
we can get along enough to try these things again. Until then we need to follow the legal documents. I have
tried to contact you regarding a conversation we had Sunday. Hunter tells me he sleeps on the couch
because your room mate sleeps in his bed. His stuff is in the hallway? This is concerning to say the least.
Please call me so we can discuss these matters and talk about settling our differences for the sake of
Hunter.
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search-inbox&th=13dc7a...
4/18/2013
Gmail - Visitation
Geiail
23133
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B 28> 233
Page 1 of 1
byCiOOgle-
V is ita tio n
1 message
To. Jennifer <mjen15@hotmail com>
Wed, Apr 3, 2013 at 5:05 PM
You're not here. You're cellphone is blocked. You're home number is blocked Do i have to involve
authorities and the courts again? This is only hurting Hunter If i haven't herd from you by 5:30 i will have
no choice.
https://mail.google.com/mail/?ui=2&ik=8bfa 13ada4&view=pt&search=all&th= 13dd25dIf..*
4/18/2013
23189
Gmail - 4-3-13 visitation.
4 /2 2 ^ 2 9 1 3
528234
Page 1 o f 1
jason shipman < outlawOOl 5@gmai1.com>

byGoogle*
4 -3 -1 3 v is ita tio n .
1 message*I
jason shipman < outlawOOl 5@gmail com>
To: Jennifer <mjen15@hotmail com>
Wed, Apr 3, 2013 at 5:38 PM
I just got off the phone with Hunter He informed me you are at a coworkers house. He said you haven't
been to Greg and Amy's and you refuse to bnng him here. I have notified the Puyallup police and Pierce
Co. Sheriff of the situation.
https://mail.google.com/mail/?ui=2&ik=8bfal 3ada4&view=pt&search=all&th=l 3dd27566... 4/18/2013
Gmail - 4-5-2013 pickup
23130
G aail
4 /2 2 /* 2 8 i3
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Page 1 of 1
byCooglc*
4 -5 -2 0 1 3 p ic k u p
1 message
To1Jennifer <mjen15@hotmail com>
Fri, Apr 5, 2013 at 5:31 PM
We are wondering why you haven't arived to pick up Hunter
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search=all&th=13ddccl8f...
4/18/2013
2 3 1 3 8 * 4 V 2 2 2 2 '0 1 3
5 2 B2BS
Gmail - Visitation on 4-10-13
G aail
Page 1 o f 1
jason shipman < outlawOOl 5@gmail.com>
byCoogle
V is ita tio n o n 4 -1 0 -1 3
2 messages
jason shipman < outlawOOl 5@gmail.com>
To: Jennifer cmjen15@hotmail.com>
Wed, Apr 10, 2013 at 5.00 PM
Hunter says he is still at home? Are you going to bring him to the designed exchange area? What's going
on? Simple communication would be nice, If you're going to be late just let us know please. We have only
been late once and I made you aware of it.
jason shipman < outlawOOl 5@gmail com>

To: Jennifer <mjen15@hotmail.com>
Wed, Apr 10, 2013 at 5 53 PM
Its almost six o'clock and you're not here. As you can see from the papers you where served today im not
going to tolerate this. Are you coming or not I need to feed my kids. Not letting Hunter talk to me is also a
violation of the parenting plan.
https://mail.google.com/mail/?ui=2&ik=8bfal 3ada4&view=pt&search=all&th=l 3df66464...
4/18/2013
'2 3 1 8 8
4 /2 2 /2 B 1 3
528287
Page 1 o f 1
Gmail - hunters exchange 4-14-2013
jason shipm an < outlaw0015@ gmail.com>
byGoOgtc
h u n t e r s e x c h a n g e 4 -1 4 -2 0 1 3
1 message
To Jennifer <mjen15@hotmail.com>
Wed, Apr 17, 2013 at 3 58 PM
It was brought to my attention that you didn't pickup Hunter on 4-14-2013. My sister had to take him to
school with no backpack or school supplies You continue to violate section 3 11 of the parenting plan, t
have provided a copy. It clearly states the exchange is to take place at the paternal grand parents unless
we mutually agree otherwise I do not agree to meet you elsewhere due to you not showing up or being
extremely late with no communication I expect you to start going to the proper designated location
pH jason pp.pdf
I a 352K
https://mail.google.com/mail/?ui=2&ik=8blal3ada4&vicw=pt&search=all&th^l3ela383d
4/18/2013
Gmail - 4-17-2013 visitation
23 IS & 4 S Z Z S 2 & 1 3
SZ&ZBB
Page 1 o f 1
jason shipman < outlawOOl5@gmaii.com>

byC.OOglc
4 -1 7 -2 0 1 3 v is ita tio n
1 message
jason shipman < outlawOOl 5@gmaii com>
To Jennifer <rnjen15@hotmail.com>
Thu, Apr 18, 2013 at 10:51 AM
I don't understand why you continue to do this. You know your hurting Hunter he wants to see me. You
know that your supposed to drop off and pick up Hunter from moms like we have done for several years
You have the ability to bring him to moms house. Your choosing not to comply with the parenting plan I
know your planning on going to court and saying you don't feel safe there. We both know that's a lie. There
is no danger at my moms you tried using that lie in court twice before when we decided on the third party
exchange location. Even if that was true you have had several years to change it Three different Judges
have told you to stop doing this stuff. Follow the parenting plan and think about whafs best for the kids.
You where told to act like an adult and communicate One judge even ordered you to go to counseling with
me witch you refused and never did. You didn't show on 4-17-2013 Making me miss my visitation When I
onginally filed the Order to show cause I had not missed any time Now I have missed several
visits, therefore I will be asking for make up time.
https://mail.google.com/mail/?ui=2&ik=8bfal3ada4&view=pt&search=:sent& th=13ele45b... 4/18/2013
23324
4 /3 8 /2 8 1 3
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IN COUNTYHrK'S office
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3) Sealed Confidential Report (WPFDRPSCU 09.270) for confidential reports
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IN COUNTY CORK'S OFFICE
10-3-00961-1
AM
04-30-13
40438425
APR 29 2013
p.m.
5T0N
" M W :PUTV

IN RE:"th e , tYlOJfYlACjt-
dP
k~ ^ U p m a r ]
Petitioner/Plaintiff,
) No. /b '3 ~ d C }/c/~ /___________
Vs.
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t o - s lu p m n
(DocumentTitle)
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Respondent/Defendant
Dated this
day of IRpiljll
2007 documentcoversheetdoc
20
4 - '3 0 r '2 0 1 3
Darren M Lund
580S 0
1715EMainU-102 Puyallup. WA98372 Phone (253) 227-9778
Date: April 26, 2013
To Whom It My Concern:
This letter is written on behalf of Jennifer K Lund (mother), by her brother Darren M Lund in regards to a visitation issue
with Jason W Shipman (father).
On April 3rd, 2013 at about 5:45pm, I was approached by Jennifer and asked if I would consider taking Hunter Shipman to
Jason's mother's home for his visitation drop off. She informed me that for many months prior, (per a court appointed
mediation in December), Jennifer and Jason had been meeting at a neutral non-family location and due to unknown reasons,
Jason suddenly reverted to meeting back at his mothers home.
Jennifer then expressed to me that due to intimidation issue from Jason's brother, Ted Shipman, violent issues from her
son Tyler Shipman and being verbally told she was not welcome at Jason's mother's home, she felt she should not appear
there. She then asked if I would mind taking Hunter to Jason's mother's home, and I agreed.
We left my home, across from the Daffodil Bowling Alley just before 6pm. On the way. I stopped at a roadside mailbox to
mail one letter for my wife. Hunter and I were at Jason's mother's home within about 5 minutes. After dropping Hunter off, I
returned home and was back by roughly 6:15pm.
Sine
Darren M Lund
^HO
J.
in countyfcl1rk*s office
10-3-00961-1
A.M APR 29 2013
04-30-13
PIERCI
KEVINSTOCK,
by._____
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___________nePUTY
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INCOUNTYA S OFFICE
APR 29 2013
'm
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in re: 'H ie .
O e t ir ik f e t
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Respondent/Defendanti
Dated this 3 ^ day of Pk^Lil)
2007-docinrteiitcovcnheeLdoc
2023
d^
H^
i D 4. J
To whom it may concern:
30CJ3D
On the evening of July 1 2012, \, Deborah R. Bergman, accompanied Jennifer Lund to the home of Jason
Shipman and his parents, Pete and Becky Rambow, residing at 1172180th Ave E in Puyallup, Washington
98373. We arrived around 6:45pm. As I was rounding the back of the house, where I heard children and
adults playing baseball, I made eye contact with Jason Shipman. His sister, jStaci, said, "Sorry, Jason, they
caught up to you." I looked down to keep from tripping on loose gravel. When I looked up, Jason had
disappeared around to the front of the house. Jennifer saw him enter the residence through the front
door. Jason's sister, Sierra, toid me, "Sorry Jason's not here." I asked, "Oh.Lthat wasn't just Jason I saw?"
Sierra replied, "Ub, well this is private property, so you need to get off and leave." Their niece,
Samantha, then added, "Yeah, you are trespassing on private property, so get the hell off!" Staci then
jumped in and said, "Sorry, you need to leave now) This is private property and you are trespassing and
you need to leave." i said, 'Thank you, have a nice day/' and i returned to [Jennifer's vehicle.
As I was relaying what was said to Jennifer, Jason's fiancee drove away in a white minivan. Jason
followed soon after in his mother's vehicle. Jennifer called the Puyallup Police Department's nonemergent number to see if they could provide us with the civil restraining jorder and other documents or
serve him a civil stand-by. The dispatcher informed Jennifer that Puyallup P.D. does not service that area
and that she would need to call the Pierce County Sherriff s Department. While she was on the phone,
Jason's brother, Theodore Shipman approached the driver's side window and said to Jennifer, "Sorry, it's
not going to happen today. You need to get off our property." Theodore pointed to 117th St and said,
"Go park over there. You can't park here." Jennifer replied, "I am on the phone with the Sheriffs
Department," while rolling up her window. Jennifer was parked on the easement of 80thAve the entire
time. She technically was never on Pete and Becky's property. Jennifer did move to appease Theodore.
f
Kasey came back while Jennifer and 1were waiting for an officer from the Pierce County Sherriff s
Department to arrive. Deputy Christian (Badge#477) and Deputy Burke (546) arrived just before 7:15 pm.
The Deputies informed Jennifer and i that they no longer get involved with serving civil restraining
orders, but would be happy to talk with Kasey to get this matter resolved! After talking with Kasey for a
bit, the deputies returned to Jennifer's vehicle and informed us that Kasey did not want to, and did not
have to accept the court papers containing the restraining order and other documents on Jason's behalf.
Deputy Christian then went to his vehicle and returned to us with a number for the Pierce County CMI
Department. He tofd us that the Pierce County Civil Department may be able to help with tfie serving of
papers.
We left Pete and Becky Rambow's residence at about 7:45pm and drove to the Hand! Corner on 112th.
We sat there waiting for Jason to drive by until about 8:10pm. While driving down 112th on our way back
to my vehicle, we passed Jason and he flipped his middle finger at us as he drove by. We traded vehicles
and arrived back at the Rambow's residence around 8:25pm. The minivan was gone. We drove to the
gas station and filled up. We left Puyallup at approximately 8:52pm.
23324
4^30^2013
8 8 b3
We arrived in Yetm at Jason and Kase/s house at around 9:15pm. When we drove by, the white minivan
was not there, so Jennifer drove us to Jack-In-The-Box for some dinner. We returned approximately 30
minutes later. Jason and Kasey's garage was open and the white minivan was parked across the road
next to Jason's work truck. Kasey was standing outside of the garage, smoking. Jennifer and ( circled the
block one time to see if Jason would join her. When we came back around, the garage was dosed and
Kasey was no longer in sight.
Jennifer parked at the top of the cul-de-sac in hopes of seeing Jason come out. As we were waiting,
Kasey came out to smoke but Jason did not join her. Soon after, a Yelm Police Officer pulled up behind
us. The neighbors had called them because Jennifer and t were parked by mail boxes and they were
concerned. He asked what we were doing there and Jennifer informed him that we were trying to serve'
her ex-husband with a Civil Restraining Order and other Documents. Kasey was still outside and the
officer offered to talk with her to find out if Jason was home. Kasey told the officer that he was not
there and she did not know when he would return.
The officer asked us to park somewhere else, so Jennifer and 1 parked in the Safeway Parking Lot. This
stiil provided a line of sight to the cul-de-sac where Jason's residence was and continued watting for his
return. At 11:10pm, Jason drove his Hariey Davidson into the Safeway Parking Lot and parked two rows
behind our vehicle. He glared at us while he spoke on his cell phone to someone. A few moments later,
his fiancee Kasey pulled into a stall by him and they began talking. Then Jason drove up and parked by
the passenger window, where I was sitting. As we were trying to roil the passenger window down, Jason
said, "Weif come on I Rolf down the window; Roll down the fucking window^ Once I got the window
down, Jason said, Three StarsTI handed him die paperwork and said, "Jason Shipman, you've been
served." Jason Shipman was served at 11:19pm.
Jennifer was so upset by Jason's anger and harsh words that it took her a half of an hour to be able to
drive us back to Puyallup.
If there are any questions or concerns, I can be reached at 253-486-6309.
Thank you,
(Name Printed)
(Signature)
413/ U J
b o tib ti
IN COUNTY ctf&CS OFFICE

10-3-00961 -1
40438452
CPEM
am.
04-30-13
APR 29 2013

IN R E :7 W e fM /r id a e ,
d e n fitte r k .
Vs.
) No. ID ~ 5 ~ Q 0 ^(d I - I
d o sttin 10-
!j& W
j j
Respondent/Defendant.
Dated this
day of JQ$Uj
2007 document,coversheel,doc
20 P ,
t,
K
do sm
? < J e n m k r/ W
( S fiL p m a s )
23324
4/7^13
4 ^ 3 3 /2 8 1 3
B88S1
Outlook Print Message
Re: H unter's u/s, $ you owe

From: jason shipman (outlawOOl5@gmafl.com) This sender is in your contact list.
Sent: Tue 11/27/12 6:15 PM
To: Jennifer Lund (mjenl 5@hotmafl.com)
If you w here in court you would have herd the judge state you are to return my soda machine and pool
table. If not returned im entitled to m onetary compensation. That being said i support five kids. I dont
have any money to give you. My w ife is a stay at home mom. I wish i could pay you. I wish i had herd this
from you not Hunter on the phone today.
On Nov 27, 20126:04 PM, "Jennifer Lund <rnienl5@ hotm ail.com > wrote:
| Novem ber 27, 2012
j M r. Jason W. Shipman
f 11721-80th Ave E
Puyallup, WA 98374
(253)686-3971
outlaw0015f5)gmail.com
M r. Jason Shipman,
1wanted to inform you that Hunter has an appointm ent this Thursday (11/29/12) morning
i fo r an abdominal ultrasound at Medical Imaging Northwest at Good Sam. His pep does not
do them . This procedure is simple, noninvasive and w ill only take a couple of minutes. It's
the same as when a pregnant woman has an ultrasound of her unborn baby. You can google
fo r more inform ation if you need it. Hunter has been having complaints of abdominal pain,
diarrhea, nausea w ith occational vom itting. The doctor just wants to make sure his
gallbladder is ok, that is why she ordered the abdominal ultrasound. Hunter needs to be on
a fat free diet 24 hours prior to the ultrasound. Since he is with you Wednesday (11/28/12)
evening, please do not feed him a fatty meal. If you do so it could alter the results of the
ultrasound. If you do not want Hunter to have this procedure please le t me know so that I
can cancel the appointm ent. If there is any abnormal result I w ill let you know, otherwise if
you do not hear from me the results were normal.
On August 4,2011 per the decree of dissolution you were ordered to pay me a principal
Judgement amout of $1,643.75. It has been 151/2 months and I have not received any
money from you in regards to this debt, t have been gracious in giving you tim e to come up
w ith the money so now I would greatly appreciate the amout to be paid in full w ith in 30
days. A creditor would have sent you to collections and/or garnished your wages months
ago. If I do not receive the money you owe to me w ith in 30 days then I w ill pursue other
options in collecting the money. Your attention to this m atter is appreciated. If it's easier
h^7/bay156.rnai!.!i\e.conVrat/PrintMessages.3spx?cpds=85f1dO29-39O1-1l02-b64f-OO215acf7ri5O,rn8dsSafB=true&Fo<deflD=OOOOOCX)O-OOOO-OOOO-OOOO-OOO . 1/2
23324
42313
4 /3 8 /2 8 1 3
SS3&2
Outlook Print Message
for you, you can send me a check in the mail. I have recently moved. My address is the
same, the only thing that changed is my apartment number. Im now in U101.
Signed,
Jennifer Lund
2323 - 7th Street SE, Apt U101
Puyallup, WA 98374
(253)245-4255
rnienl5@ hotm ail.com
https7/bay156.nral Jive.cxrrVrnail/PrintMessages.aspx?cpdb= 850 d029-3901-11e2-bcM^(Xt215ad7T150IrrAsSa^tnje&FdcterlD=00000000-0(XX)-000(>0000-000...
23324
ijjjjiw iiiiiii
10-3-00961-1
III
CPEM
53Sb3
in county ? H rk,8 office
M /fllllJM
40438463
4 /3 0 ,-2 8 1 3
04-30-13
APR 29 2013
pa
f f l 5
by________
p M.
f f
-D eputy

IN RE: 'ih .c .
fru x /n c ta e ; d f1
d n n d e r K Shbpnuw
Vs.
! No. ID -d rD W b H
c i m ? iD .d u fM m
Respondent/Defendant.
Dated this
day of
1007 document,covctshect.doc
ll
2oZ3_
23324
4/29/13
4 /3 tJ /zeid
tjotjti-i
Outlook Print M essage
M ove to Puyallup
From. Jason shipman (outlaw0015@gmafl.com) This sender Is in your contact list.
Sent: Sun 4/28/13 6:43 PM
To: Jennifer (n5eni5@hotmafl.com)
We have finally moved to Puyallup as per our previous discussions. 3.14 o f the parenting plan doesn't
apply because Hunter resides w ith you the m ajority of the tim e. We have discussed me moving back as
soon as could. Our new adress is 1242180th ave. Hunter is not prepared to go to school tomorrow.
Therefore his Sunday overnights shall start next visit. I w ill have him at the designated exchange point at
8:00 per the parenti ng plan.
httpsJ4)ay156.mail.live.corrVmaii/PrintMessages asptf?cptds=3a52cf73-b06e-11e2-9503-00215ad846a4,m&isSafe=1rue&FoIdertD=00000000-0000-0000-0000-00. .
1/1
E-FILED
May 01 2013 10:23 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)
Name: JENNIFER KAY SHIPMAN
Address: 2323 7TH ST SE APT U101 PUYALLUP, WA 98374
Phone:
Petitioner
Show Cause
Nature of Hearing: Contempt
CALENDAR DATE: Tuesday, May 28, 2013 9:00 AM

DATED:
May 1, 2013.
Signed:
NAME:
Phone:
ADDRESS: 12421 80TH AVE E

PUYALLUP, WA 98373
WSBA#:
For:
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May 1, 2013 9:00 AM
Show Cause
KEVIN GRUNDLE
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Clerk
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INOPENCOURT
3-00961-
40453667
ORCNT
MAY 0 1 2013
05-02-13
P IE R C E C O U N T Y , C le rk
vBy__ j y OEPUTY
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR PIERCE COUNTY
NW- LuntJ
In Re:
U ^ m -fe r
Petitioner/Plaintiff
no.
\m /}
I f)
ORDER RE: CONTINUANCE TO

APPLY FOR COURT APPOINTED
ATTORNEY
and
) a s o M
< h > p M 4 /l
RespondentyDefendant
ORCNT
THIS MATTER having come on regularty for hearing, and the Court having found that the
Petftioner/Respondent fs a t substantial risk of Incarceration, ft Is now therefore,
ORDERED, ADJUDGED am i DECREED, that this maty js hereby continued to:
- n > t l m v | M l W O f f , O l 3 _____________ , a t M 9 :0 0 AM 1:30 PM In
such Room as posted,' Pierce County dourthouse, County-Cfty Bufkfln( 930 Tacoma Avenue South,
Tacoma, WA 98402 . This m atter is continued to allow the Petftioner/Respondent to obtain
representation through the Department of Assigned Counsel, but only In the event the
Petftioner/Respondent financially qualifies for said representation. To apply for legal representation
you must contact the following office w ithin 4 days o r YOU WILL BE DEEMED TO HAVE WAIVED
YOUR RIGHT TO COUNSEL:
P retrial S ervices:
910 Tacoma Ave. S., 4 th Root, Tacoma, WA, 98402

11:00 a.m. to 2:00 p.m. only Monday, Tuesday, Wednesday
253 -798-3478
NOTICE: THE PETITIONER'S/RESPONDENTS PRESENCE AT THE SAME TIME AND PLACE

SET FORTH ABOVE IS MANDATORY AND SHOULD THE PETITIONER /RESPONDENT FAIL TO
APPEAR, THE COURT WILL ISSUE A BENCH WARRANT FOR HIS/HER APPREHENSION AND
CONFINEMENT IN JAIL UNTIL SUCH TIME AS THE MATTER CAN BE HEARD.
M flV
.day of
ner
KEVIN RUNDLE
ffa o TEH ,
Respondent
ORDER RE: CONTINUANCE TO APPLY FOR COURTAPPOINTED ATTORNEY - Page 1 Of 1 (01/1V U )
5 /2 1 /2 0 1 3
10-3-00961-1
AFRSP
40661843
05-21-13
IN COUNTY O jI rKS OFFICE
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MAY 21 2013 ril

County of T>\excj^
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Declaration (DCLR) - Page ? o f 4
WPF DRPSCU 01.0100 (6/2006)
10-3-00961-1
40561044
05-21-13
DCLR
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MAY2.1 2013
a.m.
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WASHINGTON
KEVINSTOCK, County Clerk
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DEPUTY

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1 declare under penalty o f perjury under the laws o f the state o f Washington that the foregoing is true and
correct.
Signed at
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court /personnel and certain state agencies and boards.) See GR 22(C)(2).
Declaration (DCLR) - Page 2 of 2 .
WPF DRPSCU 01.0100 (6/2006)
10-3-00961-1
40561861
DCLR
05-21-13
FI LED

aja.
MAY 21 2013
p.m,
PIERCE COUNTY,WASHINGTON
K B V IN s g ^ C ^

County of rV>\z_rcjL~
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Petitioners),
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Print or Type Name

If filed separately using a cover sheet the records will be sealed to protect your
D eclaration (DCLR) - Page 2 of _ 3 1
W PF D R PSC U 01.0100 (6/2006)
E-FILED
IN COUNTY CLERI
PIERCE COUNTY, W
May 28 2013 8
KEVIN STi
COUNTY C
NO: 10-3-00
2
3
4
5
6
7

8
9
JENNIFER SHIPMAN,
Petitioner
10
11
and
12
JASON SHIPMAN,
13
14
15
)
)
)
)
)
)
)
)
)
CAUSE NO. 10-3-00961-1

DECLARATION OF
JENNIFER SHIPMAN
Respondent.
)
_______________)
I, Jennifer Shipman (Lund), declare under penalty of perjury under the laws of the State
16
of Washington, that the following is true and correct to the best of my knowledge and belief:
17
I am over eighteen (18) years of age. I am competent to testify regarding facts set forth
18
19
20
in this declaration. I am the petitioner in this action.

I have been delivering our son, Hunter, to a mutually agreed upon drop-off location every
21
Wednesday and Friday at around 5:00 p.m. I pick him up from the same location at around 8:00
22
p.m. every Wednesday and Sunday. Jason and I agreed in December 2012 during our mediation
23
that our visitation exchange would move from his mothers home to Greg and Amy Edwardss
24
home. That agreement was made verbally because Jason refused to include it in our written
25
26
DECLARATION OF JENNIFER SHIPMAN - 1
Law Office of.Kathrine Price

622 Tacoma Ave S., Suite #1
Tacoma, WA 98402
(253) 292-9767 office
(253) 732-1137 cell
(253) 444-0453 fax
k.price.law@gmail.com
1
2
3
mediation agreement. Although unwritten, I was able to file proof of that agreement with the
court in the form of a declaration from Mrs. Edwards indicating that she received a call from me
while we were in mediation on December 8th, 2012, and our visitation exchange has taken place
at her home since December 9th. We have met there regularly to pick up and drop off Hunter,
although when we mutually agree to meet elsewhere (such as a store closer to Jasons home), we
have done visitation exchanges elsewhere. I have not agreed to go back to his mothers home,
but occasionally I have no choice.
8
9
10
From my prospective, the location of our pick ups and drop offs needed to change
because there had been too many hostile interactions at Jasons mothers house. Tyler, our older
son, is living there. In September 2012 when I was there to drop off Hunter, Tyler became angry
11
and hit my car. In addition, Jasons family has indicated to me that I am not welcome at the
12
home as indicated in Deborah Bergmans declaration regarding serving Jason Shipman with an
13
14
15
16
17
ex parte restraining order in July 2012. I do not feel comfortable, safe, or wanted at Jasons
mothers house, and I do not think it is a good place for the visitation exchange for Hunters
sake.
Although we had agreed to an exchange at Mr. and Mrs. Edwards home, Jason on his
18
own has apparently decided to change the exchange location back to his mothers home. I
19
believe he has made this decision maliciously, and it certainly was not agreed upon by both
20
parties. After Spring Break 2012, Jason started changing where he would decide to show up for
21
22
the exchange. Occasionally he would meet me at the Edwards as agreed, and occasionally he
would go to his mothers home, act surprised that I wasnt there, and threaten to shorten or limit
23
my visitation time if I didnt agree to his mothers home as the exchange location at that
24
moment.
25
26
DECLARATION OF JENNIFER SHI PMAN - 2

.
LawOffice of.Kathrine Price

Tacoma, WA 98402
(253) 292-9767 office
(253) 732-1137 cell
(253) 444-0453 fax
1
2
3
Spring break began on Friday, March 29. Under our parenting plan, I had blunter the first
Yz, and Easter (March 31). As has been our practice for the last few years, I assumed Spring
Break included the weekend before and after. Because I thought it was my visitation time, I
allowed Hunter to spend the night of the 29th at a friends. Apparently, Jason disagreed with my
assessment of the weekend schedule. He arrived at the Edwards home at around 5:00 p.m., and
was furious to find that Hunter wasnt there. Jason had his wife, Kasey, retrieve Hunter from
Hunters friends home that night. Since Easter was my holiday, I expected to pick up Hunter at
8
9
10
the Edwards Sunday morning. Jason refused to bring him to the Edwards, and forced me to get
Hunter at Jasons mothers home. I took Hunter to the Edwards on Wednesday evening, April
3rd, but Jason didnt come. He demanded that I take Hunter to his mothers home. I could tell
11
that Jason was escalating and was afraid to put myself in an uncomfortable and potentially
12
dangerous situation. Not wanting to deny Hunter time with his dad, I asked my brother, Darren
13
14
15
16
Lund, to take Hunter for me. He did, and has written a declaration documenting the trip. When
Jason wrote those emails on April 3rd, he knew I was at the Edwards home waiting for him.
In keeping with Jasons assessment that Spring Break didnt include the weekends, 1
17
expected to pick up Hunter from the Edwards Friday night, April 5th. I was at the Edwards
18
home at 4:50 p.m., ahead of schedule. Jason texted at 4:54 p.m. saying he would be late, so I
19
wasnt concerned when he hadnt arrived by 5:30 p.m.. Then Jason sent a text at 5:38 p.m.
20
saying that if I wasnt at his mothers home by 6:00, he was going to keep Hunter for the entire
21
22
weekend. I took a friend and got there as quickly as I could.

Jason alleges that I refused to give him visitation on April 10lh. This was the day his wife
23
served me at my home. Although they were both there, they didnt take Hunter with them. He
24
was outside with me. Even if they didnt see Hunter, they could have asked where he was and if
25
26
Law Office of Kathrine Price

Tacoma, WA 98402
(253) 292-9767 office
(253) 732-1137 cell
(253)444-0453 fax
he could go with them. I took Hunter to the Edwards home as soon as Jason and Kasey left
1
2
3
4
because I assumed that was where they were headed. I sent a text at 6:31 p.m., are u coming to
get Hunter? They never showed up.
I went to the Edwards early on Sunday, April 14th, but no one brought Hunter. Hunter
sent me a text after 8:00 p.m. to let me know he was at his grandmas home and his dad had left.
No one was willing to bring Hunter to the Edwards, and I didnt have anyone to go with me.
Jasons family was willing to take him to school the next day, so I allowed him to spend the
night. I reminded Hunter to pack a lunch for the field trip the next day.
10
On Wednesday, April 17th, I sent a text to Jason at 2:08 p.m. to let him know that Hunter
would be at Amys house early and could be picked up any time after 4:00 p.m. Jason did not
11
show up. Instead he sent a text back at 3:20 p.m., you are in violation of the parenting plan.
12
On Friday, April 26th, our visitation exchange took place as normal at the Edwards
13
home. Sunday, April 28th, I went to the Edwards home to pick up Hunter. Again, I received a
14
15
16
text from Hunter saying that he was at his grandmas house. My brother agreed to retrieve him.
On Wednesday, May 1st I went to the Edwards house with Hunter. Jason never came.
17
On Wednesday, May 8th, I had just had surgery and was unable to drive. Mrs. Edwards came to
18
my home to get Hunter and take him to her house to wait for Jason. I texted Jason at 1:05 p.m.
19
to let him know that he could get Hunter early from the Edwards home. Jason never came,
20
although his text back to me confirms that he received my message in plenty of time.
21
22
23
On Friday. May 10th, our visitation exchange took place as normal at the Edwards home.
By then, Jason was living in Puyallup, so Hunter spent the night Sunday night. There was no
exchange on Sunday - Jason made sure Hunter got to school, and then Hunter just came home
24
after school Monday evening.

25
26

.
Law office of Kathrine Price

Tacoma, WA 98402
(253) 292-9767 office
(253) 732-1137 cell
(253) 444-0453 fax
1
2
Sunday, May 12th was Mothers Day - my designated day per the parenting plan. I
arrived at the Edwards home to get Hunter at 7:45 a.m. At 8:15 a.m., Hunter sent a text stating
that he was at his grandmas house. At 8:20 a.m., Jason sent a text stating that he hadnt heard
from me so he was going to keep Hunter for the rest of the day (even though Mothers Day is
clearly my day). I took a friend with me to Jasons mothers home and retrieved Hunter.
Wednesday, May 15th Hunter and I arrived at the Edwards home on time for the
visitation exchange. Hunter complained, whats the point? He said his father was in Florida
8
9
10
anyway, and wouldnt be able to pick him up. Attached please see Facebook postings from both
Jason and his wife, Kasey, confirming that Jason was in Florida that day.
On Wednesday, May 22nd and Friday, May 24th, our visitation exchanges took place as
11
normal at the Edwards home.
12
The text messages I ve attached show that Jason and I have both been late to visitation
13
14
15
exchanges. They also show that we were meeting at the Edwards.

Jason is trying to use the court system in an abusive fashion. As you can see in the email
16
attached to this declaration dated May 11, 2013, in a single email Jason both threatened to send
17
me to jail and then stated, i just want us to get along. Over the last few months, visitation
18
exchanges have become much more stressful than they already had been for Hunter. I hope that
19
the court will discourage Jasons erratic and abusive behavior, and deny his motion.
20
21
22
23
24
25
26
Law Office of Kathrine Price

Tacoma, WA 98402
(253) 292-9767 office
(253) 732-1137 cell
(253) 444-0453 fax
k.price, lawgmail.com
9 0 13
Feb 2 7, 2013, 10:40 A M
j^Sure at 8 30^)
( i s 8:30 going to work? )
; ( Not really no im com ing
ijjjrbm Tacom a
Feb 20, 2013, 7:39 PM
^We are going to finish the >

show we are watching. Its
over at 8. We will be 10
^minutes late._____________ ^
Feb 2 7, 2013, 5:13 PM
M a r 3, 2013, 5:58 PM
Feb 27, 2 0 1 3 ,10:40 A M
( T e x t M essag e
( T ext M e ssa g e
2 )
f a : Feb 3 f
Feb 3, 2013, 6 :48 P M
M a r 11, 2013, 6:02 P M
Âre you alm ost h e r e TJ

o k 8 fine^)
M a r 3, 2013, 8:13 P M
jÂre you clo se? ^
M a r 11, 2013, 6:02 P M
^We are done. Be at fred

Meyer in about20 minutes^
A re you almost here? )
T ext M e ssa g e
y .
/jM fi
f T ext M e ssa g e
3>
Ôk ill pick him up at greg ^

and Amy's a little early if
^possible Maby 4:45. ?
^
^ls that going to be A
J possible?
Mar 13, 2013, 3:51 PM
haven't gotten a
^
response. Are you bringing
him to class? Are you
picking hum up there?
Can i scoop him up at the
r\
Mar 13,
I havent gotten a
response. Are you
him to class? Are
picking hum up there?
Can i scoop him up at
gate to you're apartment?
What's the plan?
M a r 13, 2013, 4:10 PM
^Thanks )
Mar 13, 2013, 9:19 PM
They are done )

------------------------1I
ibiv1
( T ext M e ssa g e j
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S---------------------------------------------------- N
Read you're e mail and

papers served you are in
violation of the parenting
plan, I will have witnesses.
Testimony. Im done with
you hurting Hunter. Im at
the drop off point you're
not here
L - _______ ____________________________ J
A pr 17, 2013, 2:08 PM
I have sent numerous

texts. I have sent several E
mails to
mjenl 5@hotroajJLoom. you

are in violation of the
parenting plan.
A p r 17, 2013, 3:20 PM
Q T ext M e ssa g e
M a y 8, 2 0 1 3 ,1 :0 5
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him he is at hom e said
amy w as on her way. Why
can't amy take him to
moms. I don't want to
violate the parenting plan
.
i '
Jr
M a y 1 2 ,2 0 1 3 ,8:20 A M
Îts 8:18 i haven't herd from^

you im going to take him
amy was on her way. Why

can't amy take him to
moms. I don't want to
violate the parenting plan
M ay 12, 2013; 8:20 A M
Its 8:18 i haven't herd from

you im going to take him
home w me
T ext M e ssa g e
Wl 'd
ILL9 'M
m d km m
Eios
iz ,
&
- n
Kasey Shipman > Jason

Shipman
Friday at 12:40 PM &
| Less than 36 hours &u'll b in my arms !

H Can't wait SKinda missed u !
1
| i r Like
Comment
Kasey Shipman Jason

Shipman
Wednesday at 10:27 PM &
| I miss u ! Hope u r having a blast in the sun !

| Can't wait to pick u up !
I 2 Likes
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Jason Shipman
May 14 at 4:49 PM n
5/5 'd
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Wednesday at 1Q;27 pm
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I miss u ! Hope u r having a blast in the sun

Can't wait to pick u up!
2 Likes
if r Like
Comment
Jason Shipman
May 14 at 4:49 PM l i
Fishing with the old man. Had to pull over to

change the od. By by Niel Diamond hello
Alabama.
6 Likes 2 Comments
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Jason Shipman w a s at Tampa

International Airport (TPA).
May 14 at 5:42 AM in Tampa, FL i t
I. '
Tampa International Airport

fTPA)
Government Organization
2 Likes 2 Comments
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Jason Shipman was at SeattleTacoma international Airport

(Sea-Tac).
. May 13 at 10:00 PM in SeaTac &
1, . .__
'ortflc? Seattle-Tacoma
cl S
Z ? le' International Airport (SeaIru+rvHtaruuAtom Tac)...
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Outlook- rnjen15@hotrnal.com
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Jason Shipman
F o ld e rs
Move to
- :* - ; W e d n e s d a y i T ^ y S tteP
(. steco
/Vf :*'
J a s o n Sh
View contact
5 1 1 /1 3
T 0: Jennifer
Inbox
Junk
Drafts
Sent
Deleted 3
New folder
Q u ic k v ie w s
Documents
Flagged 1
Photos
Shipping updates
New category
Jennifer,
<You neglected to bring Hunter to visitation on Wednesday
the 8th. I will be asking for a makeup day for that. Also I was
very disturbed to read your deposition.You show no
remorse for the past mistakes.You continue to try and argue
you're side of the things you where found in contempt for.
At this point I think jail is the only thing thats going to
convince you to follow the parenting plan.Therefore i will
be asking the court to sentence you as such. Jen i just want
to get along. Compromise and communicate so Hunter can
have a happy childhood. Please tell me what I can do to get
us pastthis.The more I try to be nice and accommodate you
the more you do things to try and hurt me. Unfortunately
the only one you hurt is poor Hunter.
I will have our son at the designated drop off location, per
our working parenting plan at 8 am Sunday morning.
Mothers Day.
r A M
L [/
ll
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H r V r L A d in ^ u L f c h a n j L -
May 28, 2013 9:00 AM
Show Cause
MARYE DICKE
l o a l f v / n .
Clerk
Q 0 -t 0 >
i d
S' A A
Run cfate/time 05128/13 8 07

Ixcrtrpt p b l d jo u m a !_ e n try_ sb o w ca u se _ re p o rt
E-FILED
June 03 2013 9:22 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1

Petitioner(s),
vs.
NO. 10-3-00961-1

_______________ Respondent(s)
AND TO: Kathrine Price, attorney for Petitioner, JENNIFER KAY SHIPMAN, TYLER
SHIPMAN, HUNTER SHIPMAN
PLEASE TAKE NOTICE that Daniel N Cook, appears herein on behalf of the
Respondent(s) JASON WILLIAM SHIPMAN and requests that all further pleadings and paper,
except original process, be served upon said attorney at the address listed below.
DATED: June 03, 2013
ntaprsup-0001.pdf
/s/ Daniel N Cook

Daniel N Cook, #34866
Attorney for Respondent(s)
Faubion, Reeder, Fraley and Cook, PS

5920 100th St SW Ste 25
(253) 581-0660
10-3-00961-1
40637504
QFtSC
06-04-13
IN COUNTYFcti*K 'S
office
JUN OS 2013 PM.

NGTON
Oerk
.OEPU

County of
Ln re:
no
Petitioner,
and
lO 'V O M rM
Order on Show Cause re

(ORCN)
N e x t H e a rin g D ate:
Respondent
[ ] Clerks Action Required,
3.8
l. Judgm ent Summary

([
[]
A
B.
C
D
E
F
G
H
I
J
K
L.
Does not apply.

Applies as follows'
Judgment creditor
____________________
Judgment debtor
____________________
Principal judgment amount (back child support/medical support/other obligations/
maintenance) from (date)__________ through (date)___________
$ ____
Interest to date of judgment
$
Attorney fees
$
Costs
$
Other recoveiy amount
$
Principal judgment shail bear interestat__________ % per annum
Attorney fees, costs and other recovery amounts shall bear interest a t __________ % per annum
Attorney for judgment creditor
_______________________________
_______________________________
Other
Ord on Show Cause re CntmptAJdgmnt (O RCN) - Page 1 of 7

WPF D R PSC U 05 0200 M andatory (10/2009) - R C W 26 09 160\ 7 21 010
23834
2.6
68848
Back Child Support/M edical Support/Other Unpaid Obligations/Maintenance
[]
[]
[]
[}
[]
[3
[]
2.7
6 /4 ^ 2 8 1 3
Back child support/medical support/ child care, educational expenses, transportation

expenses, or other special expenses/maintenance is not addressed in the contempt motion
No back child support, medical support, child care, educational expenses, transportation
expenses, or other special expenses, or maintenance is owed.
(N am e)_____________________________________ failed to pay the other party the sum of
$________ (_______ for child support and interest to date in the amount o f
$________________ for the period from _________________ through_________________ .
(Name)
failed to pay the other party the sum of
for medical support and interest to date in the amount of
$____
for the period from _____________ ___ through
$
(Nam e)_____________________________________ failed to pay the other party the sum of
$________________ for child care, educational expenses, transportation expenses, or other
special expenses and interest to date in the amount of $________________ for the period
from _________________ through_________________ .
(N am e)______
failed to pay the other party the sum of
for maintenance and interest to date in the amount of
$__________
for the period from _________________ through
$
Other:
Compliance W ith Parenting Plan

[]
[]
Does not apply.

*
(Name)
has complied, and is currently willing
to comply, vuth the parenting plan V
(Nam e)______________________________________ has not complied with
[]
[]
[]
[)
the residential (visitation) provisions of the parenting plan and had the ability to
comply with the parenting plan, and is currently unwilling to comply. The
noncompliance with the residential provisions [ ] was [ ] was not in bad faith
decision making provisions of the parenting plan and had the ability to comply
with the parenting plan, and is currently unwilling to comply
dispute resolution provisions o f the parenting plan and had the ability to comply
with the parenting plan, and is currently unwilling to comply
Other
Ord on Show Cause re C ntm pt/Jdgm nt (ORCN) - Page 3 of 7

WPF DR PSC U 05 0200 M andatory (1 0 /2 0 0 9 )- R C W 26 09 160, 7.21 010
3834
6 /^ 2 8 1 3
60841
II. Findings and C o n clu sio n s
This Court Finds:
2.1
C o m p liance W ith C o u rt O rder

(Name)
comply w'itfl a lawful order o f tiie colirt dated o
2.2
did comply [ ] intentionally failed to

______
N ature o f O rd er
The order is related to [ ] child support [ ] medical support [ j child care, educational expenses,
transportation expenses, or other special expenses [ ] spousal maintenance flQjarenting plan
(custody/visitalion) [ ] a restraining order.
2.3
H o w the O rd er w a s V iolated
[]
2.4
The order was not violated.

This order was violated in the following manner (include dates and times, and amounts, if
any):
P ast Ability to C o m p ly W ith O rd er

(Name) P i/(\j(w < X
with the orddar as follows:
hJbfadM O M t
<zfo A p rr(M ^
^ had [ ] did not have the ability to comply
X I A jh d iM u L / V V ? C d f j } U L fU J^
j^ c J h jP i/V '^ e w - d i
2.5
fA
P resent Ability and W illingn ess to Com ply W ith O rd er
n o r
<ai
tn r r &
(Name)
comply withffthe order as follows.
has [ ] does not have the present ability to
(Name)
to comply $ith the order as foilowH.
has f ] does not have the present willingness

WPF D R PSC U 05 0200 M andatory (10/2009) - R C W 26 09.160, 7.21 010
23834
2.8
6 /4 -^ 2 0 1 3
68042

Does not apply.
The attorney fees and costs awarded in paragraph 3.7 below have been incurred and are
reasonable.
[]
III. Order and Judgm ent
It is Ordered:
3.1
Contem pt Ruling
(Name) A
3.2
[ ] is ajjs not in contempt of court
Im prisonment
[]
Does not apply.

(Name) _____________________ ;_____________________ is to be confined in the (name of
county)______________________________________ County Jail.
[]
3.3
[]
Confinement shall commence immediately and shall continue until

(date)_________________________ or until the contempt is purged as set forth in
paragraph 3.6 below, in which case the contemnor shall be released immediately.
Confinement is suspended as follows.
[]
O ther
Additional Residential Time

Does not apply.
(Nam e)______
time as follows.
3.4
shall have additional residential
Judgm ent for Past Child Support

&
[]
Does not apply

No judgment for past child support was requested

WPF DR PSC U 05 0200 M andatory (10/2009) - R C W 26 09 160\ 7 21 010
[]
3.5
[]
[]
[]
Does not apply

(
No judgment for past medical support was requested.
(N am e)_____________________________________ shall have j udgment against
(nam e)_____________________________________ in the amount o f $ ______________
for unpaid medical support arrearages and $ ________________interest thereon for the
period from (date)_______________________ through (date)_____________________
Does not apply.

No judgm ent for past child care, educational expenses, transportation expenses, or other
special expenses was requested
(N am e)_____________________________________ shal 1have judgment against
(nam e)_____________________________________ in the amount of $ _______________
for unpaid child care, educational expenses, transportation expenses, or other special
expenses arrearages and $ ________________ interest thereon for the period from
(date)_______________________ through (date)________________________
Does not apply

No judgment for past maintenance was requested.
(N am e)_____________________________________ shall have judgment against
(nam e)_________________________________ in the amount of $ _______________ for
unpaid maintenance arrearages and $ ________________interest thereon for the period
from (date)_________________ through (date) ___________________
Conditions for Purging the Contem pt
[]
3.9
(N am e)______________________________________shall have judgment against

(nam e)_____________________________________ in the amount of $ ________________
for unpaid child support arrearages and $ ________________interest thereon for the period
- from (date)_______________________ through (date)________________________
Judgm ent for Past Maintenance
3.8
60843
Judgm ent for O ther Unpaid Obligations

&
[]
3.7
6^4^2813
Judgm ent for Past Medical Support

fl[]
[]
3.6
23834
Does not apply.

The contemn or may purge the contempt as follows'
Attorney Fees and-Costs

Does not apply.

WPF DRPSCU 05 0200 M andatory (10/2009) - R C W 26.09 1 6 0 ,7 21 010
23834
n
LJ
3.10
(Name)
______ __________________ : :---- shall have judgment against
(name)
tn
amount $ _________ ______ *or
attorney fees and $
___________- ôr costs
Does not apply.

The court shall review this matter on (date)
Other
T K l
0 { jJ J L
M k v f e c h & rn . 0*
Q rrA s D < ^
-K tu b
(H e "the C ftm M r irv

11121
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3.12
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Review Date
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Sum m ary of RCW 26.09.430 - .480, Regarding Relocation of a Child f t u f w t h * u > ri|
This is a summary only. For the full text, please see RCW 26.09 430 through 26.09.480
o J r t W - v if r t t n .
If the person with whom the child resides a majority of the time plans to move, that personshall. . , t
d u x u t n V t t w w t A j 'v
the intended move If the relocating person could not have known about the move in time to give , *
60 days notice, that person must give notice within 5 days after learning o f the move. The
notice must contain the information required in RCW 26 09 440. See also form DRJPSCU Q |v
*
CAjk
07.0500, (Notice o f Intended Relocation of A Child)
OJ/iAf^TTUUl .
d l< 7 C
rM J b r
H
may ask for modification under RCW 26.09.260
or is moving to avoid a clear, immediate and umeasonable risk to health and safety.
and safety o f a person or a child at risk.
Failure to give the required notice may be grounds for sanctions, including contempt
I f no o b je c tio n is file d w ith in 3 0 days a f t e r s ervice o f the n o tic e o f in te n d e d re lo c a tio n , th e
re lo c a tio n w ill be p e r m itte d a n d th e proposed revised re s id e n tia l s ch ed u le m a y be
c o n firm e d .
A person entitled to time with a child under a court order can file an objection to the child's

W PF DRPSCU 05.0200 M andatory (10/2009) - R C W 26 09 160, 7.21 010
23834
8 /4 /2 8 1 3
68845
An objection may be filed by using the mandatory pattern form WPF DRPSCU 07 0700,
objection, the relocating person shall not move the child before the hearing unless there is a
clear, immediate and unreasonable risk to the health or safely of a person or a child.
Warning: Violation of residential provisions of this order with actual knowledge of its terms is
punishable by contempt of court and may be a criminal off
(2) or
9A 40.070(2). Violation of this order may subject a violat
Dated
O
Presented by:
Approved for entry:

Notice of presentation waived:
Signature of Party ec-feawyerfWSBA No.
U s T J jj.
Signature of Party or L^wy<'er/WSBA No
Print or Type Name
Print or Type Name
'KfcthnVy,. P r
INCOUNTY.,
ERKS OFFICE
O rd on Show Cause re Cntm pt/Jdgm nt (ORCN) - Page 7 of 7

W PF D R PSC U 05.0200 M andatory (10/2009) - R C W 2 6 09.160, 7.21.010
e - f il e :
IN COUNTY CLEF
PIERCE COUNTY, W
June 06 201
KEVIN ST
COUNTY C
NO: 10-3-0
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COUNTY OF PIERCE
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n/k/a JENNIFER KAY LUND,
Petitioner,
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and
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MOTION FOR REVISION
Respondent.
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No. 10-3-00961-1
1. RELIEF REQUESTED
COMES NOW the Respondent JASON SHIPMAN by and through his attorney
DANIEL N. COOK of FAUBION, REEDER, FRALEY & COOK, P.S., and moves the
Court for revision of those provisions of COMMISSIONER MARY E. DICKEs Order on
Show Cause re Contempt entered on May 28, 2013, set forth below:
Page 2, Paragraph 2.1, which provides that Jennifer Shipman did comply with
the court order.
Page 2, Paragraph 2.3, which provides that The order was not violated.
Page 2, Paragraph 2.5, which provides that Jennifer Shipman has the present
willingness to comply with the order.
MOTION FOR REVISION - Page 1 of 6
Lund, Jennifer and Shipman, Jason
S:\CASES1\Shipm an, Jason\D R A FTS \P LE A D IN G S \2013\M otion fo rR e visio n .d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920-100th Street SW, Suite 25
Lakewood, WA 98499
253-581-0660
P a g e 3, P a ra g ra p h 2 .7 , w h ich p ro v id e s th a t J e n n ife r S h ip m a n h a s co m p lied and
is currently willing to comply with the parenting plan.

Page 4, Paragraph 2.8, which provides that Attorneys Fees and costs Does not
2
3
apply.
Page 4, Paragraph 3.1, which provides that Jennifer Shipman is not in contempt
4
5
of court.
Page 4, Paragraph 3.3, which provides that Additional Residential Time Does
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not apply
Page 5, Paragraph 3.8, which provides that Conditions for Purging Contempt
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9
Does not apply

Page 5, Paragraph 3.9, which provides that Attorney Fees and Costs Does not
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apply.
Page 6, Paragraph 3.11, which provides that: The Court orders that visit
exchanges will now take place on the corner in front of Jason Shipmans mothers home
at 11721 80th Avenue E., Puyallup.
Hunter at the street outside.
Mr. Shipmans mother, or step father will meet
Tyler Shipman will not be present at the home during
visitation exchange times. Justin Shipman can also meet Hunter outside.
2. STATEMENT OF FACTS
The facts are set forth in the submissions for the original hearing. In addition, a
verbatim transcript of the hearing on May 28, 2013, as prepared by Notary Public
Patricia Wood is filed in this case and submitted with this motion.
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23

S:\CASES1\Shipm an, Jason\D R AFTS\PLEAD IN G S\2013\M otion fo rR e visio n .d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
3. EVIDENCE RELIED ON
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The evidence relied on is set forth in the submissions for the original hearing. In
addition, a verbatim transcript of the hearing on May 28, 2013, as prepared by Notary
Public Patricia Wood is filed in this case and submitted with this motion..
4. AUTHORITY
The legal authority relied on for bringing this Motion for Revision is set forth in
RCW 2.24.050, PCLR 7(a)(11) and the Superior Court Civil Rules for the State of
Washington. This motion is timely filed within 10 days of entry of the order from which
the motion arises.
A revision before a judge of a court commissioners ruling is a matter of right. The
revision of the commissioners ruling is de novo on the record, requiring the judge to
review the entire case and determine its own facts, rather than to review a
commissioners order to determine its reasonableness. State v Ramer, 2004 WL
438964 (Wash., Mar 11, 2004); State v. Wicker, 105 Wn. App. 428, 433, 20 P.3d 1007
(2001); In re Marriage of Balcom, 101 Wn. App. 56, 1 P.3d 1174 (2000); In re Marriage
of Moody, 137 Wn.2d 979, 976 P.2d 1240 (1999).
De novo means afresh, anew and hearing de novo means trying matter
anew the same as if it had not been heard before and as if no decision had been
previously rendered. Blacks Law Dictionary, Sixth Ed., West Publishing Co., 1990.
The revision courts power of review is essentially unlimited. In re Dependency
of B.S.S., 56 Wn.App. 169, 171, 782 P.2d 1100 (1989); In re Welfare of McGee, 36
Wn.App. 660, 679 P.2d 933 (1984). The revision court has full jurisdiction over the
case and is authorized to determine its own facts based on the record before the
S:\CASES1\Shipm an, Jason\D R A FTS \P LE A D IN G S \2013\M otion forR e visio n .d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
commissioner. In re Marriage of Dodd, 2004 WL 503841 (Wash.App. Div. 3, Mar 16,

1
2004).
This traditional standard of review was called into question by a 2003 Division
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3
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6
Three decision applying the substantial evidence test to review a commissioners

findings of fact. State v. Lown, 116 Wn. App. 402, 407-08, 66 P.3d 660 (2003) The
Washington
Supreme
Court,
however,
has
subsequently
rejected
the
Lown
interpretation:
On revision, the superior court reviews both the commissioners
findings of fact and conclusions of law de novo based upon the
evidence and issues presented to the commissioner. [FN9]
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8
FN9. Any language to the contrary in State v. Lown, 116 Wn.App.

402, 66 P.3d 660 (2003), is disapproved.
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State v Ramer, 2004 WL 438964 (Wn. Sup. Ct., Mar 11, 2004). Thus, the Washington
11
Supreme Court has ended any dispute about the standard of reviewit is de novo.
12
De novo review also applies to findings based on oral testimony, as well as those
13
based on written testimony. See State v. Charlie, 62 Wn. App. 729, 730, 815 P.2d 819
14
(1991) (oral testimony taken; holding superior court erred by limiting review of findings
15
of fact); In re Welfare of Smith, 8 Wn. App. 285, 286, 505 P.2d 1295 (1973) (same);
16
State ex ref Biddingerv. Griffiths, 137 Wash. 448, 242 P.2 969 (1926) (same).
17
Finally, this court should apply the
de n o vo
standard of review because the
18
commissioner made no actual findings of fact, instead skipping to the legal
19
conclusion that the parenting plan should be modified without any legal basis to
20
do so.
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motion for clarification before the court, and even if there were there is no ambiguity to
There is no open Petition for Modification of the Parenting Plan. There is no
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23

S:\CASES1\Shipm an, Jason\D R A FTS \P LE A D IN G S \2013\M otion fo r Revision.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
be resolved.
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The Commissioners order specifically changed the rights and
responsibilities of the parties as it relates to the parenting plan and as such was a
modification of the parenting plan, without meeting the statutory requirements for
modification of the parenting plan.
RCW 26.09.260 sets for very detailed and specific requirements for modification
of parenting plans, including a finding that there has been a substantial change in
circumstance since entry of the last parenting plan.
The changes made to this
parenting plan generally relate to the transportation arrangements, which is a nonresidential aspect of the parenting plan and RCW 26.09.260(10) specifically requires a
substantial change in circumstances and a finding that the change is in the best interest
of the child before a change can be made. No findings related to a substantial change
or the best interest of the child were made. Furthermore, because there was no open
Petition to Modify the moving party in the contempt action did not have a full and fair
opportunity to prepare and defend a parenting plan modification action.
RCW
26.09.270 sets forth a threshold requirement that a finding of adequate cause be made
before any modification of a parenting plan may be granted and requires affidavits and
notice of the request for a change.
None of the procedures or requirements were
followed and none of the requisite findings to support a modification were made.
Indeed, there is not even an open Petition for Modification. For all of these reasons the
modification of the parenting plan was improper.
The Commissioner declined to make a finding of contempt and instead
improperly changed the exchange requirements of the parenting plan.
There is no
findings made by the Commissioner to explain why the Mothers failure to follow the
S:\CASES1\Shipm an, Jason\D R A FTS \P LE A D IN G S \2013\M otion fo r Revision.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
parenting plan was not contempt. The court simply indicates that it was not contempt
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without explanation or specific findings to support that statement. The Commissioner

should be revised and the court should make a finding of contempt against Jennifer
Shipman and not make any changes to the final parenting plan.
5. SUMMARY
The Commissioner should be revised and the court should make a finding of
contempt against Jennifer Shipman and should eliminate any changes to the final
parenting plan.
6. PROPOSED ORDER.
A Proposed Order will be provided.
DATED this
day of June 2013.

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By: Daniel N. Cook, WSBA 34866

Of: Attorneys for Respondent
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S:\CASES1\Shipm an, Jason\D R A FTS \P LE A D IN G S \2013\M otion fo r R evision.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
5920100th Street SW, Suite 25
Lakew ood, W A 98499
2 5 3 -5 8 1 -0 6 6 0
E-FILED
June 06 2013 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
T r a n s c r ip t o f P r o c e e d in g s
R e:
S h ip m a n v . S h ip m a n
P age 1 o f 25
RmlOO Tuesday, May 28, 2013 10:21:06 AM 11:26
COMMISSIONER:
. . . swear or affirm to tell the truth and nothing but the truth?
FEMALE:
Yes.
MALE:
Thank you.
COMMISSIONER:
(Unintelligible) identify themselves.
PRICE:
Kathrine Price, Your Honor, on behalf o f . . . Ms. Shipman whose name, if

you could tell the court youve changed.
7
8
LUND:
Jennifer Lund.
PRICE:
Is Ms., Ms. Lund now but Shipman per the court record.
10
SHIPMAN:
And Jason William Shipman.
11
COMMISSIONER:
Okay, so . . . Im not sure I received your response (unintelligible).
12
PRICE:
Yes, Your Honor, if I could address that as a preliminary . . .
13
COMMISSIONER:
(Unintelligible).
14
PRICE:
.. . issue, um, Ms. Shipman contacted me in plenty of time, this was
15
completely my error that it didnt get to the court, um, I realized my mistake
16
yesterday and ran out there and had her sign it and it has been filed. I left a
17
copy for Mr. Shipman, um, on his doorstep, it looks like he did receive it, I
18
also emailed it to him, so I am begging the Courts forgiveness and asking
19
the Court if I can, um, give a . . .
20
COMMISSIONER:
Well let me (unintelligible) . . .
21
PRICE:
. .. bench copy now.
22
COMMISSIONER:
. . . (unintelligible).
T r a n s c r i p t o f P r o c e e d in g s
R e:
P age 2 o f 25
SHIPMAN:
Its, its repetitive from what she already said, I have no problem with it.
COMMISSIONER:
So you have no problem going forward?
SHIPMAN:
Nope.
COMMISSIONER:
Okay.
SHIPMAN:
Not at all.
COMMISSIONER:
All right.
PRICE:
Okay.
COMMISSIONER:
Thank you, so Mr. Shipman just indicate what youre here for
(unintelligible) here for?
9
10
SHIPMAN:
Um .. . weve had issues with the drop off location for my son .. . shes
11
been to Court several times to try to change i t . . . its the best place, um, this
12
last summer . . . my son was supposed to go see my father . . . um, she
13
(unintelligible). . . this is one of the times she tried to change i t . .. she, ah,
14
waited till the last minute went into . . .
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PRICE:
Your Honor.
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SHIPMAN:
. . . ex parte . . .
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PRICE:
I dont remember any of this from the declaration.
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COMMISSIONER:
It has (unintelligible). . .
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SHIPMAN:
Its in there.
20
COMMISSIONER:
Youre limited so . . .
21
(Unintelligible)
22
COMMISSIONER:
. . . or I guess refer to me where exactly (unintelligible).
Transcript of Proceedings
Re: Shipman v. Shipman
Page 3 of 25
SHIPMAN:
Ah, I believe it was in my first statement. . . wed gone to Court, its, she
complained about me missing Pierce County on one of the forms.
2
3
COMMISSIONER:
Yeah, th at. . .
SHIPMAN:
Then I talked about her filing . .. Court like three times I can, came here
with King County documents so Im not sure why . . . me missing one lines
a huge issue b u t. . . in that same statement I discussed that.
COMMISSIONER:
Well (unintelligible) all I can say is you need to . . . stay in the, the confines
of what you (unintelligible).
8
SHIPMAN:
I was just trying to show that weve gone over this issue numerous times . . .
10
COMMISSIONER:
So . . .
11
SHIPMAN:
. . . in Court.
12
COMMISSIONER:
. . . what are you alleging to be the contempt?
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SHIPMAN:
Shes not showing up at the designated, ah . . . drop off location, shes tried
14
to change it numerous times .. . weve gone to Court a couple of other
15
judges have heard her argument and said, no, this is the location, this is
16
where its going to be, um, I have bent over backwards to try to
17
accommodate her so a few times I did agree to meet here there then she
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wanted me to meet her in a parking lot, um, she provided some emails here
19
where shes chopped out parts of the conversation that include me sitting in
20
a parking lot for hours on end waiting for her when she is supposedly just a
21
few minutes down the street, ah, in the meantime these are school nights, at
22
least at my parents home, which is a very safe place for everyone, ah,
Page 4 of 25
Hunter can, you know, thats where we agreed, um, she alleges that there is a
police report indication where theres some unsafety, that is an argument that
she had with our oldest son, whose now eighteen, she showed up there not
for a visitation exchange cause my parents have, because of the issues with
her and her animosity towards anyone and everyone that talks to me
instantly becomes no longer her friend . . . um, my parents have a simple
rule, during the time that Jennifer drops . . . Hunter off, nobody is to be
outside, everybody comes in, they sit in there and they wait for her . . . I
dont, I try not to be there until hes there, I have . .. changed my residence
10
location numerous times to try to accommodate seeing my kids and every
11
time I move, she does something . ..
12
PRICE:
And, Your Honor, the . . .
13
SHIPMAN:
more .. .
14
PRICE:
. . . change of location I, I dont remember . . .
15
SHIPMAN:
Shes ju s t. . .
16
PRICE:
. . . (unintelligible). . .
17
SHIPMAN:
. . . violating the parenting . . .
18
PRICE:
. . . documents (unintelligible).
19
COMMISSIONER:
(Unintelligible). . .
20
SHIPMAN:
. . . plan, shes not showing up.
21
COMMISSIONER:
. .. (unintelligible) let me hear in regards to (unintelligible) response.
22
PRICE:
U m .. .
Re: Shioman v. Shipman
Page 5 of 25
COMMISSIONER:
And, un, understanding I havent read it so I (unintelligible).
PRICE:
Thank you, Your Honor and much of what, ah, is in . . . Ms. Lunds
Declaration is actually included in the attachments where shes documented
her visitation and I dont know if your Court, if the Court remembers seeing
these, there are . . . new ones from May that werent included in her previous
Declaration.
SHIPMAN:
time . .. you can see where she just wrote it o u t.. . and its very inaccurate.
8
9
And I have an objection to that documentation, it was clearly written at one
COMMISSIONER:
10
I mean . . . thats why I asked (unintelligible) if you wanted to, um . ..

continue this . ..
11
SHIPMAN:
I do.
12
COMMISSIONER:
. . . if you . . .
13
SHIPMAN:
hi...
14
COMMISSIONER:
. .. because you have the right to respond, um . . .
15
SHIPMAN:
And I did.
16
COMMISSIONER:
. . . to this reply.
17
PRICE:
Well, Your, Your Honor, I believe what hes objecting to is . . .
18
COMMISSIONER:
Well I . ..
19
PRICE:
. . . um, items that she filed previously . . . um, months . . .
20
SHIPMAN:
Yeah, its . . .
21
PRICE:
. . . um, over a month ago.
22
SHIPMAN:
Its inaccurate.
Re:
P age 6 of 25
COMMISSIONER:
Well thats your opinion, you certainly can make that argument. ..
SHIPMAN:
Okay.
COMMISSIONER:
. . . if you want to continuance to respond to the newly filed material.
SHIPMAN:
I have no issue with any of it.
COMMISSIONER:
Okay, go ahead.
PRICE:
Okay.
COMMISSIONER:
(Unintelligible) go ahead Ms. Price.
PRICE:
Thank you, Your Honor . . . um . . . Ms. Lund documented days when she
arrived at the Edwards home, thats where in mediation, um, Ms. Lund and
Mr., ah, Shipman, agreed verbally.
10
11
SHIPMAN:
(Unintelligible)
12
PRICE:
T hat. . .
13
COMMISSIONER:
Just let her . . .
14
SHIPMAN:
Im sorry.
15
COMMISSIONER:
.. . finish.
16
PRICE:
And, and this is documented in a declaration that was filed some time ago,
17
um, by Mrs. Edwards . . . that there was a phone call from the mediation in
18
December, um, Ms. Lund asked could we use your home as a place where
19
we could do visitation exchanges . . . Mrs. Edwards said, yes, thats okay,
20
um, and has and indicated in her declaration that thats been taking place
21
regularly, now Ms. Lund agrees that its not always been at the Edwards,
22
that theres been other times when theyve agreed to other places and theres
Page 7 of 25
text mes, messages that indicate that theres been an agreement to other
places and thats not a violation of the parenting plan because it clearly
states, unless otherwise agreed by the parties, um, but at that mediation, the
parties did agree that the regular . . . exchange location would be at the
Edwards.
COMMISSIONER:
So do we have that reduced to writing . . . as part of the mediation

(unintelligible). . .
7
8
PRICE:
No.
COMMISSIONER:
. .. (unintelligible).
10
PRICE:
No, Your Honor, according to the declaration that was just filed, um . . .
11
COMMISSIONER:
Okay, so . . .
12
PRICE:
. . . Ms. Lund wrote . .. that was not put in writing because Mr. Shipman
13
absolutely refused to put that in writing, although he did agree to it and
14
h a s.. .
15
(Unintelligible)
16
PRICE:
.. . been conforming to i t . . . up until April, there were only a few times
17
when the exchange didnt take place at the Edwards. And Mr. Shipmans
18
argument is that theres no other place thats safe for Hunter and that he has
19
to sit in a parking lot but hes able to sit in the Edwards home . . . um . . .
20
this is a, a mutual family friend . . . ah, a place where Ms. Lund feels safe,
21
um, and . . . I know that the Court hasnt had an opportunity to read the
22
declaration but, um, this . . . worked until April when there was a
R e:
P age 8 o f 25
disagreement about. . . visitation during spring break, Ms. Lund gave into
what Mr. Shipman wanted for spring break, he wanted, um . . . the first
weekend was originally his weekend . . . he didnt want to include that in
Spring Break, he wanted Spring Break just to be Monday through Friday . ..
she did, that wasnt her understanding from their past practices, in the past
theyd had visitations from the first weekend through the middle of Spring
Break and then . . . the other half of Spring Break included the . . . last
weekend, um . . . but when she realized that that was not his understanding
she said, oh, well hes at a friends house . . . Mr. Shipmans wife went and
10
retrieved . . . um . . . Hunter from the friends house and took him over night
11
but thats where . . . a disagreement st, started . . .
12
COMMISSIONER:
Okay.
13
PRICE:
. . . . and since . . .
14
COMMISSIONER:
(Unintelligible).
15
PRICE:
. . . then . . .
16
COMMISSIONER:
I mean although this is for contempt. . . I mean the, main, main goal is to
17
have this worked out for the future .. . Mr. Edwards didnt, I mean Mr. . . .
18
Shipman denies that, um, that the Edwards was a location that was agreed
19
upon even though apparently hes said . . . he on occasion has agreed to it.
20
PRICE:
W hen.. .
21
COMMISSIONER:
So what is gonna be . . . the location going forward?
Page 9 of 25
PRICE:
Well, Your Honor, Ms. Lund simply doesnt feel safe . . . at this home, you
saw from the Declaration, um, from Debra, what was the last name?
2
3
LUND:
Bergman (spelling?).
PRICE:
Bergman about the challenges that she encountered when she tried to serve
Mr. Shipman .. . there and the family was relatively hostile to her . . . um . . .
theres been past hostilities, not necessarily . . . by Mr. Shipmans mother
but other family members who are there, um, and its just not healthy for
Hunter to continuously see that animosity . . . um, she . . . prefers, um, the
Edwards home because theres not that animosity and he is safe there if one
10
parent wants to drop him off and leave . .. and have the other parent come
11
and pick him up, theres no problem with that.
12
SHIPMAN:
Weve argued this in Court several times . . . she cannot prove any of the
things shes . . . the incident shes discussing . . . she w ent. . .
13
14
COMMISSIONER:
15
SHIPMAN:
Mr. . . .
. .. there on her own, made an arrangement to meet my son, who shes been
in Court with . . . with police involvement, they . . .
16
17
COMMISSIONER:
(Unintelligible) . . .
18
SHIPMAN:
. . . have an issue . ..
19
COMMISSIONER:
.. . obviously there are possibilities . . .
20
SHIPMAN:
My . . .
21
COMMISSIONER:
. . . so what plan is gonna work best going forward?
R e:
P a g e 10 o f 2 5
SHIPMAN:
I just moved . . . to be close to this drop off location . . . the last time I
moved to be close to my children, she moved and switched their schools,
she, everything shes done . . . has been very vindictive . . . Ive sent her an
email saying . . . on April 1st, Ive provided it to you, that I did not agree to
go to the Edwards, I no longer want to go to the Edwards, weve argued this
in Court numerous . ..
COMMISSIONER:
So where . . .
SHIPMAN:
. . . times.
COMMISSIONER:
. . . are you saying.
SHIPMAN:
My parents home is absolutely a safe place for her . . . nobody goes out
10
there, she doesnt . . .
11
12
COMMISSIONER:
How far . ..
13
SHIPMAN:
. . . need to go in.
14
COMMISSIONER:
. . . is your parents from the Edwards?
15
SHIPMAN:
The Edwards, the other issue with the Edwards home is its not only is it not
16
a mutual place, this is a friend of hers, thats very hostile towards me, but
17
they are very . . . they have a huge family with a ton of kids . .. and they
18
arent home, the police have said . . . numerous times, you need a third
19
party . ..
20
PRICE:
Your Honor.
21
SHIPMAN:
. . . exchange.
22
PRICE:
I have no documents . . .
R e:
S h i p m a n v . S h ip m a n
P a g e 11 o f 2 5
SHIPMAN:
This is not a .. .
PRICE:
SHIPMAN:
.. . third .. .
COMMISSIONER:
Im just trying to figure this out, Im not (unintelligible) Im trying to figure

this out for the future of (unintelligible) to have . ..
5
6
SHIPMAN:
Theres a . . .
COMMISSIONER:
.. . (unintelligible) Mr. Shipmans mother . . . go pick Hunter up at some
neutral location . . . um, to keep, Hunter shouldnt be in the middle of all
this.
10
SHIPMAN:
Exactly.
11
(Unintelligible)
12
COMMISSIONER:
So . . . Im inclined to have, as I say . . .
13
SHIPMAN:
I dont know that my mother . . . is . . . going to be able to do that, I

would
14
15
COMMISSIONER:
Okay.
16
SHIPMAN:
. . . love to have my mother come in and discuss that. . . if you look in those
police reports, she has offered her home up, her home is absolutely safe.
17
18
COMMISSIONER:
Okay.
19
SHIPMAN:
But thats .. .
20
COMMISSIONER:
Well why dont you (unintelligible) go to McDonalds . . . um . ..
21
SHIPMAN:
Because she doesnt show up, its . ..
22
COMMISSIONER:
(Unintelligible).
Page 12 of 25
SHIPMAN:
.. . hours and hours on end of waiting . , .
COMMISSIONER:
Ju st. ..
SHIPMAN:
. . . for her.
COMMISSIONER:
Okay, how about your mother goes to . . .
SHIPMAN:
And the . . .
COMMISSIONER:
.. . (unintelligible).. .
SHIPMAN:
. . . last time we . . .
COMMISSIONER:
. .. McDonalds .. .
SHIPMAN:
.. . had a . . . .
10
COMMISSIONER:
. . . where she can get a little . . . little slip, um . . .
11
SHIPMAN:
I cant speak . . .
12
COMMISSIONER:
13
SHIPMAN:
. . . for my mom, I dont know that shes . . . available to do that every .. .
14
COMMISSIONER:
Okay, lets take a recess (unintelligible) go call your mother.
15
PRICE:
And just for the . . .
16
SHIPMAN:
Ah, shes a t . . .
17
PRICE:
. . . record, Your Honor . . .
18
SHIPMAN:
. . . school.
19
PRICE:
. . . Ms. Lund has no objection . . . to Mr. Shipmans mother picking up

Hunter, its her home that she has a problem with.
20
21
COMMISSIONER:
(Unintelligible) go check with your mother.
22
SHIPMAN:
Shes a (unintelligible).
Page 13 of 25
COMMISSIONER:
Go check with your mother.
(Unintelligible)
ENDS 10:32:32
Rm_100 Tuesday, May 28,2013 10:58:34 AM 05:02
FEMALE:
(Unintelligible)
FEMALE:
(Unintelligible)
SHIPMAN:
Court is now reconvened.
Okay, now were back.
Yes, I got a hold of her, um . . . and shes always been willing to help any
10
way she can, she has suggested possibly Hunter being dropped off on the
11
comer by her home, so he can just walk across the street . . . I have her
12
number if youd like to contact her and talk with her.
13
COMMISSIONER:
How old is Hunter?
14
FEMALE:
Twelve.
15
FEMALE:
Twelve.
16
SHIPMAN:
He just turned twelve over the weekend.
17
COMMISSIONER:
(Unintelligible)
18
PRICE:
Do you have an objection to, the concern I guess that we would have is what
if for some unknown reason there wasnt anybody home?
19
20
SHIPMAN:
Hunter has a key to the home, I have two brothers and sisters that live there
21
. .. my father is a City, ah, employee, hes home, theres a, thats the reason
22
we choose my mothers, if my moms busy, my dad will be home, if theyre

Page 14 of 25
both busy, they make sure Sierra or Justin, theres always somebody there
for Hunter and he knows how to get into the home . . . in addition, I just
moved a block and a half away . . . its, its . . . this, weve argued this in
Court so many times already.
COMMISSIONER:
(Unintelligible) in response . . . Im just trying to figure out something thats
going to work for Hunter cause this is, you know, obviously the parties are
in conflict, he doesnt need to be involved in this conflict.. . um . . .
SHIPMAN:
And thats why I agreed to try Greg and Amys . . . and tried the parking lot,
Ive tried .. . everything I can to get along and, and Ive .. .
9
10
COMMISSIONER:
(Unintelligible)
11
SHIPMAN:
. . . Ive offered counseling . . .
12
COMMISSIONER:
What is your response?
13
PRICE:
Um, Your Honor, Ms. Lunds concern would be, um, if no ones allowed to
14
come outside, how could she be sure when shes dropping him off that there
15
is someone there . . . to care for him, shes not entirely comfortable with him
16
just going up to an empty house with a key . . . um, but if somebody . . .
17
SHIPMAN:
(Unintelligible) he . ..
18
PRICE:
. . . could perhaps . . .
19
SHIPMAN:
.. . comes (unintelligible).
20
PRICE:
. . . meet him at the comer.
21
COMMISSIONER:
And why doesnt . . .
22
SHIPMAN:
He comes . . .
R e:
P a g e 15 o f 2 5
COMMISSIONER:
SHIPMAN:
. . . home every day to a . . .
COMMISSIONER:
Okay, how about. . .
SHIPMAN:
. . . empty house with a house with a key, I will make sure he has a key to
the house.
5
6
COMMISSIONER:
Well how about your mom comes out and just meets them . . .
(unintelligible).
7
8
SHIPMAN:
Thats fine.
COMMISSIONER:
At the comer.
10
SHIPMAN:
Absolutely.
11
PRICE:
And what comer is that?
12
COMMISSIONER:
Okay, just tell us what corner?
13
SHIPMAN:
Theres only one comer, the road that comes up from . . .
14
PRICE:
112th and. . .
15
SHIPMAN:
. . . moms house.
16
PRICE:
.. . 80th?
17
SHIPMAN:
No, ah, 80th Avenue and . ..
18
PRICE:
Im n o t.. .
19
SHIPMAN:
20
FEMALE:
Whats your concern?
21
SHIPMAN:
And again, you can call my mom and discuss it with her if youd . . .
22
COMMISSIONER:
I cant . . .
. . . 116th, I want to say, its right outside of her home . . . across the street.
Re:
P a g e 16 o f 2 5
SHIPMAN:
. . . like.
COMMISSIONER:
.. . call your mom.
SHIPMAN:
Oh, Im sorry.
COMMISSIONER:
Well Im gonna order that, I mean . . . we got to work this out and
everyones in agreement with . . . having him be picked up at the corner by,
you know, Mr. Shipmans mother .. . um, at age twelve is okay.
SHIPMAN:
And if my moms unavailable . . .
COMMISSIONER:
(Unintelligible).
SHIPMAN:
. .. my father or my brother or sister, whomevers . . . it will typically be my
10
mom but shes a special ed. teacher . . . um, she deals with kids with autism
11
. . . and a lot of times, shell have conferences on Wednesdays and
12
Wednesdays . . . is when I . . . I have Wednesday evening visits also . . . so if
13
my father, if my moms not available, my father or brother or somebody will
14
be there to meet.
15
PRICE:
And Your Honor, Ms. Lund has, um, one last concern . . . um, that I believe
16
we could deal with, um . . . her son, Tyler, has been aggressive in the past
17
and is often at the grandmas house . .. um, hes filed a declaration saying he
18
doesnt live there, if Tyler could not be there at the regular pick up and drop
19
off times then that could hopefully avoid the, he did hit her car, came out
20
angry and . ..
21
LUND:
And th at. . .
22
PRICE:
. . . was . . .
R e:
P a g e 17 o f 2 5
LUND:
. .. was at the . . .
PRICE:
. .. hitting her car.
LUND:
. .. corner.
PRICE:
At the . . .
LUND:
(Unintelligible) house.
PRICE:
.. . comer . ..
SHIPMAN:
She alleged.
PRICE:
. .. previously.
COMMISSIONER:
Okay regardless . . .
10
PRICE:
So . . .
11
COMMISSIONER:
. . . Tyler n o t. . .
12
SHIPMAN:
Tyler. . .
13
COMMISSIONER:
. . . be there.
14
SHIPMAN:
. .. wont be there.
15
PRICE:
Okay.
16
SHIPMAN:
Or he wont come out so if hes, if hes (unintelligible) is there, hell stay in
17
the house, Tyler wont be there, Ill just make sure hes not there. Thats no
18
problem. Hes . . .
19
PRICE:
Okay.
20
SHIPMAN:
. . . moved out and hes got his own job and stuff now.
21
COMMISSIONER:
Okay, so Tyler . . .
22
SHIPMAN:
Hes not there . . .
Page 18 of 25
COMMISSIONER:
. .. wont (unintelligible).
SHIPMAN:
.. . anyway.
PRICE:
Okay.
COMMISSIONER:
Lets just have an Order . . . Im not finding contempt but I am modifying

the transfer to . . . incorporate these agreements including Tyler not be there.
5
6
PRICE:
Okay.
SHIPMAN:
And then also, um . . . would it be possible to get makeup time for all of the
days that I missed?
8
9
COMMISSIONER:
No, I just want to, basically try to change this so it works .. . well in the
future.
10
11
SHIPMAN:
Okay and . . . if theres issues with her not showing up and . .. and . . .
12
COMMISSIONER:
(Unintelligible).. .
13
SHIPMAN:
. . . ah, me n o t. . .
14
COMMISSIONER:
15
SHIPMAN:
. . . seeing my kid again then what do I do?
16
COMMISSIONER:
Bring another contempt.
17
SHIPMAN:
Just do it again?
18
COMMISSIONER:
Yeah.
19
(Unintelligible)
20
SHIPMAN:
Okay.
21
UNKNOWN:
Can you add me to the lis t. . . as well?
22
SHIPMAN:
Oh, my . . .
R e:
S h i p m a n v . S h ip m a n
P a g e 19 o f 25
UNKNOWN:
(Unintelligible). . .
SHIPMAN:
. .. wife.
UNKNOWN:
. . . is coming . . .
COMMISSIONER:
(Unintelligible).
UNKNOWN:
.. . (unintelligible).
COMMISSIONER:
(Unintelligible) talk where she cant be . . . part of the hearing so . . .

(unintelligible) with her?
7
8
SHIPMAN:
Is i t . . . is it okay if my mom or my father are unavailable my wife stand at

the comer and . . .
9
10
COMMISSIONER:
No.
11
SHIPMAN:
12
(Unintelligible)
13
COMMISSIONER:
No.
14
SHIPMAN:
Okay. All right.
15
(Unintelligible)
16
ENDS 11:03:36 AM
17
Rm lOO Tuesday, May 28, 2013 11:16:42 AM 04:38
18
(Unintelligible)
19
UNKNOWN:
20
(Unintelligible)
21
PRICE:
(Unintelligible) Shipman matter (unintelligible) record .. . visitation.
Did you want to look at it while you argue it?
Page 20 of 25
SHIPMAN:
No, I agree with everything other than just adding my brother and sisters to
be able to one of the ones.
PRICE:
Okay.
(Unintelligible)
COMMISSIONER:
Court is reconvened (unintelligible) back on the record so . . .
SHIPMAN:
I just wanted to, a h ,. . . .
COMMISSIONER:
State your name again for the . . .
SHIPMAN:
Oh.
COMMISSIONER:
. . . record.
10
SHIPMAN:
Jason William Shipman.
11
COMMISSIONER:
Okay.
12
SHIPMAN:
Just wanted to try to hinder a possible future problem . . . ah, this home is
13
right next to Rogers High School. . . my brother is a history teacher at
14
Rogers and my mother is a teacher out at Kapowsin and my brother has a
15
house out in Graham, my parents and him are talking and considering living
16
in the other ones house for a little while to, during the winter . . . so their
17
closer for the school stuff and switching back, so I simply wanted to add my
18
brother, Justin, sister, Stacy, or sister, Sierra, who will be living in that home
19
. . . to be able to be the ones to be able to stand on the comer if my parents
20
are not there.
R e:
P a g e 21 o f 2 5
COMMISSIONER:
Well let me just ask (unintelligible) potentially consider it only on the
condition, they actually have physically . . . changed residences, I mean I
wouldnt want to . . .
SHIPMAN:
Okay.
COMMISSIONER:
. .. do i t . . .
SHIPMAN:
Thats fine.
COMMISSIONER:
.. .just add anybody and anyone to be doing this, ah, (unintelligible) let me
just hear the response.
8
9
10
SHIPMAN:
Just family members that live in the home, yes.
COMMISSIONER:
No, Im saying, youre indicating that they may switch residences . . . thats
11
a whole different story, they physically move o u t. . . and live in the other
12
persons house . . . and th at. . . (unintelligible) gonna happen,
13
(unintelligible). . .
14
SHIPMAN:
Theyre gonna . . .
15
COMMISSIONER:
16
SHIPMAN:
. . . try it this summer .. . its, ah, theyre going to do it this summer and try
17
it and see how it works . . . my parents home is like an open house, my
18
family members and .. .
19
COMMISSIONER:
(Unintelligible).. .
20
SHIPMAN:
. . . brothers are . . .
21
COMMISSIONER:
. . . (unintelligible). . .
22
SHIPMAN:
. . . always there.
Page 22 of 25
COMMISSIONER:
. . . response.
PRICE:
Your Honor, um, to simplify matters, Ms. Lund . . . thought that the brother
that was being addressed was a different brother, she has no issue with, um,
Justin, is it Justin . . .
SHIPMAN:
Correct.
PRICE:
.. . Shipman .. . being included as one of the people who can, whether or
not he lives there, as one of the people who can meet him at the comer,
thats fine.
COMMISSIONER:
Okay.
10
SHIPMAN:
One of them (unintelligible).
11
COMMISSIONER:
(Unintelligible).
12
(Unintelligible)
13
PRICE:
All right (unintelligible).
14
SHIPMAN:
Yeah.
15
PRICE:
All right, initial. . . (unintelligible) initial.
16
(Unintelligible)
17
PRICE:
Youre gonna sign as the party, so youre not the lawyer, youre just
(unintelligible).
18
19
(Unintelligible)
20
PRICE:
And then . . .
21
SHIPMAN:
(Unintelligible).
22
PRICE:
. . . print your name, um-huh.
Page 23 of 25
(Unintelligible)
SHIPMAN:
Thank you, Your Honor.
COMMISSIONER:
(Unintelligible).
SHIPMAN:
Ah, its . .. just (unintelligible) to chase him around and getting to see him,
its gonna be great.
5
6
(Unintelligible)
COMMISSIONER:
(Unintelligible) everyone.
PRICE:
Thank you, Your Honor.
(Unintelligible)
10
PRICE:
Ah, thank you (unintelligible) quick.
11
(Unintelligible)
12
UNKNOWN:
13
(Unintelligible)
14
ENDS 11:21:20
15
*****e n d
Were at recess.
o f p r o c e e d i n g s ****
16
Page 24 of 25
1
2
3
4
5
6
7
CERTIFICATIO N OF TRANSCRIPTION
State of Washington
County of Pierce
I, Patricia Wood, declare under the penalty of perjury under the laws of the State of
8
9
)
) ss.
)
Washington that the following is true and correct to the best of my knowledge and belief.
10
11
I certify that I am over eighteen years of age and not a party to this action.
12
I prepared the foregoing transcript from a CD of a proceeding that took place on May 28, 2013
13
regarding the above captioned matter and consists of the twenty-four (24) pages.
14
Dated at Tacoma, Washington on this
15
16
17
18
19
20
21
^ .M O O D
' \ . f rAT O*
R e:
P age 25 o f 25
day of June, 2013.
Vatricia Wood, Notary Public

In and for the State of Washington
Residing at Pierce County, Washington
E-FILED
June 06 2013 8:30 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)
Name: Kathrine Price

Address: 622 TACOMA AVE S STE 1 TACOMA, WA 9802
Phone: (253) 292-9767

Motion - Revision
Calendar: FAMILY COURT - 2
CALENDAR DATE: Friday, June 28, 2013
9:00 AM
W O RKING COPIES SHALL BE DELIVERED TO THE COURT PURSUANT TO PCLR 7 (a) (7)
Submitted by:
DATED:
June 5, 2013.
Signed:
/s/ Daniel N Cook
NAME:
Daniel N Cook
Phone:
(253) 581-0660
W SBA#:
34866
For:
1 of 1
24218
7^1^2813
448205
III
10-3-00961-1
40706996
ORFR
06-28-13
2
3
4
5
6
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8
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COUNTY OF PIERCE
10
11
12

No. 10-3-00961-1
Petitioner,
13
A gnsez)
ORDER MOTION FOR REVISION
and
14
15
16
17
18

_________________________ Respondent.
This matter having come before the court on Respondents Motion for Revision,
the court having reviewed the records and court files herein and otherwise deeming
itself fully advised, it is hereby ORDERED:
19
[
The motion for revision is DENIED.
3/
20
21
22
23
24
25
^4. The motion for revision is GRANTED IT IS THEREFORE ORDERED:
______ (h
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Order on Motion for Revision - Page 1 of 2

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FAUBION, REEDER,
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Lakewood, WA 98499
253-581-0660
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Dated:
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Judge Brian Tollefson
FILED ^
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IN OPEN C 0 U R l\
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JUN 2 8 2013
Presented by:
FAUBION, REEDER, FRALEY & COOK,
Approved by:
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K^fthrine Price^W SBA #44389

Daniel N. Cook, W SBA #34866

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Order on Motion for Revision - Page 2 of 2

$ \CASES1 \Shipman, Jason\DRAFTS\PLEADiNGS\2013\Order on M otion fo r Revision docx
FAUBION, REEDER,
FRALEY & COOK, P.S.

Lakewood, WA 98499
253-581-0660
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10-3-00961-1
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Cause Number
10-3-00961-1
Petitioner(s)
vs
Page 1 of 2
FILED
DEPT. 8
IN OPEN CO U R T
Respondent(s)
Judge/Commissioner BRIAN TOLLEFSt
Court Reporter TIMOTHY REGIS
Judicial Assistant/Clerk Brian Matson
JUN 2 8
DEPUTY,
Kathrme Price
Attorney for i
Daniel N Cook
Attorney for R espondent
SHIPMAN, TYLER
SHIPMAN, HUNTER
Proceeding Set Motion - Revision

Proceeding Outcome Motion Held
Resolution
Outcome Date 06/28/2013 10 32

Amended Resolution code.
Report run date/tim e 06/28/13 10 33 AM

Ixc a lc tv il p b t d _ c m ljo u m a l_ r e p o r t_ c o v e r
2013
IN
T H E
S U P E R IO R
C O U R T , P IE R C E
C O U N T Y , W A S H IN G T O N

MEMORANDUM OF
JOURNAL ENTRY
vs
Page 2 of 2
Judge/Commissioner
BRIAN TOLLEFSON
________________________________ MINUTES OF PROCEEDING________________

Judicial Assistant/Clerk Brian Matson
Court Reporter TIMOTHY REGIS
June 28, 2013 10.32 AM Agreed order presented and signed

Order taken by Mr. Cook for copies.
JUDGE/COMMISSIONER BRIAN TOLLEFSON Year 2013
E-FILED
July 03 2013 3:07 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)

Name: Kathrine Price
Address: 622 TACOMA AVE S STE 1 TACOMA, WA 9802
Phone: (253) 292-9767

Motion
Nature of Hearing: Other TO CORRECT SCRIVENERS ERROR
Calendar: FAMILY COURT - 2
CALENDAR DATE: Friday, July 12, 2013
9:00 AM
WORKING COPIES SHALL BE DELIVERED TO THE COURT PURSUANT TO PCLR 7 (a) (7)
Submitted by:
DATED:
July 3, 2013.
Signed:
/s/ Daniel N Cook
NAME:
Daniel N Cook
Phone:
(253) 581-0660
WSBA#:
For:
34866
1 of 1
E-FILED
IN COUNTY CLERK'S OFFIC
PIERCE COUNTY, WASHING'
July 03 2013 3:07 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
5
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7
S U P E R IO R C O U R T O F W A S H IN G T O N
C O U N T Y O F P IE R C E
10
11
In re the M arriage of:

N o . 1 0 -3 -0 0 9 6 1 -1
J E N N IF E R K A Y S H IP M A N
Petitioner,
M O T IO N T O C O R R E C T S C R IV E N E R S
ERROR
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and
13
Respondent.
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I. M o tio n
15
T h e undersigned m oves the court for an order correcting scriveners error. T h e
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17
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Agreed O rder Motion for Revision entered on June 28, 2 0 1 3 , contains a scrivener's error
at P ag e 2, Lines 17-25.
At the tim e the A greed O rder w as entered, it w as agreed by and betw een the
20
parties that Mr. S hipm an would pick up the child on Friday, which is A ugust 1 6 th. T h e
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O rder reflects the date of August 17th.
22
D A T E D thi
day of July 2 0 1 3 .
23
24
Daniel N. Cook, W S B A 3 4 8 6 6
O f Attorneys for R esponden t
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Mtn to correct scriveners error (MTAF) - Page 1 of 1

WPF DR 04.0100 Mandatory (7/2009) - RC W 26.09.060;. 110;. 120;. 194
Shipman, Jason
S :\C A S E S 1 \S h ip m a n , J a s o n \D R A F T S \P L E A D IN G S \M o tio n to C o rre c t
Error.docx
Scrivener'S
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
10-3-00961-1
40864038
CME
07-15-13

Cause Number: 1 0 -3 -0 0 9 6 1 -1
Petitioner(s)
vs.
Page 1 of 2

Respondent(s)
Judge/Commissioner: BRIAN TOLLEFSO
Court Reporter: TIMOTHY REGIS
Judicial Assistant/Clerk: Brian Matson
DEPUw
Kathrine Price
Attorney for PlarnfiTT/PSTItioner
Daniel N Cook
SHIPMAN, TYLER
SHIPMAN, HUNTER
Proceeding Set: Motion

Proceeding Outcome: Motion Held
Resolution:
Outcome Date: 07/12/2013 9:19
Clerk's Scomis CodetMTHRG

Proceeding Outcome code:MTHRG

lx c a lc iv il,p b l.d _ c iv ilJ o u m a l_ r e p o r t_ c o v e r
IN T H E S U P E R IO R C O U R T , P IE R C E C O U N T Y , W A S H IN G T O N

MEMORANDUM OF
JOURNAL ENTRY
vs.
Page: 2 of 2
Judge/Commissioner:
BRIAN TOLLEFSON
Judicial Assistant/Clerk: Brian Matson

Court Reporter:TIMOTHY REGIS
July 12, 2 0 1 3 0 9 :1 9 A M A greed order presented and signed
End Datemme: 07/12/13 9:19 AM
JUDGE/COMMISSIONER: BRIAN TOLLEFSON Year 2013
1 c?'-s*. V: - i L
10-3-00961-1
40664039
07-15-13
OR
4
5
FILED
DEPT. 8
IN OPEN COURT
8
9
10
11
12
JUL 12 2013
S U P E R IO R C O U R T O F W A S H IN G T O N
C O U N T Y O F P IE R C E
\B y
N.
In re th e M a rriag e of:
N o. 1 0 -3 -0 0 9 6 1 -1
J E N N IF E R K A Y S H IP M A N ,
n /k /a J E N N IF E R K A Y L U N D
Petitioner
13
and
14
Respondent.
y
deputy /
-----------
O R D E R O N M O T IO N T O C O R R E C T
S C R IV E N E R S E R R O R
15
R E S P O N D E N T , J A S O N W IL L IA M S H IP M A N , having presented a motion for o rd er to
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17
18
19
correct scriveners error to this court. T h e court having considered the motion, testim ony
and th e court file, and finding good cause, It is O rdered.
T h e A greed O rd er Motion for Revision entered on June 28, 2 0 1 3 , contains a scriveners
20
error at P ag e 2, Lines 1 7-25 .
21
read as follows:
22
23
24
T h e Agreed O rd er Motion for Revision is hereby corrected to
*F a th e r will h ave one-tim e additional residential tim e in sum m er 2 0 1 3 as follows:

August 16 at 5 :0 0 p.m. pick up from A m y Edw ards hom e through August 20 at
10:00 pm drop off at paternal grandparents. T h e 8 /1 6 pick-up at Edwards is a
o ne-tim e a g re e m e n t only.
25
Order correcting Scriveners error - Page 1 of 2
S :\C A S E S 1 \S h ip m a n , J a s o n \D R A F T S \P L E A D IN G S \D is s o \O rd e r C o rre c tin g S c riv e n e r's
E rm r.d o c
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
253-581-0894
1
This corrected order shall have the full force and effect and sam e rights and
2
3
4
5
6
7
Presented by:
8
9
Approved for entry:

Notice for presentation waived:
FA U B IO N , R E E D E R , FR A LE Y
& C O O K , P.S.
10
11
12
A R IE L N. CO O K, W S B A # 3 4 8 6 6
aJ.
CJUl
H R IN E P ty C E , W S B A # 44389
13
14
15
16
17
18
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20
21
22
23
24
25
Order correcting Scrivener's error - Page 2 of 2

S : \ C A S E S 1 \ S h i p r m n , J a s o n \ D R A F T S \ P L E A D I N G S \ D i s s o \ O r d e r C o r r e c tin g S c r i v e n e r 's
Brwr-doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
253-581-0660
253-581-0894
E-FILED


KEVIN STOCK
No. 10-3-00961-1
COUNTY CLERK
ORDER SETTING CASE SCHEDULE

Type of case:
DIC
Petitioner(s)
Vs.
Track Assignment:
Assignment Department:
Docket Code:

Respondent(s)
Notice of Adequate Cause & Note for Comm Cal filed w/Petition or no later than
Modification of Custody
AREN
ORSCS
2/10/2015
2/24/2015
Adequate Cause Hearing on Commissioner Calendar to be held. (If this hearing is not held by this date,
petition will be dismissed)
Set Settlement Conference Date with Judge/Commissioner BRIAN TOLLEFSON
4/7/2015
Certificate of Parenting Class - Petitioner's (Must be filed on or before)
4/7/2015
Certificate of Parenting Class - Respondent's (Must be filed on or before)
4/7/2015
Requesting Party's Disclosure of Primary Witnesses
6/9/2015
4/7/2015
Non-Requesting Party's Disclosure of Primary Witnesses
6/30/2015
Disclosure of Rebuttal Witnesses
7/14/2015
7/28/2015
Week of 9/8/2015

Discovery Cutoff
9/15/2015
Exchange of Witness and Exhibit Lists and Documentary Exhibits
9/29/2015
10/13/2015 9:00
Trial
Unless otherwise instructed, ALL Attorneys/Parties shall report to the trial court at 9:00 AM on
the date of trial.
If the case has been filed, the plaintiff shall serve a copy of the Case Schedule on the defendant(s) with the summons and complaint/
petition: Provided that in those cases where service is by publication the plaintiff shall serve the Case Schedule within five (5) court days
of service of the defendant's first response/appearance. If the case has not been filed, but an initial pleading is served, the Case Schedule
shall be served within five (5) court days of filing. See PCLR 3.
All attorneys and parties shall make themselves familiar with the Pierce County Local Rules, particularly those relating to case
scheduling. Compliance with the scheduling rules is mandatory and failure to comply shall result in sanctions appropriate to the
violation. If a statement of arbitrability is filed, PCLR 3 does not apply while the case is in arbitration.
Dated: February 3, 2015
Judge FAMILY COURT - 2

Department AREN
E-FILED
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)

Name: JENNIFER LUND
Address: 2323 7TH ST #U101 PUYALLUP, WA 98373
Phone: (253) 606-3039

Involved Party
Show Cause
Nature of Hearing: Parenting Plans, Restraining Orders
CALENDAR DATE: Monday, May 04, 2015
9:00 AM

DATED:
February 3, 2015.
Signed:
NAME:
Phone:
(253) 686-3971

YELM, WA 98597
WSBA#:
For:
1 of 1
E-FILED
February 03 2015 12:06 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)

Name: JENNIFER LUND
Address: 2323 7TH ST SE #U101 10-3-00961-1, WA 98374
Phone: (253) 606-3039

Involved Party
Show Cause
Nature of Hearing: Parenting Plans, Restraining Orders
CALENDAR DATE: Wednesday, March 04, 2015
9:00 AM

DATED:
February 3, 2015.
Signed:
NAME:
Phone:
(253) 686-3971

YELM, WA 98597
WSBA#:
For:
1 of 1
rv'i
OJ

County of Pierce
In re:
J'fihiivfW Wtu
Liuv|
O
ip
no
Petitioner,
and
ID-3-CW UH
A c c e p ta n c e o f S e rv ic e
(A C S R )
O cjon UTilhawi
1.
A c c e p ta n c e o f S e rv ic e
[Name] accepts service of:

M the summons and petition in this action.'
[ ] a proposed order of child support.
[ ] proposed Child Support Worksheets.
proposed parenting plan.

[] a financial declaration.
r f
L
' ^ other prfrhfli A br W w m a z w A OTOn
Or- {WremiKA pw i/c
^
C o n s e n t to P e rs o n a l J u ris d ic tio n
[ ] Does not apply.

[] __________________________
[ ] Other
3.
* MT#F
[Name] consents to personal jurisdiction.
O th e r
Dated: t i l
IS
Y .'r h U /A
ature of Party or Lawyer /WSBA No. Accepting Service
Print or Type Name
Notice to party: You may list an address that is not your
residential address where you agree to accept legal documents.
Any time this address changes while this action is pending,
you must notify the opposing parties in writing and file an
updated Confidential Information Form (WPF DRPSCU
09.0200) with the court clerk.
[Address]
Acceptance o f Sen/ice (ACSR) - Page 1 o f 1

WPF DRPSCU 01.0310 (6/2006)
- V
rOi
OJ1
10-3-00961-1
44069309
C * F F* E
FEB 03

County of
In re:
Jennifer Lund
N o. 1 0 -3 -0 0 9 6 1 -1
Petitioner,
and
Jason Shipman
S u m m o n s (M o d ific a tio n /
A d ju s tm e n t o f C u s to d y
D e c re e /P a re n tin g P la n /
Respondent.
R e s id e n tia l S c h e d u le )
(S M )_________________________________
To.
Jennifer Lund
1.
2.
You must respond to this notice and petition by serving a copy of your written response on the
person signing this summons and by filing the original with the clerk of the court. If you do not
serve your written response within 20 days (or 60 days if you are served outside of the state of
Washington) after the date this summons was served on you, exclusive of the day of service, the
court may enter an order of default against you, and the court may, without further notice to you,
enter an order regarding adequate cause and a decree to modify/adjust the custody decree/parenting
plan/residential schedule and providing for other relief requested in the petition. If you serve a
notice of appearance on the undersigned person, you are entitled to notice before an order of
default or a decree may be entered.
3.
v
[x]
[]
Temporary residential placement or custody is not being sought.

Temporary residential placement or custody is being sought. If adequate cause is found,
the court may proceed immediately to hear the motion for temporary placement/custody or
may continue the matter to a later time.

WPF DRPSCU 07.0120 Mandatory (7/2007) - CR 4.1; R C W 26.09.270; 26.10.020
4.
hearing. If you do not file an opposing declaration or respond and the court finds that adequate
cause exists, the court may enter an adequate cause order and an order modifying/adjusting the
26.09.270.
5.
Your written response to the summons and petition must be on form WPF DRPSCU 07.0200,
Response to Petition for Modification/Adjustment of Custody Decree/Parenting Plan/Residential
Schedule. This form may be obtained by contacting the clerk of the court at the address below, by
contacting the Administrative Office of the Courts at (360) 705-5328, or from the Internet at the
Washington State Courts homepage:
6.
http://www.courts.wa.gov/forms
signing this notice. Within 14 days after you serve the demand, the petitioner must file this action
with the court, or the service on you of this notice and motion will be void.
7.
If you wish to seek the advice of an attorney in this matter, you should do so promptly so that your
written response, if any, may be served on time.
One method of serving a copy of your response on the petitioner is to send it by certified mail with
return receipt requested.
Dated: -3 ,^
/ S ____________
Print Name
F ile o r ig in a l o f y o u r r e s p o n s e w ith
S e rv e a c o p y o f y o u r re s p o n s e on.
t h e c le r k o f t h e c o u r t a t
Moving Party [You may list an address that is not

"'your residential address where you agree to accept
legal documents. Any time this address changes while
this action is pending, you must notify the opposing
parties in writing and file an updated Confidential
Information Form (WPF DRPSCU 09.0200) with the
court clerk ]
[ ] Moving Partys Lawyer
[Name of Court]
'~5cjc} G ^
[Name]
[Address]
[Address]
SC\

WPF DRPSCU 07.0120 Mandatory (7/2007) - CR 4.1; RCW 26.09.270; 26.10.020
___________
F IL E D
N '
^fcK
PIERCE COUNTYSUPERIORCOURT
KEVINSTOCK
CLERKOF THESUPERIORCOURT
TACOMAfcJA
III
,
10-3-00961-1
44069310
02-04-15
$PTMDG
FILED
_______ JNTY CLERKS OFFICE

a.m.
FEB 0 3 2015
10-3-00961-1
p .m.
ftcpt. Date
02/03/2015

KEVIN S i.j^ lfv C o u n ty Clerk
BY_____ / V f \
DEPUTY
(M
n
U)
Receipt/Ites it Tran-Code
2015-03-01029/01 1104
Cashier: MLR
Paid By: shipman, jason
Transaction Ainount:

County of
In re:
UT
P e titio n fo r M o d ific a tio n /

A d ju s tm e n t o f C u s to d y D e c re e /
P a re n tin g P la n /R e s id e n tia l
S c h e d u le
(PTM D)
Petitioner,
and
0-1
Para. 2.14: check box if petition is

attached for:
O rder fo r protection DV (PTORPRT)
O rder fo r protection UH (PTORAH)
Respondent.
e
1.1
<p o 9 < / ~ /
N o.
L iSW ^
f\
Acct, Date
Time
02/03/2015 10:43 AM
Id e n tific a tio n o f R e q u e s tin g P a rty /P a rtie s
Name (first/last)
P&'zGcn
Last known residence (county and state only)
_____________ Birth date $
P'
Name (first/last)____________________;_____________
~KC>
___________ .
Birth date
Last known residence (county and state only)____________

1 .2
Id e n tific a tio n o f O th e r P a rty /P a rtie s
Name (first/last) _
'/-f s /
_ Birth date.
Last known residence (county and state only)_

Name (first/last) _________________________________________ Birth date
Last known residence (county and state only)____________________________
Name (first/last) _ _ ______________________________________ Birth date______________
Last known residence (county and state only)_____________________________.
WPF DRPSCU 07.0100 Mandatory (03/2013) - CR 4.1; R C W 26.09.181; .260; .270, RC W 26.26.130(7)(b)
Docket-Code
tFFR
$56.00
1.3
D e p e n d e n t C h ild re n
Name (first/last)
H u W / tV '
Age
Name (first/last)
_Age
Name (first/last)
Age
Name (first/last)
Age
Name (first/last)
Age
Name (first/last)
Age
'
2.1
II. B a s is
P e titio n fo r a n O rd e r M o d ify in g C u s to d y D e c re e /P a re n tin g P la n /R e s id e n tia !

S c h e d u le
This is a petition for an order modifying the prior custody decree/parenting plan/residential
schedule/judgment establishing parentage and approving my proposed parenting plan/residential
schedule, which is filed with this petition.
2 .2
The court entered a judgment and order establishing parentage on

(date)__________________ at (county and state)________________________
under cause number______________ and did not enter a Parenting Plan or Residential
Schedule at the same time. I attached a copy of the order establishing parentage if it was filed in another county or state.
A d e q u a te C a u s e
There is adequate cause for hearing the petition for modification.

2 .3
C h ild S u p p o rt
2 .4
Does not apply.

Child support should be modified or established if the court grants the petition to modify
the parenting plan or residential schedule. A child support worksheet and financial
declaration must be filed with this action. RCW 26.09.170.
J u ris d ic tio n a n d V e n u e
The court has proper jurisdiction and venue.

Hie requesting party/parties reside(s) in (county and state only)________________________ .
The children reside in (county and state only)_____________________________________ .
The other party/parties reside(s) in (county and state only)____________________________

WPF DRPSCU 07.0100 Mandatory (03/2013) - CR 4.1; R C W 26.09.181; .260; .210, R C W 26.26.130(7)(b)
2 .5
J u ris d ic tio n O v e r P ro c e e d in g
This court has jurisdiction over this proceeding for the reasons below:
This court has exclusive continuing jurisdiction. The court has previously made a child
custody, parenting plan, residential schedule or visitation determination in this matter and
retains jurisdiction under RCW 26.27.211.
the children lived in Washington with a parent or a person acting as a parent for at
least six consecutive months immediately preceding the commencement of this
proceeding.
the children are less than six months old and have lived in Washington with a .
parent or a person acting as parent since birth - - ^
'J v ' - *
.any absences from Washington have been only temporary.
Washington was the home state of the children within six months before the
commencement of this proceeding and the children are absent from the state but a
parent or person acting as a parent continues to live in this state.
The children and the parents or the children and at least one parent or a person acting as a
parent have significant connection with the state other than mere physical presence, and substantial evidence is available in this state concerning the childrens care, protection,
training and personal relationships, and:
.
|~1
The children have no home state elsewhere.,

,
The childrens home state has declined to exercise jurisdiction on the ground that
this state is the more appropriate forum under RCW 26.27.261 or .271.
All courts in the children's home state have declined to exercise jurisdiction on the ground
that a court of this state is the more appropriate forum to determine the custody of the
children under RCW 26.27.261 or .271.
No other state has jurisdiction.
This court has temporary emergency jurisdiction over this proceeding because the children
are present in this state and the children have been abandoned or it is necessary in an
emergency to protect the children because the children, or a sibling or parent of the children
is subjected to or threatened with abuse. RCW 26.27.231.
.
There is a previous custody determination that is entitled to be enforced under

this chapter or a child custody proceeding has been commenced in a court of a
state having jurisdiction under RCW 26.27.201 through 26.27.221. The
requirements of RCW 26.27.231(3) apply to this matter. This states jurisdiction
over the children shall last until (date)____________________________ .
There is no previous custody determination that is entitled to be enforced under

this chapter and a child custody proceeding has not been commenced in a court
of a state having jurisdiction under RCW 26.27.201 through 26.27.221. If an

action is not filed in (potential home state)_________________________

by the time the child has been in Washington for six months,
(date)_______________________ ;_____, then Washington's jurisdiction
will be final and continuing.
2 .6
Other:
U n ifo rm C h ild C u s to d y J u ris d ic tio n a n d E n fo rc e m e n t A c t In fo rm a tio n
Name of Child
Parents Name
Parents Name
During the last five years, the children have lived:

in no place other than the state of Washington and with no person other than the requesting
party or the other party.
in the following places with the following persons (list each place the children lived,
including the state of Washington, the dates the children lived there and the names of the
persons with whom the children lived. The present addresses of those persons must be
listed in the required Confidential Information Form.):
Claims to custody or visitation:
The requesting party does not know of any person other than the other party who has
physical custody of, or claims to have custody or visitation rights to, the children.
The following persons have physical custody of, or claim to have custody or visitation
rights to, the children (list their names and the children concerned below and list their
present addresses in the Confidential Information Form. Do not list the other party.):
The requesting party has not been involved in any other proceeding regarding the children.
The requesting party has been involved in the following proceedings regarding the children
(list the court, the case number, and the date of the judgment or order):

Ul
Other legal proceedings concerning the. children:
/vr^
'a .-
[U
The requesting party does not know of, any other legal proceedings concerning the
children.
The requesting party knows of, the following legal proceedings that concern the children
(list the children concerned, the court, the case number, and the kind of proceeding):
T'i
CU
U\
2 .7
H
O
C u s to d y D e c re e o r P a re n tin g P la n /R e s id e n tia l S c h e d u le
The Custody Decree/Parenting Plan/Residential Schedule was entered on (date)____________ _

at (county and state) ______________________________ _____ . A certified copy of the
Custody Decree/Parenting Plan /Residential Schedule to be modified is filed with or attached to this
petition, if the decree or plan to be modified was entered in another county or state.
2 .8
M o d ific a tio n U n d e r R C W 2 6 .0 9 .2 6 0 (1 ), (2)
cA ~-
Does not apply.

The custody decree/parenting plan/residential schedule should be modified because a
substantial change of circumstances has occurred in the circumstances of the children or the
other party and the modification is in the best interests of the children and is necessary to
serve the best interests of the children. This request is based on the factors below.
The parties agree to the modification.
The children have been integrated into my family with the consent of the other
party in substantial deviation from the decree/parenting plan/residential schedule.
The childrens environment under the custody decree/parenting plan/residential
schedule is detrimental to the childrens physical, mental or emotional health and
the harm likely to be caused by a change in environment is outweighed by the
advantage of a change to the children.
2.9
/
The other party has been found in contempt of court at least twice within three A
years because the party failed to comply with the residential time provisions in the
court-ordered parenting plan, or the parent has been convicted of custodial
interference in the first or second degree under RCW 9A.40.060 or 9A.40.070.
Modification o r A djustm ent Under RCW 26.09.260(4) or (8)
Does not apply.

WPF DRPSCU 07.0100 Mandatory (03/2013) - CR4.1; RCW 26.09.181; .260; .270, RCW 26.26.130(7) (b)
2 .1 0
The custody decree/parenting plan/residential schedule should be modified because the

reduction or restriction of the residential time for the person with whom the child does not
reside a majority of the time would serve and protect the best interests of the child using the
criteria in RCW 26.09.191, as described here:
The custody decree/parenting plan/residential schedule should be adjusted because the

nonresidential party has voluntarily failed to exercise residential time for one year or more
and the adjustment is in the best interest of the children.
A d ju s tm e n ts to R e s id e n tia l P ro v is io n s U n d e r R C W 2 6 .0 9 .2 6 0 (5 )(a ) a n d (b)
Does not apply.

The custody decree/parenting plan/residential schedule should be adjusted because a
substantial change in circumstances of either parent or of the child has occurred and the
proposed modification to the custody decree/parenting plan/residential schedule is in the
best interest of the children and is a minor modification in the residential schedule that does
not change the residence the children are scheduled to reside in the majority of the time
and:
2.11
is not more than 24 full days in a calendar year; or
i I
is based on a change of residence of the parent with whom the child does not reside
a majority of the time or an involuntary change in work schedule by a party which
makes the residential schedule in the parenting plan impractical to follow.
A d ju s tm e n ts to R e s id e n tia l P ro v is io n s U n d e r R C W 2 6 .0 9 .2 6 0 (5 )(c ), (7), (9)
Does not apply.
T h is s e c t io n o n ly a p p lie s to a p e r s o n w ith w h o m th e c h ild d o e s n o t re s id e a

m a jo r ity o f th e tim e w h o is s e e k in g to in c r e a s e r e s id e n tia l tim e .
2.11.1 Parent subject to limitations under RCW 26.09.191(2) or (3)
The residential time of (name)____________________________________is not

subject to limitations.

The residential time of (name)_______________________________ is subject to

limitations. This parent demonstrates a substantial change in circumstances specifically
related to the basis for the limitation.
2.11.2 Parent Required to Complete Evaluations, Treatment, Parenting or Other Classes
(Name)__________________________ is not required under the existing Parenting

Plan/Residential Schedule to complete evaluations, treatment, parenting or other classes.
(Name)_______________________ , is required by the existing Parenting
Plan/Residential Schedule to complete evaluations, treatment, parenting or other classes.
This parent has fully complied with such requirements as described here:
2.11.3 Adjustment to Residential Provision Under RCW 26.09.260(5)(c)
2 .1 2
The Custody Decree/Parenting Plan/Residential Schedule should be adjusted because a

substantial change in circumstances of (parents name)_________________________
or (children)s name(s))____________________________________________has
occurred. The proposed modification to the Custody Decree/Parenting Plan/Residential
Schedule is in the best interest of the children. It is a minor modification in the residential
schedule that does not change the residence the children are scheduled to reside in the
majority of the time. The increase is more than 24 full days but less than 90 overnights per
year total. The Custody Decree/Parenting Plan/Residential Schedule does not provide
reasonable time with the nonprimary residential party.
A d ju s tm e n ts to N o n re s id e n tia l P ro v is io n s U n d e r R C W 2 6 .0 9 .2 6 0 (1 0 )
Does not apply.
The following nonresidential provisions of the parenting plan should be adjusted because
there is a substantial change of circumstances of either party or of the children and the
adjustment is in the best interest of the children:
0
0
0
0
Dispute resolution.
Decision making.
Transportation arrangements.
Other:

2 .1 3
S u b s ta n tia l C h a n g e in C irc u m s ta n c e
(You m u st com plete th is p a rt i f yo u request a m odification o r adjustm ent in

paragraphs 2.8, 2.10, 2.11.1, 2.11.3 o r 2.12.)
The requested modification or adjustment of the custody decree/parenting plan/residential schedule

is based upon the following substantial change in circumstance:
T W
c l n '/ i
h f c t,
dfi-e* d t ^
i*l
c \r < fv ih y
2 .1 4
;s
n /r'
S e tte e )
v u * i * tj j /o
v jo W
P ro te c tio n O rd e r
Does not apply.

There is a protection order between the parties filed in case number______________ ,
court________________________ , which expires on (date)__________________ .
The court should grant the domestic violence QJ antiharassment petition for order for
protection:
Q attached to this petition.

filed separately under this case number case number________________ .
2 .1 5
S e r v ic e m e m b e r s C iv il R e lie f A c t S ta te m e n t
2.15.1 A. Service member status (name of other party)______________ -___________ :

is not a service member;
is on active duty in the U.S. armed forces (excluding National Guard and
reserves);
is on active duty and is a National Guard member or a Reservist residing in
Washington;
is not on active duty in the U.S. armed forces (excluding National Guard and
reserves);
is not on active duty and is a National Guard member or a Reservist residing in
Washington;
lam unable to determine whether the other party is or is not on active duty in the
U.S. armed forces;
lam unable to determine whether the other party is or is not on active duty as a
National Guard member or a Reservist residing in Washington.
B. Factual basis:
See the attached Department of Defense Manpower Data Center Status Report
Pursuant to Servicemembers Civil Relief Act (SCRA) obtained from
https://www.dmdc.osd.mil/appi/scra/. (You must have the persons social
security number to search in this site.)
Other factual basis:
c.
As indicated above, the other party is on active duty and (check all that apply):
The other party is represented by an attorney.
The court has appointed an attorney to represent the other party.
A stay of these proceedings has has not been entered by the court.
2.15.2 A. Dependent of a service member status (name of other party)_______________

is a dependent of a resident of Washington who is on active duty and is a
is not a dependent of a resident of Washington who is on active duty and is a
I am unable to determine whether the other party is a dependent of a resident of
Washington who is on active duty and is a National Guard member or a
Reservist.
B. Factual basis:
The other party failed to respond to a notice to him or her as a dependent of a
person in Military Service that was served on mailed by first class mail on
(date) ____________________________________ , therefore he or she
should be presumed not a dependent of a resident of Washington who is on
active duty and is a National Guard member or a Reservist.
Other factual basis:
C. As indicated above, the nonmoving party is a dependent of a resident of
Washington who is on active duty and is a National Guard member or a
Reservist and (check all that apply):
The nonmoving party is represented by an attorney.
The court has appointed an attorney to represent the nonmoving party.
A stay of these proceedings has has not been entered by the court.
2.16
Other
111. R e lie f R e q u e s te d
(A
The moving party requests that the court find that there is adequate cause for hearing this petition arid enter
an order modifying the custody decree/parenting plan/residential schedule in this matter and approving the
proposed parenting plan/residential schedule, which is filed with this petition.
The moving party also requests that the court:
Enter an order establishing child support in conjunction with the proposed parenting
plan/residential schedule. The child support worksheet and financial declaration are filed
with this petition.
Enter a domestic violence protection order.
Enter an antiharassment protection order.
Other:
*
if
i*;
Date
/$Tgnatftre of Requesting Party or Lawyer/WSBA No. Print Name
Signature of Requesting Party or Lawyer/WSBA No. Print Name
Date
j (state)
______ on (date)
___.
Print Name
Signed at (city) ______________________ , (state)__________on (date)__________________ .
Signature of Requesting Party
Print Name
J o in d e r
i,_______________ ________ , join in the petition. I understand that by joining in the petition,
a decree or judgment and order may be entered in accordance with the relief requested in the
petition unless, prior to the entry of the decree or judgment and order, a response is filed and
served.
1waive notice of entry of the decree.
n \

WPF DRPSCU 07.0100 Mandatory (03/2013) - CR 4. 1; R C W 26.09.181; .260;.270, R C W 26.26.130(7)(b)
I demand notice of all further proceedings in this matter. Further notice should be sent to
the following address (you may list an address that is not your residential address where
you agree to accept legal documents):
Any time this address changes while this action is pending, you must notify the opposing parties
in writing and file an updated Confidential Information Form (WPF DRPSCU 09.0200) with the
court clerk.
Date
Signature
Print Name
I,_______________________ , join in the petition. I understand that by joining in the petition,

1 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.
_
, .
'
v
.
Lj , I waive notice of entry of the decree.
you agree to accept legal documents): .
, court clerk.
, /
Date
Signature
'
Print Name
' I,________________ .______ , join in the petition. I understand that by joining in the petition,
a decree or judgment and order may be entered in accordance with the relief requested in the
petition unless, prior to the entry of the decree or judgment and order, a response is filed and
served.
I waive notice of entry of the decree.

you agree to accept legal documents):
court clerk.
Date
Signature
Print Name

tr
WITTMO
10-3-00961-1
02-04-15
44069312

a m.
FEB 0 3 2015
p.m.

K, Count} Clerk
KEVIN STOCK,/County
.DEPUTY
BY
I'M
f"';

County of
[x] In re the Marriage of:
[ ] In re the Domestic Partnership of:
Ui
N o . 1 0 -3 0 0 9 6 1 -1
Jenifer Lund
CJ
Petitioner,
and
Jason Shipman
M o tio n a n d D e c la ra tio n fo r
T e m p o r a r y O rd e r
(M T A F )
Respondent.
I. M o tio n
Based on the declaration below, the undersigned moves the court for a temporary order which:
[]
[]
[x]
[]
[]
[x]
[]
[]
orders temporary maintenance.

orders child support as determined pursuant to the Washington State child support statutes.
approves the parenting plan which is proposed by the [ ] petitioner [x] respondent.
approves the Temporary Residential Time re Military Parents proposed by the [ ] petitioner
[ ] respondent pursuant to RCW 26.09.260(11), (12).
restrains or enjoins the [ ] petitioner [ ] respondent from transferring, removing, encumbering,
concealing or in any way disposing of any property except in the usual course of business or for
the necessities of life and requiring each party to notify the other of any extraordinary expenditures
made after the order is issued.
Restrains or enjoins the [x] petitioner [ ] respondent from disturbing the peace of the other party or
of any child.
restrains or enjoins the [ ] petitioner [ ] respondent from going onto the grounds of or entering the
home, work place or school of the other party or the day care or school of the following named
children:
restrains or enjoins the [ ] petitioner [ ] respondent from knowingly coming within or knowingly
remaining within (distance)__________________ of the home, work place or school of the
other party or the day care or school of the following children:
Mtn/Decl for Temp Ord (MTAF) - Page 1 o f 4

WPF DR 04,0100 Mandatory (06/2014) - RCW 26.09.060;. 110;. 120;. 194
[]
restrains or enjoins [ ] petitioner [ ] respondent from assaulting, harassing, stalking or molesting the
other party or the children, or using attempting to use, or threatening to use physical force against
the other party or the children that would reasonably be expected to cause bodily injury, or
engaging in other conduct that would place the other party in reasonable fear of bodily injury to the
other party or children. (If the court orders this relief, the restrained person may be prohibited
from obtaining or possessing a firearm, other dangerous weapon, concealed pistol license, or
ammunition under state or federal law for the duration of the order.)
[j
[J
[]
[]
[]
[]
[j
[]
[]
(If th is b o x is checked yo u m ust com plete paragraph 2.3 in the declaration below.)
requires the [ ] petitioner [ ] respondent to surrender any firearm, other deadly weapon, and
concealed pistol license in his or her immediate possession or control or subject to his or her
immediate possession or control to the sheriff of the county having jurisdiction of this proceeding,
to his or her lawyer or to a person designated by the court.
restrains or enjoins the [ ] petitioner [ ] respondent from removing any of the children from the
state of Washington.
restrains or enjoins the [ ] petitioner [ ] respondent from assigning, transferring, borrowing,
lapsing, surrendering or changing entitlement of any insurance policies of either or both parties
whether medical, health, life or auto insurance.
makes each party immediately responsible for their own future debts whether incurred by credit
card or loan, security interest or mortgage.
divides responsibility for the debts of the parties.
authorizes the family home to be occupied by the [ ] petitioner [ ] respondent.
orders the use of property.
requires the [ ] petitioner [ ] respondent to vacate the family home.
requires the [ ] petitioner [ ] respondent to pay temporaiy attorney fees, other professional fees and
costs in the amount of $___
___ to:
[x]
Appoints a guardian ad litem on behalf of the minor children.
[]
other:
Si
No.
Print or Type Name
II. D e c la ra tio n
Mtn/Decf for Temp Ord (MTAF) - Page 2 o f 4

WPF DR 04.0100 Mandatory (06/2014) - R C W 26.09.060; .110;. 120;. 194
rty or Lawyer/WSBA
2.1
Temporary relief is required because:
T lie .
C.U. ) d
iw
rtm kx!
tiw A .
P h ///C ^ f
e /~
~\ h e -
1d
i 5
f o r < y
1-0
O c tr e e
2.2
[]
If a Temporary Residential Time re Military Parents is requested, and I request delegation

of residential time or visitation rights to a nonparty, to the best of my knowledge, that
person
[ ] would
[ ] would not
be subject to limitations on residential time under RCW 26.09.191. (See paragraph 2.1
and 2.2 of the parenting plan.)
2.3
[]
If the surrender of firearms, other deadly weapons, and concealed pistol license is
requested, please explain (check and complete all that apply):
[]
Has the other party used, displayed, or threatened to use a firearm or other
dangerous weapon in a felony? Describe:
[]
Has the other party previously committed an offense that makes him or her
ineligible to possess a firearm under the provisions of RCW 9.41.040? Describe:
[]
Does possession of a firearm or other dangerous weapon by the other party

present a serious and imminent threat to public health or safety, or to the health or
safety of any individual? Describe:
Mtn/Decl for Temp Ord (MTAF) - Page 3 o f 4

WPF DR 04.0100 Mandatory (06/2014) - RCW 26.09.060;. 110;. 120;. 194
2.4
[]
If the other party is not present and:

a) is on active duty and is a National Guard member or Reservist residing in Washington,
or
b) is a dependent of a National Guard member or Reservist residing in Washington on
active duty, list the reasons why this temporan, order should be granted despite the
absence of the other party:
correct.
j, (state)
Do n o t attach fin a ncia l records, p e rsonal health care records o r co n fidential reports to
th is declaration. Such records s h o u ld be served on the o th e r p a rty and file d w ith the
co u rt using one o f these co ve r sheets:
1) Sealed Financial Source Docum ents (WPF DRPSCU 09.0220) fo r financial records
2) Sealed Personal Health Care R ecords (WPF DRPSCU 09.0260) fo r health records
3) Sealed C onfidential R eport (WPF DRPSCU 09.270) fo r confidential reports
If file d separately using a co ve r sheet, the records w ill be sealed to p ro te c t y o u r p riva cy
(although they w ill be available to a ll parties in the case, th e ir attorneys, co u rt personnel
and certain state agencies and boards.) See GR 22(C)(2).
Mtn/Decf for Temp Ord (MTAF) - Page 4 o f 4

WPF DR 04.0100 Mandatory (06/2014) - R C W 26.09.060; .110;. 120;. 194
FILED
INOPENCOUR'f
TPROTSC
10-3-00961-1
x
El! PARTE DEP.ASTislEW?
02-*'15
44069322
FEB 0 3 2015
PIERCE COUNTS Clark
A
j2^L
DEWY

County of
W f/ty
re the Marriage of:
[] In re the Domestic Partnership of:
No. (O
Petitioner,
and
~y<=t'?Or1
3^ 7'
^Respondent.
O o *? 6 /
E x P a rte R e s tra in in g O rd e r/
O rd e r to S h o w C a u s e
(T P R O T S C /O R T S C )

[ j Law Enforcement Notification, tf
4.1,4.3
Restraining Order'Summary:
[ ] Does not apply.
[ ] Restraining Order Summary is set forth below:
Name of person(s) restrained:
person(s) protected:
H Uw4
rV /
>
icisyt A
Q
. Name of
See p a ra g ra p h 4.1.
Violation o f a R estraining O rder in paragraph 4.1 below w ith actual knowledge o f its
term s is a c rim in a l offense u n d e r Chapter 26.50 RCW and w ill su b je ct the violator to
a rre s t RCW 26.09.060.
i. S h o w C a u s e O rd e r
It is Ordered th^p^Lpetitioner [ ] respondent appear and show cause, if any, why the restraints below
should not be continued in full force and effect pending final determination of this action and why the other
relief, if any, requested in the motion should not be granted. A hearing has been set for the following date,
time and place:
N
*")
Time:
MWdR/ rJiAf . T -^z0a // 5
i / SUPERjQft COURT
CQiiR1
Place: _____*
Room/Department:
r o ptJUif.
If you disagree wit$
ofidie[nfiff&Tiijiyou must respond to the motion in writing before the
hearing and by the dil^&îhiWAu6 gQ0ty. At the hearing, the court will consider Written sworn
affidavits or declarations. Oral testimony may Not be allowed. To respond you must: (1) file your
documents with the court; (2) provide a copy of those documents to the judge or commissioners
staff; (3) serve the other partys attorney with copies of your documents (or have the other party
served if that party does not have an attorney); and (4) complete your filing and service of documer
within the time period required by the local court rules in effect in your county. If you need more
information, you are advised to consult an attorney or a courthouse facilitator.
Date:
Ex Parte Restraining Ord (TPROTSC/ORTSC) - Page 1 of 4

WPF DR 04.0170 Mandatory (6/2014) - CR 65 (b); R C W 26.09.060
Failure to appear m ay result in a Temporary Order being entered b y the co u rt that grants
the re lie f requested in the m o tio n w ithout fu rther notice.
II. B a s is
A motion for a temporary restraining order without written or oral notice to the^petitioner
[ ] respondent or that partys lawyer has been made to this court.
^
III.
F in d in g s
The court adopts paragraphs 2.1, 2.2, and 2.4 of the Motion/Declaration for an Ex Parte Restraining Order
and for an Order to Show Cause (Form WPF DR 04.0150) as its findings, except as follows:
[]
Further, the court finds that the nonrequesting party is absent and a) is on active duty as a National
Guard member or Reservist residing in Washington, or b) is a dependent of a National Guard
member or Reservist residing in Washington on active duty. Despite the service members or
dependents absence, failure to enter the temporary orders below would result in manifest injustice
to the other interested parties.
IV .
O rd e r
It is Ordered:
4.1
R e s tra in in g O rd e r
Violation o f a R estraining Order in paragraph 4.1 with actual notice o f its terms
is a crim inal offense u nder Chapter 26.50 RCW and w ill su bject the violator to
arrest. RCW 26.09.060.
[]
i H
Does not apply.

. The^Jetitioner'^respondent is restrained and enjoined from:
K
disturbing the peace of the other party or of any child.
[]
going onto the grounds of or entering the home, work place or school of the
other party or the day care or school of the following protected children:
knowingly coming within or knowingly remaining within
(distance)_______________________ of the home, work place or school
of the other party or the day care or school of the protected children,
assaulting, harassing, stalkingfTir molesting the other party or the children, or
using, atfembting to use, onmreaiening to use physical/erce against the other
partwor the children that/wouldReasonably be expected to cause bodily injuryDor
engaging in >ther conduct thatôuld place the^pther pjcty in reasonable fearjof
the childra
)dily injur
"elief after'the hearing, the restrained person
If the doupforders
may be prohibited from objafffing or possessine a'firearm, other
dangerous weapon, concealed pistol licenser'franimunition undei
state or federal law for the duration of the order.
Ex Parte Restraining Ord (TPROTSC/ORTSC) - Page 2 of 4

Clerk's A ction. The clerk of the court shall forward a copy of this order, on or before
the next jud<cUl^blrfto (ame^>fjthfe apgrapnate law enforcement agency)
_______ {Jj&sivlAfi. i / v / which shall enter this order into any
computer-based criminal intelligence system available in this state used by law
enforcement agencies to list outstanding warrants. (A law enforcement information
sheet must be completed by the party or the partys attorney and provided with
this order before this order will be entered into the law enforcement computer
system.)
Service
The requesting party must arrange for service of this order on the restrained party. File the
original Return of Service with the clerk and provide a copy to the law enforcement agency
listed above.
Full Faith and Credit
Pursuant to 18 U.S.C. 2265, a court in any of the 50 states, the District of Columbia, Puerto
Rico, any United States territory, and any tribal land within the United States shall accord full
faith and credit to the order.
4 .2
O th e r R e s tra in in g O rd e rs
[]
[]
[]
CHk
c f4 -
4 .3
S u rre n d e r o f F ire a rm o r o th e r D a n g e ro u s W e a p o n s
[]
[]
4 .4
The [ ] petitioner [ ] respondent is restrained and enjoined from transferring, removing,

encumbering, concealing or in any way disposing of any property except in the usual
course of business or for the necessities of life and requiring each party to notify the other
of any extraordinary expenditures made after the order is issued.
The [ ] petitioner [ ] respondent is restrained and enjoined from removing any of the
children from the state of Washington.
The [ ] petitioner [ ] respondent is restrained and enjoined from assigning, transferring,
borrowing, lapsing, surrendering or changing entitlement of any insurance policies of either
or both parties whether medical, health, life or auto insurance.
The^êtitione^^re^pQj'^fiHffphall be the parent with whom the children) reside until
the hearing.
Other:
Does not apply.

It is ordered that (name)______________________ ^ surrender any firearm or other
dangerous weapon in his or her immediate possession or control or subject to his or her
immediate possession or control to the person or agency named in the Order to Surrender
Weapon (Issued without Notice) signed by the court on this date, under this cause number.
E x p ira tio n D a te
This order shall expire on the hearing date set forth above or 14 days from the date of issuance,
which ever is sooner, unless otherwise extended by the court.
Ex Parte Restraining Ord (TPROTSC/ORTSC) - Page 3 o f 4
4 .5
W a iv e r o f B o n d
[ y . Does not apply.

[/jV
flHng 0f a bond or the posting of security is waived.
Print or Type Name
Date
M i
K jD
Ex Parte Restraining Ord (TPROTSC/ORTSC) - Page 4 o f 4

,
,
10-3-00961-1
44071636
CME
EX
02-04-15
FILED
OPEN COURT
PARTE DEPARTMENT
FEB 0 3 2015
PIERCE MWTV, Clerk;
vBy
k pu t T


Petitioner(s)
vs
Respondent(s)
Judge/Commissioner: ROBYN LINDSAY

Judicial Assistant: Stephanie Meelap
Kathrine Price
Daniel N Cook

SHIPMAN, TYLER
SHIPMAN, HUNTER
Proceeding Date: Feb 3, 2015 9:21 AM

Resolution:
Clerk's Code: MTHRG
Amended Resolucton code:
M em ornadum o f Journal Entry.

Page 1 o f 2
1 0 -3 -0 0 9 6 1 -1

vs


Judge/Commissioner: ROBYN LINDSAY
Start Date/Time: Feb 3, 2015 9:22 AM
Judicial Assistant: Stephanie Meelap

F E B R U A R Y 3, 2 01 5 09:21 A M - R E S P O N D E N T JASON S H IP M A N A P P E A R S B E FO R E TH E
C O U R T W IT H A R E Q U E S T FO R AN E X P A R TE R E S T R A IN IN G O R D E R . T H E C O U R T W ILL
C O N S ID E R T H E R E Q U E S T A F T E R A P E T IT IO N TO M O D IF Y IS FILED.
10:54 A M - BACK O N TH E R E C O R D . C O U R T R E Q U IR E S N O T IC E A N D D IR E C T S
R E S P O N D E N T TO C S D -R O O M 140 TO HAVE CALL PLACED.
11:12 A M - BACK O N T H E R E C O R D . P E T IT IO N E R J E N N IF E R S H IP M A N IS N O W
P R E S E N T . BOTH P A R TIE S A R E S W O R N . C O U R T R E V IE W S JIS. 11:12 A M - O P E N IN G
S T A T E M E N T BY R E S P O N D E N T A B O U T SO N E X C E S S IV E A B S E N C E FRO M S C H O O L. 11:13
A M - C O U R T IN Q U IR E S W H E N BOTH P A R TIE S P A R TIC IP A TE D IN M E D IA TIO N . 1 1 :15 A M R E S P O N S E BY P E T IT IO N E R E X P LA IN IN G S O N S A B S E N C E . 11:17 A M - C O U R T O R D E R E D
THAT:
NO C H A N G E IN C U S T O D Y
T H E P A R TIE S A R E TO P A R TIC IP A TE IN M E D IA TIO N P E N D IN G H E A R IN G
C H ILD TO BE E N R O LLE D IN C O U N S E L IN G IM M E D IA TE LY , BOTH P A R E N TS TO
P A R T IC IP A TE
BO TH P A R E N TS A R E TO C O M M U N IC A T E BY T E X T M E S S A G E S ; NO B LO CKING OF
TEXT M ESSAGES
H E A R IN G TO BE S C H E D U L E D FO R M A R C H 4TH
11:23 A M - M O T H E R A G R E E S TO A C C E P T S E R V IC E IN C O U R T.
End Date/Time: Feb 3, 2015 11:24 AM
Memornadum of Journal Entry.

Pagc2 o f 2
E-FILED
PIERCE COUNTY, WASHING
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
3
4
5
6
7
8
COUNTY OF PIERCE
10
11
12

13
and
14

_________________________ Respondent.
No. 10-3-00961-1
Petitioner,
15
16

ORDER CONTINUING HEARING
MOTION
17
COM ES NOW the Respondent, JASON SHIPMAN, by and through his attorney of
18
record, Daniel N. Cook, of FAUBION, REEDER, FRALEY & COOK, P.S., and respectfully
19
moves the Court for an Order Continuing the show cause hearing set for March 4, 2015,
20
on Respondents Motion for Temporary Order.
21
22
Respectfully submitted this^ 7 day of February 2015.

FAUBION, REEDER, FRALEY, & COOK, P.S.
23
24
25
By: Daniel N. Cook, W SBA 34866

Motion for Order to Continue Hearings- Page 1 of 2
S:\CASES1\Shipman, Jason\DRAFTS\PLEADINGS\Motion to Continue Hearing.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
1
2
My name is Daniel Cook and I am the attorney of record for the Respondent
3
4
5
JASON SHIPMAN in this matter.

JASON SHIPMAN, acting pro se, filed a Petition for Modification and a Motion for
Temporary Order against JENNIFER LUND on February 3, 2015, and he noted a
hearing on the motion for March 4, 2015. An Ex Parte Restraining Order was issued on
February 3 as well, which ordered the parties to attend mediation before the hearing. At
this time, the parties have not been able to attend mediation, nor is one scheduled.
10
11
12
On February 23, 2015, JASON SHIPMAN retained me to represent him in this

matter. I have a vacation scheduled out of the country and will not be able to attend the
March 4 hearing.
13
I request that the hearing in this matter be continued to March 31 to allow the
14
parties to attend mediation, and for me to prepare for a hearing if the parties do not
15
16
17
18
reach an agreement at the mediation.

19
20
21
22
Daniel N. Cook, W SBA 34866

23
24
25
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
PIERCE COUNTY, WASHING
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
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COUNTY OF PIERCE
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and
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_________________________ Respondent.
No. 10-3-00961-1
Petitioner,
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ORDER CONTINUING HEARING
MOTION
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COM ES NOW the Respondent, JASON SHIPMAN, by and through his attorney of
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record, Daniel N. Cook, of FAUBION, REEDER, FRALEY & COOK, P.S., and respectfully
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moves the Court for an Order Continuing the show cause hearing set for March 4, 2015,
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on Respondents Motion for Temporary Order.
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Respectfully submitted this^ 7 day of February 2015.

FAUBION, REEDER, FRALEY, & COOK, P.S.
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By: Daniel N. Cook, W SBA 34866

FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
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My name is Daniel Cook and I am the attorney of record for the Respondent
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JASON SHIPMAN in this matter.

JASON SHIPMAN, acting pro se, filed a Petition for Modification and a Motion for
Temporary Order against JENNIFER LUND on February 3, 2015, and he noted a
hearing on the motion for March 4, 2015. An Ex Parte Restraining Order was issued on
February 3 as well, which ordered the parties to attend mediation before the hearing. At
this time, the parties have not been able to attend mediation, nor is one scheduled.
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On February 23, 2015, JASON SHIPMAN retained me to represent him in this

matter. I have a vacation scheduled out of the country and will not be able to attend the
March 4 hearing.
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I request that the hearing in this matter be continued to March 31 to allow the
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parties to attend mediation, and for me to prepare for a hearing if the parties do not
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reach an agreement at the mediation.

I DECLARE UNDER PEN ALTY OF PER JUR Y UNDER THE LAWS OF THE
STATE OF W A SH IN G TO N THAT THE FO REG OING IS TRUE A ND CORRECT.
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Daniel N. Cook, W SBA 34866

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FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
Phone: (253) 581-0660
E-FILED
March 02 2015 10:35 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)
Show Cause
Nature of Hearing:
Parenting Plans,PARE~Parenting Plans
CALENDAR DATE: Thursday, April 09, 2015
9:00 AM

DATED:
March 2, 2015.
Signed:
/s/ Daniel N Cook
Daniel N Cook
Phone:
(253) 581-0660
NAME:
W SBA#:
34866
For:
1 of
E-FILED
PIERCE COUNTY, WASHING!
March 04 2015 11:52 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
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County of Pierce
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No. 10-3-00961-1

Petitioner,
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and
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Petitioners Notice of
Hearing for Adequate Cause
Determination
(Optional Use)
(NTHG)
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_________________________ Respondent.
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To th e C le rk o f C o u rt a n d to. J e n n ife r L u n d
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1.
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Please note that the court will be asked to determine if adequate cause exists to
modify/adjust the custody decree/parenting plan/residential schedule as requested
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in the petition filed in this case.
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2.
A hearing has been set for the following date, time and place.
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Date: April 9, 2015
Time: 9:00 a.m.
Place: Pierce County Superior Court Room/Department: TBD
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3.
This request is based on the declaration in the Petition for Modification/Adjustment
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of Custody Decree/Parenting Plan/Residential Schedule and on the additional

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declarations served on the nonmoving party.
Petitioners Not of Hrng (Adequate Cause) (NTHG) - Page 1 of 1

W PF DRPSCU 07.0250 (6/2006) - R C W 26.09.260; .270; 26.10.200

S:\CASES1\Shipman, Jason\DRAFTS\PLEADINGS\Notice of Hearing re Adequate
Cause.doc

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
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4.
You may serve and file a response and opposing declarations prior to the hearing
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date. If the court determines that adequate cause for hearing the petition is
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established by the declarations, it will set a date for hearing on an order to show
cause why the petition should not be granted.
5.
If you do not file a response to the petition, opposing declarations, or a notice of
appearance, an order may be entered without further notice to you finding you in
default and granting the relief requested in the petition.
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Presented by:
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Petitioners Not of Hrng (Adequate Cause) (NTHG) - Page 2 of 1

W PF DRPSCU 07.0250 (6/2006) - R C W 26.09.260; .270; 26.10.200
S :\C A S E S 1 \S h ip m a n , J a s o n \D R A F T S \P L E A D IN G S \N o tic e o f H e a rin g re A d e q u a te
C a u s e .d o c

& COOK, P.S.
Lakewood, WA 98499
253-581-0660
E-FILED
March 04 2015 11:55 AM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1


No. 10-3-00961-1
Petitioner(s),
vs.

Respondent(s)
Adequate Cause - Custody

Nature of Hearing: Parenting Plans
CALENDAR DATE: Thursday, April 09, 2015
9:00 AM

DATED:
March 4, 2015.
Signed:
/s/ Daniel N Cook
Daniel N Cook
Phone:
(253) 581-0660
NAME:
WSBA#:
For:
34866
1 of
E-FILED
PIERCE COUNTY, WASHING!
March 04 2015 1:43 PM
KEVIN STOCK
COUNTY CLERK
NO: 10-3-00961-1
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IN THE SU PER IO R COURT OF THE STATE OF W A SH IN G TO N

IN AND FOR THE CO U NTY OF PIERCE
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In re:
No. 10-3-00961-1
Petitioner,
DECLARATIO N OF M AILING
and
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JASON W ILLIAM SHIPMAN,

_________________________ Respondent.
I, Sally DuCharme, am over the age of 18, and competent to testify in the
above entitled case.
On March 4, 2015, I placed in the U.S. Mail a copy of the following
documents in the above-entitled caption:
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1. Note for Commissioners Calendar on April 9, 2015; and

2. Notice of Adequate Cause Hearing.
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Said documents were addressed to:
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Jennifer Lund
2323 7th St SE U101
Puyallup, W A 98374
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I declare, under the penalty of perjury and the Laws of the State of Washington,
that the foregoing is true and correct.
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DATED
March 4, 2015
S 'A
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-<___________
Sally DiCRarme, Legal Assistant

Declaration Of Mailing
S:\CASES1\Shipman, Jason\DRAFTS\PLEADINGS\Declaration of Mailing.doc
FAUBION, REEDER,
FRALEY & COOK, P.S.
Lakewood, WA 98499
Phone: (253) 581-0660

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E-FILED

IN COUNTY CLERK'S OFFICE

SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY

Case Number 10-3 -096 1-1__________

Phone (253) 770-0808

Address 4115 S. MERIDIAN, SUITE B_______

Adoption (ADP 5) Non PCLR

____Invalidity (INV 3) FAM LAW

Absentee (ABS 4) REV 4

Foreign Judgment Domestic (FJU 3)Non PCLR

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

JASON WILLIAM SHIPMAN

Friday, July 16, 2010 9:00 AM

DATED: March 15, 2010

Superior Court of Washington

Petition for Dissolution

JASON WILLIAM SHIPMAN

Name: Jennifer Shipman,

Last known residence Pierce County, WA

Birth date February 16, 1974

Name: Jason Shipman,

Last known residence Pierce County, WA

Birth date August 20, 1972

Children of the Marriage Dependent Upon Either or Both Spouses

'ETITION FOR DISSOLUTION

LA W OFFICES OF GREENE & LLOYD, PLLC

This marriage isirretrievably broken.

Date and Place of Marriage

Allegation Regarding Marriage

This court has jurisdiction over the respondent because:

The respondent is presently residing in Washington.

Tire petitioner and respondent lived in Washington during their marriage

Debts and Liabilities

The division of debts and liabilities should be determined by the court at a

Each party shall pay their debts incurred since separation.

LA W OFFICES OF GREENE & LLOYD, PLLC

Spousal maintenance should not be ordered.

Continuing Restraining Order

The wife is not pregnant.

Note: Under RCW 26.26.116. the husband is the presumed father. If

Jurisdiction Over the Children

any absences from Washington have been only temporary.

Child Support and Parenting Plan for Dependent Children

LA W OFFICES OF GREENE & LLOYD, PLLC

is attached and is incorporated by reference as part of this Petition.

Claims to custody or visitation:

Involvement in any other proceeding concerning the children:

Other legal proceedings concerning the children:

u . W OFFICES OF GREENE & LLOYD, PLLC

arfothy M] Greene, WSBA #17499

Signed at Puyallup, WA on March 10, 2010

u . W OFFICES OF GREENE & LLOYD, PLLC

W OFFICES OF GREENE & LLOYD, PLLC

Superior Court of Washington

JENNIFER KAY SHIPMAN

JASON WILLIAM SHIPMAN

To the Respondent: JASON WILLIAM SHIPMAN

LAW OFFICES OF GREENE c LLOYD, PLLC

DATED THIS 10,h day of March 2010